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Uranerz Jane Dough Amendment Volume IV Environmental Report

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Uranerz Jane Dough Amendment Volume IV Environmental Report
Nichols Ranch ISR Project
U.S.N.R.C Source Material
SUA- 1597
Jane Dough Amendment
Volume IV
Environmental Report
Chapters 1.0-10.0
Uranerz
ENERGY CORPORATION
Uranerz Energy Corporation
PO Box 50850
Casper, WY 82605-0850
307-265-8900
April 2014
Uranerz Energy Corporation
Jane Dough Unit
JANE DOUGH UNIT
URANIUM SOLUTION MINE
Campbell and Johnson Counties, Wyoming
Volume IV
(Environmental Report)
U.S.N.R.C. Source Material License Application
April 2014
April 2014
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TABLE OF CONTENTS
Pagze
1.0 IN TR O D U C T IO N ........................................................................................................
1.1 G E N E RA L ........................................................................................................
1.2 PURPOSE AND NEED FOR PROPOSED ACTION .....................................
1.3 THE PROPOSED ACTION .............................................................................
1.4 APPLICABLE REGULATORY REQUIREMENTS, PERMITS, AND
REQUIRED CONSULTATIONS ...............................................................
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2.0 A LT ER N AT IV E S .........................................................................................................
2.1 DETAILED DESCRIPTION OF THE ALTERNATIVES ..............................
2.1.1 N o A ction A lternative ........................................................................
2.1.2 Proposed A ction .................................................................................
2.1.3 Alternatives Considered But Eliminated From Detailed Analysis ....
2.1.3.1 Conventional Underground or Open-pit Mining ................
2.1.3.2 Alternative Recovery Solutions ..........................................
2.1.3.3 Groundwater Restoration Alternatives ...........................................
2.1.3.4 Liquid Effluent Disposal Alternatives ................................
2.2 CUMULATIVE EFFECTS ..............................................................................
2 .2 .1 L and U se ...........................................................................................
2.2.2 T ransportation ....................................................................................
2.2.3 Geology and Soil Resources .............................................................
2.2.4 W ater R esources ...............................................................................
2.2.4.1 Surface Water Resources ...................................................
2.2.4.2 Groundwater Resources .....................................................
2.2.5 Ecological Resources ........................................................................
2.2.6 A ir Q uality Resources .......................................................................
2 .2 .7 N o ise .................................................................................................
2.2.8 Historic, Cultural, and Paleontological Resources ...........................
2.2.9 V isual R esources ...............................................................................
2.2.10 Socioeconomics (Including Environmental Justice) .......................
2.2.11 Public and Occupational Health ......................................................
2.2.12 Waste M anagem ent .........................................................................
2.3 COMPARISON OF THE PREDICTED ENVIRONMENTAL IMPACTS ...
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3.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT .........................................
3.1 L A N D U S E ......................................................................................................
3.1.1 Site Location and Layout ..................................................................
3.1.2 Uses of Lands in and Adjacent the Project Area ..............................
3.1.2.1 G eneral ...............................................................................
3.1.2.2 Livestock G razing ..............................................................
3.1.2.3 R ecreation ..........................................................................
3.1.2.4 W ater R ights ......................................................................
3.1.2.5 Industrial - Energy and Mineral Development ..................
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TABLE OF CONTENTS (Continued)
Page
3.2 TRAN SPORTATION ......................................................................................
3.3 GEOLOGY AND SOIL RESOURCES ..........................................................
3.3.1 Geology .............................................................................................
3.3.2 Soils ...................................................................................................
3.4 WATER RESOURCES (INCLUDING SURFACE WATER, WETLANDS,
AN D GROUN DW ATER) ..........................................................................
3.5 ECOLOGICA L RESOURCES ........................................................................
3.5.1 Topography .......................................................................................
3.5.2 Vegetation .........................................................................................
3.5.2.1 General ...............................................................................
3.5.2.2 Federal Threatened, Endangered, Proposed and Candidate
Plant Species ......................................................................
3.5.3 W ildlife .............................................................................................
3.5.3.1 General ...............................................................................
3.5.3.2 Federal Threatened, Endangered, Proposed and Candidate
Anim al Species ..................................................................
3.6 METEOROLOGY AND AIR QUALITY RESOURCES ...............................
3.6.1 Introduction .......................................................................................
3.6.2 Tem perature ......................................................................................
3.6.3 Precipitation ......................................................................................
3.6.4 W ind ..................................................................................................
3.6.4.1 W ind Speed ........................................................................
3.6.4.2 W ind Speed Frequency ......................................................
3.6.4.3 W ind Direction ...................................................................
3.6.4.4 W ind Direction Frequency .................................................
3.6.5 Hum idity ...........................................................................................
3.6.6 Evaporation .......................................................................................
3.6.7 Severe W eather .................................................................................
3.6.8 Effects of Local Terrain ....................................................................
3.6.9 Air Quality ........................................................................................
3.7 NOISE ..............................................................................................................
3.8 HISTORIC, CULTURAL, AND PALEONTOLOGICAL RESOURCES .....
3.8.1 Historic and Cultural Resources .......................................................
3.8.1.1 Class I Literature Search for the Jane Dough Unit ............
3.8.2 Paleontological Resources ................................................................
3.9 VISUA L RESOURCES ...................................................................................
3.10 SOCIOECONOMICS (INCLUDING ENVIRONMENTAL JUSTICE) ......
3.11 PUBLIC AN D OCCUPATIONAL HEA LTH ...............................................
3.11.1 Background Radiation ....................................................................
3.11.2 Major Sources and Levels of Background Chemicals ....................
3.11.3 Occupational Health ........................................................................
3.11.4 Regional Public Health Studies ......................................................
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TABLE OF CONTENTS (Continued)
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3.12 WASTE MANAGEMENT ............................................................................
4.0 ENVIRONMENTAL IMPACTS ................................................................................
4.1 L A N D U SE ......................................................................................................
4.1.1 Proposed Action ................................................................................
4.1.2 N o A ction A lternative .......................................................................
4.2 TRANSPORTATION ......................................................................................
4.2.1 Proposed Action ................................................................................
4.2.1.1 Introduction ........................................................................
4.2.1.2 Transportation Incidents ....................................................
4.2.1.3 Shipment of Refined Yellowcake ......................................
4.2.1.4 Shipments of Loaded Resin ...............................................
4.2.1.5 Shipment of Process Chemicals .........................................
4.2.1.6 Shipment of 11 e(2) By-product Material for Disposal ......
4.2.1.7 Transporting Employees To and From Project Site ...........
4.2.2 N o Action A lternative .......................................................................
4.3 GEOLOGY AND SOIL RESOURCES ..........................................................
4.3.1 Proposed A ction ................................................................................
4.3.2 N o A ction A lternative .......................................................................
4.4 WATER RESOURCE (INCLUDING WETLANDS) ....................................
4.4.1 Proposed Project ...............................................................................
4.4.1.1 Surface Water Impacts .......................................................
4.4.1.2 Ephemeral Drainages Impacts ...........................................
4.4.1.3 Groundwater Impacts .........................................................
4.4.2 N o A ction A lternative .......................................................................
4.5 ECOLOGICAL RESOURCES ........................................................................
4.5.1 Proposed A ction ................................................................................
4.5.1.1 Threatened, Endangered, Proposed, and
C andidate Species ..............................................................
4 .5.1.2 W ild life ..............................................................................
4.5.1.2.1 B ig G am e ............................................................
4.5.1.2.2 Upland Game Birds, Shorebirds, and Waterfowl
4.5.1.2.3 Mammalian Predators, Lagomorphs, and Small
M am m als ............................................................
4.5.1.2.4 Raptors and Nongame/Migratory Birds ..............
4.5.1.2.5 Reptiles and Amphibians ....................................
4.5.1.3 V egetation Im pacts ............................................................
4.5.2 N o A ction A lternative .......................................................................
4.6 AIR QUALITY RESOURCES ........................................................................
4.6.1 Proposed A ction ................................................................................
4.6.2 N o A ction A lternative .......................................................................
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TABLE OF CONTENTS (Continued)
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4.7 NOISE ..............................................................................................................
4.7.1 Proposed Action ................................................................................
4.7.2 No Action Alternative .............................................................................
4.8 HISTORIC, CULTURAL, AND PALEONTOLOGICAL RESOURCE
IM PACTS ...................................................................................................
4.8.1 Proposed Action ...............................................................................
4.8.1.1 Historic and Cultural Resources ........................................
4.8.1.2 Paleontological Resources .................................................
4.8.2 No Action Alternative .......................................................................
4.9 VISUAL RESOURCES ...................................................................................
4.9.1 Proposed Action ................................................................................
4.9.2 No Action A lternative .......................................................................
4.10 SOCIOECONOMICS (INCLUDING ENVIRONMENTAL JUSTICE) ......
4.10.1 Proposed Action ..............................................................................
4.10.2 No Action Alternative .....................................................................
4.11 PUBLIC AN D OCCUPATIONAL HEA LTH ...............................................
4.11.1 Proposed Action ..............................................................................
4.11.2 No Action Alternative .....................................................................
4.12 W A STE M ANAGEM ENT ............................................................................
4.12.1 Proposed Project .............................................................................
4.12.3 No Action Alternative .....................................................................
5.0 M ITIGATION M EA SURE S .......................................................................................
5.1 INTRODUCTION ...........................................................................................
5.2 GROUN DW ATER RESTORA TION .............................................................
5.2.1 W ater Quality Criteria .......................................................................
5.2.2 Restoration Criteria ...........................................................................
5.2.3 Groundwater Restoration M ethods ...................................................
5.2.3.1 Groundwater Transfer ........................................................
5.2.3.2 Groundwater Sweep ...........................................................
5.2.3.3 Groundwater Treatm ent .....................................................
5.2.3.4 Restoration M onitoring ......................................................
5.2.4 Restoration Stability M onitoring Stage ............................................
5.2.5 W ell Abandonm ent ...........................................................................
5.3 SURFACE RECLAMATION AND DECOMMISSIONING .........................
5.3.1 Introduction .......................................................................................
5.3.2 Surface Disturbance ..........................................................................
5.3.3 Topsoil Handling and Replacem ent ..................................................
5.3.4 Vegetation Reclam ation Practices ....................................................
5.3.5 Road Reclam ation .............................................................................
5.3.6 Site Decontam ination and Decom m issioning ...................................
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TABLE OF CONTENTS (Continued)
Page
5.3.6.1 Wellfield........................................................
5.3
5.4
5.5
5.6
5.3.6.2 Plant D ism antling ...............................................................
5.3.7 Final C ontouring ...............................................................................
5.3.8 Financial A ssurance ..........................................................................
CULTURAL RESOURCE MITIGATION .....................................................
W ILD LIFE M ITIG A TIO N ..............................................................................
WATER PROTECTION MEASURES ...........................................................
SO LID W A STE DISPO SAL ...........................................................................
6.0 ENVIRONMENTAL MEASUREMENTS AND MONITORING PROGRAMS ......
6.1 RADIOLOGICAL MONITORING .................................................................
6.1.1 Surface Soil., Subsurface Soils and Sediment ...................................
6.1.1.1 Purpose and Procedure .......................................................
6.1.1.2 Sam pling M ethodology ......................................................
6.1.1.3 Results for the Jane Dough Unit ........................................
6.1.2 Baseline G am m a Survey ...................................................................
6.1.2.1 Purpose and Procedure .......................................................
6.1.2.2 Survey M ethodology ..........................................................
6.1.2.3 Jane Dough Unit Results ....................................................
6.1.3 Baseline Radon-222 and Direct Gamma Exposure Rates .................
6.1.3.1 Purpose and Procedure .......................................................
6.1.3.2 Survey M ethodology ..........................................................
6.1.3.3 Results for Jane Dough Unit ..............................................
6.1.3.4 Background Gamma Exposure Rate ..................................
6.1.4 Flora and Fauna .................................................................................
6.1.4.1 Purpose and Procedure .......................................................
6.1.4 .2 M ethods ..............................................................................
6.1.4.3 Results for the Jane Dough Unit ........................................
6.1.5 R adon Flux ........................................................................................
6.1.6 Quality Assurance .............................................................................
6.1.6.1 C ollection ...........................................................................
6.1.6.2 Analysis ..............................................................................
6.1.6.3 R esults ................................................................................
6.2 PHYSIOCHEMICAL GROUNDWATER MONITORING ...........................
6.2.1 G roundw ater M onitoring ..................................................................
6.2.1.1 Regional Groundwater Monitoring ....................................
6.2.1.2 Pre-Operational Wellfield Assessment ..............................
6.2.1.3 M onitor W ell Spacing ........................................................
6.2.1.4 Production Area Pump Test ...............................................
6.2.1.5 Production Area Pump Test Document .............................
6.2.1.6 Baseline Water Quality Determination ..............................
6.2.1.6.1 D ata C ollection ...................................................
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TABLE OF CONTENTS (Continued)
Page
6.2.1.7 Statistical Assessment of Baseline Water Quality Data ....
6.2.1.8 Restoration Target Values ..................................................
6.2.1.9 U pper Control Lim its .........................................................
6.2.1.10 Calculation of Upper Control Limits ...............................
6.2.1.11 Operational Groundwater Monitoring Program ...............
6.2.1.11.1 Monitoring Frequency and Reporting ...............
6.2.1.11.2 Water Quality Sampling and
Analysis Procedures ..........................................
6.2.1.11.3 Excursions .........................................................
6.2.2 Q uality A ssurance .............................................................................
6.2.2.1 Sam ple Collection ..............................................................
6.2.2.2 Sam ple A nalysis .................................................................
6.2.2.3 R esults ................................................................................
6.3 ECOLOGICAL MONITORING .....................................................................
6.3.1 W ild life .............................................................................................
6.4 NO ACTION ALTERNATIVE .......................................................................
7.0 CO ST
7.1
7.2
7.3
7.4
BEN EFIT AN A LY SIS .....................................................................................
G EN E RA L .......................................................................................................
QUANTIFIABLE ECONOMIC IMPACTS ....................................................
ENVIRONMENTAL COSTS .........................................................................
SU M M A R Y .....................................................................................................
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8.0 SUMMARY OF ENVIRONMENTAL CONSEQUENCES .......................................
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9.0 RE FE RE N C E S ............................................................................................................
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10.0 LIST O F PREPA RE R S ..............................................................................................
10.1 U R A N E R Z .....................................................................................................
10.2 TRC ENVIRONMENTAL CORPORATION ...............................................
10.3 CRAIG HOLMES CONSULTING ...............................................................
10.4 OMEGA PROJECT SERVICES ...................................................................
10.5 HYDRO-ENGINEERING, LLC ...................................................................
10.6 WILDLIFE RESOURCES, LLC ...................................................................
10.7 BKS ENVIRONMENTAL ASSOCIATES, INC ..........................................
10.8 STRATIGRAPHIC REX, LLC .....................................................................
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LIST OF FIGURES
Page
Figure ER3-1 Monthly Temperature Comparison, for the Jane Dough Unit ....................
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Figure ER3-2 Monthly Wind Speed Statistics, Baseline (Year 1) and Year 2
Comparison for the Jane Dough Unit .........................................................
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Figure ER3-3 Wind Rose Comparison, Baseline (Year 1) and Year 2 for the
Jane Dough Unit .........................................................................................
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Figure ER3-4 Wind Speed Frequency Distributions Year 1 and Year 2 for the
Jane Dough U nit .........................................................................................
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Figure ER3-5 Nichols Ranch Wind Direction Frequency Distributions
Y ear I and Y ear 2 .......................................................................................
Figure ER3-6 Construction Equipment Noise Levels .......................................................
Figure ER5-1 Letter from Wyoming Game and Fish Department ....................................
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LIST OF TABLES
Pat2e
Table ER2-1
Summary Comparison of Potential Environmental Impacts ......................
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Table ER3-1
Nearest Residents to the Jane Dough Unit ..................................................
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Table ER3-2
Vegetation/Habitat Types, Number of Acres, and Sampling Intensity,
Jane D ough U nit, 20 10 ...............................................................................
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Table ER3-3
Mean Monthly Temperatures for Jane Dough Unit ....................................
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Table ER3-4
A verage Precipitation V alues .....................................................................
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Table ER3-5
Comparison of Measured Noise Levels with Commonly Heard Sounds ...
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Table ER3-6
Cultural Resource Inventories Completed Within or near
U ranerz's Jane D ough U nit .........................................................................
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Table ER3-7
Recorded Sites Within or near the Jane Dough Unit ..................................
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Table ER3-8
Cities Within a 50-mile Radius of the Jane Dough Unit ............................
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LIST OF TABLES (Continued)
Page
Table ER3-9
Natural Background Radiation Dose Rates (mrem/year) ...........................
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Table ER3-10 Radiological Exposure from Various Sources in the United States ...........
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Table ER3-11 Radiation Dose Com parisbns ......................................................................
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Table ER3-12 Projected Dose Rates to Hypothetical Receptors at the
License Boundaries and to Public Receptors (Time-Step 4,
M axim um A ctivity Period) .........................................................................
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Table ER4-1
Table ER4-2
Table ER4-3
Bulk Chemicals Required at the Nichols Ranch CPP and
Jane Dough U nit .........................................................................................
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Summary of Project Effects and Management Recommendations
for Sites W ithin the Jane Dough Unit .........................................................
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Projected Dose Rates to Public Receptors (Time-Step 4, Maximum
Activ ity P erio d) ...........................................................................................
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Table ER6-1
Permanent Reclamation Seed M ixture ........................................................
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Table ER6-2
Radiological Background in Surface and Subsurface Soil Jane D ough Unit .........................................................................................
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Table ER6-3
Average Radiological Background Values ..........................................
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Table ER6-4
Subsurface Soils: Radiological Baseline, Jane Dough Unit .......................
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Table ER6-5
Subsurface Soil Radiological Baseline Comparison by
Depth and Sample Site Jane Dough Unit ....................................................
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Table ER6-6 Average Sediment Background Radiological Values .................................
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Table ER6-7
Radiological Baseline in Sediments: Jane Dough Unit ..............................
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Table ER6-8
Gamma Survey Results: Jane Dough Unit ..................................................
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Table ER6-9
Baseline Radon-222 at the Jane Dough Unit Air Monitoring Stations .......
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Table ER6-10 Baseline Gamma Exposure Rate at the Jane Dough Unit
A ir Monitoring Stations ..............................................................................
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Table ER6-11 Radiological Baseline Values in Vegetation: Jane Dough Unit .................
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LIST OF TABLES (Continued)
Pag~e
Table ER6-12 Comparison of Average Baseline Values: Jane Dough,
N ichols Ranch and H ank U nits ...................................................................
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Table ER6-13 Groundwater Baseline Water Quality Parameters and
Analytical M ethods .....................................................................................
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Table ER6-14 Restoration Target V alues ...........................................................................
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ABBREVIATIONS AND ACRONYMS LIST
ALARA
AUMs
BLM
BPT
CaCO3
CBNG
CFR
CO
CO 2
CPA's
CPP
CR
CR-SRH
dBA
EA
EIS
EPA
F-Scale
GEIS
GPS
H2 0 2
HCL
IML
ISR
LAS
mrem
NAAQS
NAGPRA
NaOH
NEPA
NH 3
2014
Apr11 2014
April
As Low As Is Reasonably
Achievable
Animal unit month
Bureau of Land
Management
Best Practical Technology
Calcium Carbonate
Coalbed Natural Gas
Code of FederalRegulations
Carbon monoxide
Carbon dioxide
Core population areas
Central processing plant
Cameco Resources
Cameco's Smith
RanchHighlands
A-weighted decibels
Environmental Assessment
Environmental Impact
Statement
Environmental Protection
Agency
Fuj ita-scale
Generic Environmental
Impact Statement
Global Positioning System
Hydrogen peroxide
Hydrochloric acid
InterMountain Labs
In situ recovery
License Area Sample Site
milli roentgen equivalent
National Ambient Air
Quality Standards
Native American Graves
Protectionand Repatriation
Act
Sodium hydroxide
NationalEnvironmental
Policy Act
Ammonia
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Nmiss
function of numeric missing
values
NO 2
NRC
NRCS
NRHP
NUREG
NWS
03
Pb
Pb-2 10
pCi/g
pCi/l
PM
PM10
PM2.5
POD
ppm
PRB
PSD
Ra-226
Rn-222
RO
RSO
RTVs
SB
SD
SEIS
SERP
S02
SOPs
SS
Stdev
Nitrogen dioxide
Nuclear Regulatory
Commission
National Resources
Conservation Service
National Register of Historic
Places
Nuclear Regulatory Guide
National Weather Service
Ozone
Lead
Lead-210
pico Curies per gram
pico Curies per liter
Particulate matter
Particulate matter
Particulate matter
Plan of Development
parts per million
Powder River Basin
Prevention of Significant
Deterioration
Radium-226
Radon-222
Reverse Osmosis
Radiation Safety Officer
Restoration Target Values
Subsurface Soil Site
Sediment Sample Site
Supplemental
Environmental Impact
Statement
Safety and Environmental
Review Panel
Sulfur dioxide
Standard Operating
Procedures
Surface Soil Site
Standard Deviation
Jane Dough Unit
Uranerz Energy Corporation
ABBREVIATIONS AND ACRONYMS LIST (Continued)
SWPP
Stormwater Pollution
Prevention
TCP
Traditional Cultural
Property
TDS
Total Dissolved Solids
TEPC
Threatened, Endangered,
Proposed, and Candidate
Th-230
Thorium-230
UCLs
Upper Control Limits
Uranerz
Uranerz Energy Corporation
USACE
U.S. Army Corps of
Engineer's
USFWS
U.S. Fish and Wildlife
Service
WDEQ-LQD Wyoming Department of
Environmental Quality-Land
Quality Division
WGFD
Wyoming Game and Fish
Department
WOGCC
Wyoming Oil and Gas
Commission
WSGIT
Wyoming Sage Grouse
Implementation Team
WSHPO
Wyoming State Historical
Preservation Office
WYPDES
Wyoming Pollutant
Discharge Elimination
System
yellowcake
U308
April 2014
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Uranerz Energy Corporation
Jane Dough Unit
1.0 INTRODUCTION
1.1 GENERAL
Uranerz Energy Corporation (Uranerz) plans to license the Jane Dough Unit (Township 43 North,
Range 76 West, portions of Sections 20, 21, 27, 28, 29, 30, 31, 32, 33, and 34) and use the in situ
recovery (ISR) extraction/mining method. The Jane Dough Unit is an amendment to the original
Nichols Ranch ISR project and will add wellfield areas to the overall production of the project.
This is the same method that is used by Uranerz at the adjacent Nichols Ranch Unit and Hank Unit
for the Nichols Ranch ISR Project.
The Jane Dough Unit ore zones will be incorporated in the existing Nichols Ranch ISR Project
into one license. The Nuclear Regulatory Commission (NRC) requires a license under 10 CFR
Part 40 in order to "receive title to, receive, possess, use, transfer, deliver.., any source... material"
therefore a source license must be obtained by Uranerz to produce U30
8
(yellowcake).
A "Permit to Mine" must also be obtained from the Wyoming Department of Environmental
Quality-Land Quality Division (WDEQ-LQD) under the Wyoming Environmental Quality Act,
Article 4. Any permitting or licensing activities required by the Environmental Protection Agency
(EPA) would be carried out by the WDEQ as they are a primacy state with the EPA.
Uranerz plans on starting production in the Jane Dough Unit in 2016. Figure 3-11 (see map pocket)
of the Uranerz, Jane Dough Unit NRC Source Material License Application Technical Report
provides a schedule of planned activities for the Jane Dough Unit.
1.2 PURPOSE AND NEED FOR PROPOSED ACTION
The purpose and the need for the proposed action are to obtain a license for the construction and
operation of facilities for ISR mining and processing. The uranium product produced at the Jane
Dough Unit would be used in the manufacturing of nuclear fuel to be used by the nuclear power
industry. The uranium produced would allow for a domestic source of uranium to be used in
United States nuclear power reactors helping to reduce the need to use foreign energy sources.
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1.3 THE PROPOSED ACTION
The Jane Dough Unit is located in the Pumpkin Buttes Mining District of the Powder River Basin
(PRB) in the state of Wyoming in the counties of Johnson and Campbell. The recovered uranium
would be transported via pipelines to the central processing plant in the Nichols Ranch Unit where
the uranium would be processed.
The Jane Dough Unit contains approximately 3,680 acres. The project site is approximately
46 air mi south/southwest of Gillette, Wyoming and approximately 61 air mi to the north/northeast
of Casper, Wyoming. The general location of the project is shown in Figures 1-1 and 1-3 (see map
pocket) of the NRC Technical Report.
Extraction of the uranium ore contained in the Wasatch formation of the PRB would be through
the in situ recovery method of mining. A sodium carbonate/sodium bicarbonate solution and an
oxidizing agent such as oxygen would be injected and recovered through a complex of well
patterns. 4-spot, 5-spot, and 7-spot well patterns would be used in the ore recovery process. The
wellfield at the Jane Dough Unit is divided into production areas. Construction for each production
area is estimated to take approximately one year and each area would require approximately six
months to ramp up to full production. It will take an estimated 3-4.25 years to extract the uranium
from the Jane Dough Unit.
The NRC has approved the licenses for the Uranerz central processing plant and the plant is online except for final processing and drying. The central processing plant has a nameplate capacity
to produce 2,000,000 pounds per year of yellowcake. Once the uranium has been "loaded" onto
resin beads, the uranium could be processed to yellowcake at the central processing plan or it could
be transported via trucks to Cameco Resources Inc.'s Smith Ranch-Highland central processing
plant for the processing of yellowcake. Cameco Resource Inc.'s Smith Ranch Highland central
processing plant is located about 17 miles north of Glenrock Wyoming in east-central Wyoming.
Uranerz and Cameco Resources Inc. entered into an agreement in 2013 in which Uranerz could
transport
uranium-loaded
resin
beads
to
Cameco
Resource
Inc.'s
Smith
Ranch-Highland Central Processing Plant (CPP), if needed. Uranerz is also approved by NRC for
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its own dryer and will also use its own dryer in the Nichols Ranch CPP should this equipment be
installed. Initially, Uranerz will transport uranium-loaded resin beads from the Nichols Ranch
CPP to Cameco Resource Inc.'s Smith Ranch Highland CPP but at some point this activity would
not be necessary or conducted.
Once mining is completed in a production area, reclamation of that production area would begin.
Figures 3-11 (see map pockets) of the NRC Technical Report show the production areas for the
Jane Dough Unit. Groundwater would be restored to its pre-mining conditions (as is reasonably
achievable) or to its class of use by utilizing groundwater restoration methods such as groundwater
sweep, groundwater transfer, and reverse osmosis. Groundwater reclamation is anticipated to take
approximately three years from start to finish. Solid material such as pipelines, buildings, etc.
would either be reused in different production areas or decommissioned and removed for disposal
at a NRC licensed disposal facility or nearby landfill.
1.4 APPLICABLE REGULATORY REQUIREMENTS, PERMITS, AND REQUIRED
CONSULTATIONS
Various state and federal permits and licenses that are needed or are in-hand for the Nichols Ranch
ISR Project are listed in Chapter 10.0, Table 10-2 of the Uranerz, Nichols Ranch ISR Project NRC
Source Material License Application Technical Report. Prior to the start of mining (the injection
of lixiviant into the ore zone aquifer), Uranerz would obtain all permits, licenses, and approvals
required by the WDEQ and the NRC. The list of additional state and federal permits and licenses
required for the Jane Dough Unit is listed in Table 10-2a in the Nichols Ranch ISR Project NRC
Source Material License Application Technical Report.
The general area of the Jane Dough Unit has also been subject to numerous federal environmental
reviews over the past few years. The Nichols Ranch ISR project area (without the Jane Dough
Unit) was subject to an environmental impact statement (EIS) completed by the NRC in 2011. In
addition, the Bureau of Land Management (BLM) is currently preparing an environmental
assessment (EA) for the Hank Unit due to separate jurisdictional requirements associated with
BLM-administered lands in the Hank Unit. With the presence of coalbed natural gas (CBNG)
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extraction on the land in and adjacent to the permit boundary of the Jane Dough Unit, the area has
been subject to one EIS and two EAs. All of these documents conducted for CBNG-related
projects were completed by the BLM. The environmental analyses for the CBNG activities can
be found at the following BLM website link: http://www.blm.gov/wy/st/en/info/NEPA/
documents/bfo.html.
Anadarko's Dry Willow Phase III EA and Phase V EA contain areas where the Jane Dough Unit
is located. Anadarko's Dry Willow Phase I EA and Phase II EA contain areas where the Hank
Unit is located and WPX Rocky Mountain Energy LLC (formerly Williams Production) underwent
an EA for the Tex Draw Project which contains the land where the Nichols Ranch Unit is located.
The Powder River Basis (PRB) EIS covers the entire Powder River Basin and Exhibits and tables
detailing the location of all CBNG wells that have been completed and those that are permitted in
and adjacent to the permit boundaries are located in Appendix D6, Hydrology, that is attached to
this report.
Detailed additional information on wildlife, cultural and paleontological resources, vegetation,
soils, geology, hydrology, wetlands, land use, history, and a background radiological assessment
of the Jane Dough Unit can also be found in the attached Appendix D. This information is required
by the WDEQ-LQD for an amendment to an existing Permit to Mine.
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2.0 ALTERNATIVES
2.1 DETAILED DESCRIPTION OF THE ALTERNATIVES
2.1.1 No Action Alternative
The no action alternative is one alternative that must be considered under the provisions of the
National Environmental Policy Act (NEPA). No action means that the proposed activity of the
Jane Dough Unit would not take place because the NRC would not issue a license for Jane Dough
Unit. Under the No Action Alternative, uranium ISR extraction would not take place in the Jane
Dough Unit and no environmental impacts associated with the in situ recovery extraction would
occur.
2.1.2 Proposed Action
Uranerz has secured a license for the central processing plant and accompanying wellfields for an
ISR operation with ion exchange columns under NRC license SUA-1597. The applications for
the Jane Dough Unit amendment, operating and reclamation, will be submitted to the NRC and
the WDEQ-LQD.
The Jane Dough Unit is located in the Pumpkin Buttes Mining District of the Powder River Basin
in the state of Wyoming in the counties of Johnson and Campbell. No processing of uranium
would occur in the Jane Dough Unit; rather, uranium would be pumped via pipelines from the
extraction areas to the existing central processing plant located at the Nichols Ranch Unit.
The current land surface ownership of the Jane Dough Unit includes approximately 3,860 acres of
private ownership.
Uranerz estimates the yellowcake content for the Jane Dough Unit to 2,735,000 pounds. The
central processing plant at Nichols Ranch has a nameplate capacity to produce 2,000,000 pounds
per year of yellowcake.
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production and recovery will be dependent on the Nichols Ranch Unit CPP. Construction for the
two production areas is estimated at approximately one year each and it is estimated to take six
months to ramp up to the full. It will take an estimated 4.25 years to extract the uranium from the
Jane Dough Unit. Refer to Figure 3-11 (see map pocket in the NRC Technical Report) of the
Uranerz, Jane Dough Unit NRC Source Material License Application Technical Report for a
schedule of planned activities for the Jane Dough Unit.
The plans for project waste management and disposal are twofold. Uranerz is permitted, through
the State of Wyoming and the EPA Underground Injection Control Program, to install up to eight
deep disposal wells for the Nichols Ranch ISR Project. The deep disposal wells would receive
liquid waste. Uranerz also has an agreement with an approved waste disposal facility for I Ie(2)
byproduct material.
A detailed description of the proposed Jane Dough Unit facilities including process and wellfield
descriptions can be found in Chapter 3.0, Description of the Facilities, in the NRC Technical
Report. Details concerning the reclamation and restoration activities for the proposed Jane Dough
Unit can be found in Chapter 6.0, Reclamation Plan of the NRC Technical Report.
2.1.3 Alternatives Considered But Eliminated From Detailed Analysis
2.1.3.1 Conventional Underground or Open-pit Mining
Alternated methods of mining available for the Jane Dough Unit include underground and openpit mining.
Both of these methods were not considered for the project since they are not
economically feasible for mining of the uranium because of the much larger capital investment
required, the grade of the ore, and the size of the ore zones. Additionally the underground and
open-pit mining methods result in greater environmental impacts to the area along with exposing
employees and the project area to higher safety and health risks.
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The overall impacts of ISR mining compared to conventional and open-pit mining result in several
environmental and socioeconomic advantages.
These advantages were detailed in an NRC
evaluation (NUREG-0925, 1983, Section 2.3.5) and are as follows:
1. The amount of surface area disturbed by in situ mining is significantly less. The amplitude
of disruption is also significantly less.
2. Tailings that result from the milling process are not produced. Additionally the amount of
solid waste produced by the ISR mining method is generally less than 1% of that produced
by conventional milling methods.
3. Air pollution problems caused by ore stock piles, overburden stockpiles, tailings stockpiles,
and crushing and grinding operations in conventional and open-pit mining do not exist with
the ISR mining method.
4. Radiation exposure at an ISR operation is significantly less than that associated with
conventional mining and milling. Operating personnel are not exposed to the radionuclides
present in and emanating from the ore and tailings. Conventional mills tailing can contain
all of the radium-226 originally present in the ore whereas ISR operations may have less
than 5% of the radium in the ore zone being brought to the surface through the recovery
process.
5. The entire mine site can be returned to its original land use more rapidly with ISR mining
methods than those of underground or open-pit mining methods. ISR mines can remove
the solid wastes from the site to a NRC licensed disposal site preventing them from
contaminating the surface and subsurface environment. This is not always possible with
the size and extent of conventional mining.
6. Solution mining results in significantly less water consumption than conventional mining
and milling.
7. Socioeconomic advantages of ISR operations include:
" Ability to mine lower grade ore
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*
Minimum capital investment
*
Less risks to miners
*
Shorter lead time in beginning production, and
*
Minimal staffing requirements
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2.1.3.2 Alternative Recovery Solutions
The alkaline recovery solution (lixiviant) consisting of sodium carbonate/carbon dioxide,
dissolved oxygen or hydrogen peroxide, and groundwater is the preferred recovery solution to be
used in at the Jane Dough Unit. The solution was selected based upon its successful use in
recovering uranium and aquifer restoration in the Nichols Ranch ISR Project, several pilot plant
projects, and commercial ISR operations in the Powder River Basin.
Alternate recovery solutions include ammonium carbonate solutions and acidic solutions. Both of
these solutions have been used in the past in ISR mining operations, but are no longer used because
of safety reasons and the difficulties in restoring and stabilizing the affected ore zone aquifers.
Because of these reasons, the solutions were not considered for the Jane Dough Unit.
2.1.3.3 Groundwater Restoration Alternatives
Uranerz may utilize, but are not limited to, a combination of groundwater sweeps, groundwater
transfer, and Reverse Osmosis for the restoration of groundwater impacted by the Jane Dough
Unit. This method is the chosen method for aquifer restoration because of its successful, proven
use in ISR mining groundwater restoration. It is also considered to be Best Practicable Technology
(BPT) available by the NRC and state regulatory agencies. If future technology advances are made
to produce better alternatives for groundwater restoration, then Uranerz would consider
incorporating these technologies into groundwater restoration.
2.1.3.4 Liquid Effluent Disposal Alternatives
The proposed disposal of liquid effluents is through the injection of the effluents down a deep
disposal well. This method was chosen over other alternatives such as evaporation ponds and land
application (irrigation) facilities because of the environmental impacts and additional land
disturbance that ponds and irrigation have on the project area. There will be no deep disposal
wells located within the Jane Dough Unit.
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2.2 CUMULATIVE EFFECTS
Cumulative impacts result from the incremental effects of an action added to other past, present,
and reasonably foreseeable future actions, regardless of who is responsible for such actions.
Cumulative impacts may result from individually minor but collectively significant actions
occurring over a period of time (40 CFR 1508.7).
2.2.1 Land Use
The Proposed Action would not make a significant contribution to the cumulative land use impacts
in the region. With only 101 acres of disturbance expected during the life of the Jane Dough Unit,
the main disturbance would be to the loss of grazing and wildlife habitat, recreational
opportunities, and mineral and energy development during the life of the project. This disturbance
would be temporary because of the sequential nature of the mining operation and the restoration
and reclamation of the land at the end of the projects life. Because of the nature of ISR mining,
project restoration and reclamation, the combination of existing land disturbance, new disturbance
related to the project, and disturbance from reasonably foreseeable future actions, no significant
cumulative impacts are expected by the proposed project.
2.2.2 Transportation
Shipments of process chemicals to the site and the shipment of product from the site would
contribute to minimal transportation risks on the roads in the region of the development and
operation of the Jane Dough Unit, but the contribution to the cumulative impacts of past, present,
and future actions is not expect to be significant. The overall volume of traffic associated with the
Jane Dough Unit would be low. In addition, the development and operation of the Jane Dough
Unit would likely only add a limited amount of incremental risk because production of the
Jane Dough Unit would occur sequentially to the approved production in the Nichols Ranch ISR
project area and would not add additional volume to traffic that would already occur.
Approximately one tractor-trailer per day from the Nichols Ranch CPP would utilize the roads in
the region of the proposed project along with approximately eight passenger type vehicles. This
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volume of traffic results inr minimal impact to the existing roads that are used by ranchers and
CBNG and conventional oil and gas operators.
2.2.3 Geology and Soil Resources
There are other ISR projects in the region including the Uranerz Nichols Ranch ISR project,
Cameco's North Butte ISR project, and Uranium One Inc.'s Willow Creek and Moore Ranch ISR
projects. ISR mining activities would not result in the removal of any rock matrix or structure.
Therefore, no subsidence would result at the site from the collapse of overlying rock strata in the
mining zone which would happen in underground mining operations. In addition, the NRC's
Generic Environmental Impact Statement (GEIS) determined that it would be unlikely that ISR
operations in the Wyoming East Uranium Milling Region (which includes the Jane Dough Unit
and the other ISR projects) could reactivate local faults and extremely unlikely that ISR operations
could or would cause earthquakes (NRC 2009). Therefore, the Proposed Action would have no
discernible cumulative impacts on geological resources including geological hazards (e.g.,
earthquakes, subsidence, and mass movements).
The Proposed Action would contribute limited impacts on soil resources in the project area,
specially the disturbance of approximately 101 acres of soil resources. Past and current CBNG
and conventional oil and gas development have affected soils that would be located in the Jane
Dough Unit and surrounding region. Both the uranium and coalbed and conventional oil and gas
industry have had to construct access roads to their wells in the project area along with the
installation of pipelines and utility corridors. Even though this has affected the soils in the area, it
has also helped reduce the amount of soil that Uranerz would have to disturb since engineered and
improve exist roads in the project area and region.
The contribution of the 101 acres of disturbance to past, present, and future impacts on soils in the
region is not expected to create a significant cumulative impact to soil resources because Uranerz
is required to decommission and reclaim all disturbance associated with the Proposed Action. As
has been demonstrated at other ISR facilities in Wyoming, the proposed project's contribution to
cumulative impacts on soils would likely be small and temporary.
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2.2.4 Water Resources
2.2.4.1 Surface Water Resources
No surface water would be discharged or collected as part of ISR activities within the Jane Dough
Unit. Potential impacts to onsite ephemeral channels would be from increased surface water
runoff, primarily during the construction and decommissioning phases of the proposed project.
The channels within and surrounding the proposed Hank Unit are ephemeral in nature and flow
only in response to precipitation events or snowmelt (i.e., they are dry a majority of the year). One
wetland area exists on the Jane Dough Unit; however, this area would be avoided and not disturbed
by ISR activities. Approximately 2.47 miles of Waters of the U.S. occur within the Jane Dough
Unit and potential impact to Waters of the U.S. would be mitigated through the implementation of
BMP for the Uranerz WYPDES storm water permit that would obtain from the WDEQ-WQD
before operations commence, securing of coverage under an individual permit or Nationwide
Permit 12 from USACE, and the implementation of appropriate BMPs in the storm water pollution
prevention plan.
Furthermore, Uranerz would avoid installing wells in the channels and washes of ephemeral
drainages.
If a well would be installed in an ephemeral drainage, then appropriate erosion
protection controls would be implemented to minimize damage. Such controls would include:
grading and contouring, culvert installation, low-water crossing constructed of stone, water
contour bars, and designated traffic routes. Other energy development activities within the surface
water study area, namely from CBNG production, conventional oil and production, and uranium
ISR production could also result in limited impacts to wetlands and Waters of the U.S. However,
these potential impacts would be mitigated through implementation of appropriate best
management practices that would be required of all operators through the appropriate permitting
process that have or would be undertake for development activities in the surface water study area.
Therefore, the Jane Dough Unit would have minimal cumulative impacts on surface water
resources.
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2.2.4.2 Groundwater Resources
Potential environmental impacts on groundwater resources from the proposed Jane Dough Unit
would occur primarily during the operation and aquifer restoration phases of the ISR facility
lifecycle.
The detailed analysis of impacts to groundwater resources from operation of
the proposed Jane Dough Unit Project is presented in Section 4.4.1.3 which showed that the water
yields in some private wells located outside of the proposed project area that are completed in the
ore zone aquifer could potentially be affected by the facility's operation at the Jane Dough Unit.
Cumulative impacts that could contribute to the groundwater in the proposed project area include
future ISR operations. Five NRC licensed operations exist in the area near the Nichols Ranch ISR
Project. This includes the North Butte Satellite ISR permit area is located approximately 9 miles
northeast of the Jane Dough Unit. Uranium One Inc.'s Willow Creek (Christensen Ranch/Irigaray)
ISR project area is located approximately 6 mile north of the Jane Dough Unit on the northwest
side of North Pumpkin Butte.
Uranium One Inc.'s Moore Ranch ISR Project is located
approximately 6 mile south of the Jane Dough Unit. Cameco's Reynolds Ranch ISR Satellite and
Smith Ranch-Highland ISR are located approximately 37 and 42 miles southeast of the Jane Dough
Unit, respectively. Additionally, reasonably foreseeable future mining activities by Uranerz have
the potential of being in the same aquifer as the Jane Dough Unit ISR Project. The effect of mining
in the same aquifers in the region of the Nichols Ranch ISR Project could result in temporary
impacts on the groundwater level in the ore zone aquifer and the geochemical change of the ore
zone aquifer chemistry, but not so much as to degrade the aquifer's use. Moreover, Uranerz is
required to install monitoring wells around and within the proposed wellfield, as part of its
license/permit, for early detection, control, and reversal of potential horizontal and vertical
excursions.
Furthermore,
Therefore, the potential risk of impacts on nonexempted aquifers would be low.
after production and aquifer restoration were completed and groundwater
withdrawals were terminated at the proposed Jane Dough Unit Project, the groundwater levels
would recover with time.
BLM estimated that CBNG development in the PRB through the year 2018 would remove about
(3 million acre-feet), less than 0.3% of the total recoverable groundwater (nearly 1.4 billion acrefeet) in the Wasatch and Fort Union Formations within the PRB. Water from CBNG production
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within the Jane Dough Unit is being collected and transported off-site for disposal (i.e., there is no
surface water discharge) (Uranerz 2012).
Cumulative impacts on groundwater resulting from the interaction between ISR activities and
CBNG activities may occur but are not likely because CBNG production and ISR activities are
conducted in stratigraphically separate aquifers. For the proposed Jane Dough Unit Project, the
ISR activities would take place in sandstone aquifers 671 ft above the coal seam. Because of the
presence of multiple layers of sand/sandstone and low-permeable silt/shale (confining layers)
between the coal seams and uranium ore-bearing aquifers, hydraulic communication between them
would be very low. The drawdown induced by groundwater withdrawals from CBNG coal seams
would be progressively attenuated across impermeable silt/shale layers within 100 to 200 ft above
the coal seams; therefore, the potential risk of impacts of groundwater withdrawals from coal
seams on groundwater levels in the uranium ore-bearing aquifers would be low. The possibility
of communication between a uranium ore zone aquifer and a coalbed methane coal seam could
happen if coal be methane wells located near any of the wellfields is not completed properly.
Although this could happen, the chance of it actually occurring is low since the CBNG producers
use a well procedure that tests each well's integrity. The well completion procedure used by the
CBNG producers is very similar to that used for the ISR wells. Coalbed methane wells in the Jane
Dough area are in place and producing. This has allowed Uranerz Energy to monitor the ore zone
aquifer to see if any impacts are taking place between the ore zone and the CBNG wells. If any
impacts are observed, problems can be addressed and resolved before any mining takes place.
Exhibit 2-1A, Jane Dough CBNG infrastructure (see map pockets) details the current CBNG
infrastructure (wells, pipelines, utilities and roads) that occurs in the Jane Dough Unit area.
2.2.5 Ecological Resources
The proposed project would have a minimal ecological impact to the region through the
disturbance of land. Approximately 101 acres would be disturbed in the Jane Dough Unit during
the life of the proposed project, but the cumulative impact of this disturbance combined with past,
present, and future actions would not be significant. Much of the land in and near the Nichols
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Ranch ISR Project site has been used by past and current actions such as livestock grazing, uranium
extraction, and CBNG and conventional oil and gas development.
Disturbance to vegetation during wellfield development and pipeline construction in the
Jane Dough Unit would be temporary since the areas disturbed would be reclaimed and reseeded
as soon as possible after these activities occur. Also the land disturbed by the project is small
(101 acres) relative to the amount of similar wildlife habitat available in the region. Any land that
is disturbed by the project would be reclaimed and revegetated upon completion of the project.
Additionally, there are no foreseeable future actions that when combine with the Jane Dough Unit
would create significant cumulative impacts on ecological resources.
Cumulative impacts to wildlife, particularly greater sage-grouse and raptors, from the proposed
Jane Dough Unit would be less than significant when combined with past, present, and future
actions because Uranerz would comply with appropriate mitigation measures to reduce impacts to
these species. Greater sage-grouse activity along with raptor nesting is monitored on a yearly basis
to assess bird populations and impacts.
Uranerz would undertake measures to mitigate any
potential impacts that may occur to the greater sage-grouse and raptors inhabiting the proposed
Jane Dough Unit. Such avoiding physically disturbing leks and maintaining the 0.25 mile no
surface occupancy buffer around all occupied leks, implementing the 2-mile seasonal buffer during
the nesting and brood rearing season (as discussed in the mitigation section of this report), and
advising project personnel of appropriate speed limits for specific access roads, that they are not
allowed to haze or harass the animals, and that they should minimize any direct disturbance to all
wildlife whenever possible. These mitigation measures are also being implemented by all other
industrial/mineral development activity occurring the general area around the Jane Dough Unit.
As a result of the implementation of all ecological mitigation measures described in the Proposed
Action, the Jane Dough Unit would not any significant impacts on ecological resources.
2.2.6 Air Ouality Resources
The Jane Dough Unit would not have any significant impacts on meteorology or climatology. In
addition, the development and operation of the proposed Jane Dough Unit would not result in any
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significant cumulative impacts on air quality in the region. Existing air quality in the project
vicinity is good with the impacts of the project on air quality being minimal. Other industrial
activities in the region include several uranium ISR projects and existing CBNG and conventional
oil and gas development.
The BLM recently completed a regional technical study, called the Powder River Basin Coal
Review, to help evaluate the cumulative impacts (including on air quality) of mineral and energy
development in the PRB (BLM 2011). The current study evaluated conditions as of a baseline
year (2004) and projects development levels and potential associated cumulative impacts related
to mineral and energy development.
The study included existing and future for oil and gas
(conventional oil and gas and CBNG), coal mining, uranium ISR projects, wind energy
developments, other mineral developments, and industrial facilities projected for 2015 and 2020
(BLM 2011).
The Powder River Basin Coal Review considers existing regional air quality conditions in the
study areas to be very good. There are limited air pollution emissions sources (few industrial
facilities, including the surface coal mines, and few residential emissions in relatively small
communities and isolated ranches) and good atmospheric dispersion conditions (BLM 2011). The
available data show that the region complies with the ambient air quality standards for N02 and
SO2 . There have been no monitored exceedances of the annual PMio standard in the Wyoming
Powder River Basin (BLM 2011). The BLM Coal Review air quality study presents results that
show the maximum modeled impacts on ambient air quality at the near-field receptors in Wyoming
and Montana (BLM 2011). Results shown represent the maximum impact at any point in each
receptor group; data are provided for the baseline year (2004) analysis and existing and all
reasonably foreseeable future actions (including the Proposed Action) for 2015 and 2020. Peak
impacts occur at isolated receptors and are likely due to unique source-receptor relationships. The
model results should not be construed as predicting an actual exceedance of any standard, but are
at best indicators of potential impacts (BLM 2011 d). Based on these results, the Proposed Action
would not have a significant impact on air quality.
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2.2.7 Noise
The proposed project would generate minimal impacts associated with additional noise in the
immediate vicinity of the project area. However, the combination of existing background noise,
noise from the project, and noise from reasonably foreseeable future actions is not expected to
represent a significant cumulative impact. ISR processing equipment would be housed inside of
buildings reducing the amount of noise to the outside environment. Wellfield development would
have some noise impacts from the running of drilling equipment, but the noise levels are minimal
and only occur part of the time since wellfield development takes place during daylight hours.
Therefore, there would be no significant noise impacts from the Proposed Action and any
reasonably foreseeable future projects.
2.2.8 Historic, Cultural, and Paleontological Resources
Minimum cumulative impacts to historic, cultural, and paleontological resources would likely
result from implementation of the Proposed Action. Past and current activities by the uranium ISR
operators and CBNG and conventional oil and gas operators have identified historic, cultural, and
paleontological resources in the proposed project area. In addition, steps would be taken by
Uranerz to mitigate any impacts to historic, cultural, and paleontological resource sites. If any
sites are encountered at any time during wellfield development, proper mitigation measures would
be taken to protect the resource and the proper regulatory agencies would be notified so that a path
forward could be determined and implemented.
Because of the activities of the proposed project and the past and current activities that have
occurred in the project area, minimum significant cumulative effects would occur with the
proposed project.
2.2.9 Visual Resources
The Proposed Action would not have any significant cumulative impacts to the visual resources.
The Jane Dough Unit is located in a remote area that is privately owned with limited or no public
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Jane Dough Unit
access. This restricts the number of people that would able to see the Proposed Action. The Jane
Dough Unit would not have any impacts on the Pumpkin Buttes TCP (a regionally visually
sensitive area) located on and near Pumpkin Buttes. The Jane Dough Unit is located outside of
the BLM/WSHPO area of potential effect and therefore, there would be visual impacts to the TCP.
2.2.10 Socioeconomics (Including Environmental Justice)
The proposed Jane Dough Unit would have an overall positive contribution to cumulative
socioeconomic impacts in the region. The project would provide jobs, wages, and tax revenues to
the state and surrounding communities without major adverse impacts to local infrastructures like
hospitals, schools, and community services.
Impacts on the current housing shortage in the
communities surrounding the project area would not be a concern because no additional employees
would work at the Jane Dough. Existing employees that work at the Nichols Ranch ISR project
would work at the Jane Dough Unit; thus no additional employees would be required.
No minority and low-income populations have been identified as residing near the proposed
Jane Dough Unit. Based on the 2011 NRC SEIS, the percentage of minority populations living in
the two nearest block groups are very small when compared to the percentage of minority
populations recorded at the state level and much less than the national level. The NRC GEIS also
identified no minority population block groups in the Wyoming East Uranium Milling Region near
the Jane Dough Unit (NRC 2009).
The economic base of the region is largely comprised of ranching and resource extraction. Low
income populations are generally dispersed throughout the study area. Based on this information
and the analysis of human health and environmental impacts presented in Chapters 4 and 5, any
impacts from the construction, operation, and decommissioning of the proposed Jane Dough Unit,
including other past, present, and reasonably foreseeable future actions, would not be
disproportionately high and adverse.
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2.2.11 Public and Occupational Health
The proposed Jane Dough Unit would have no significant cumulative impact on public and
occupational health. With the Jane Dough Unit being located in a remote, sparsely populated area,
on private land, public access and interaction with the Proposed Action would be limited to prearranged public tours.
The occupational health hazards of exposure to radioactive materials (uranium, radon, etc.) to
employees would be minimal. The CPP at the Nichols Ranch ISR project would be design with
features such as downflow IX columns and a vacuum dryer to minimize the possibility of radon
and uranium escaping into the atmosphere. Facility ventilation would also be designed to keep air
circulating throughout the plant to prevent any buildup of radon gas. Localize ventilation would
be available for situations when operators and other personnel would be working in such places
that they could be exposed to radon gas or uranium dust.
Radiation monitoring would also take place within the CPP at the Nichols Ranch ISR Project.
Area and individual monitoring would be conducted to ensure that every employee is free from
contamination and their exposure to radioactive materials is as low as reasonably achievable. In
the event that an employee or area is deemed contaminated, decontamination measures would be
immediately implemented.
Radiological monitoring of the Jane Dough Unit permit boundary would also take place. The
monitoring would be compared with base line data collected prior to any ISR activities to ensure
that radiological exposure is minimized to the areas surrounding the Jane Dough Unit.
2.2.12 Waste Management
The proposed Jane Dough Unit would have some impacts to licensed NRC disposal facilities and
local landfills from the solid wastes generated from the project. The additional solid wastes would
add to the volume of waste that would have to be disposed of, but because of the nature of the ISR
mining, the amount of waste generated is not substantial or significant. Liquid wastes would not
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Jane Dough Unit
have significant cumulative impact since these wastes would be disposed of through a permitted
deep disposal well at the CPP at the Nichols Ranch ISR project.
2.3 COMPARISON OF THE PREDICTED ENVIRONMENTAL IMPACTS
Table 2-1 outlines the predicted environmental impacts of the proposed Jane Dough Unit compared
to the No Action Alternative.
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Table ER2-I
Jane Dough Unit
Summary Comparison of Potential Environmental Impacts.
No Action
Alternative
No additional impact
beyond those that
already exist
Resource
Land use
Proposed Action Alternative
ISR operation would only disturb 101 acres over life of
project. Restoration and reclamation of disturbed lands
would take place during and after mining activities,
Temporary loss of grazing and wildlife habitat would occur,
but not a significant cumulative impact.
Transportation
Traffic from ISR operations is very low. One tractor-trailer
per day along with 8 passenger vehicles per day would
utilize roads.
No additional impact
beyond those that
already exist
Geology and Soil
Resources
There would be no impacts to geology. ISR operation would
disturb approximately 101 acres of land. All disturbed land
would be restored and reclaimed after life of project.
No additional impact
beyond those that
already exist
Water Resources and
Wetlands
Surface water resources would be protected by mitigation
measures. ISR operation would restore the affected
groundwater in the mining ore zone back to pre-mining
conditions or class of use. There would be no impacts to
wetlands.
No additional impact
beyond those that
already exist
Ecological Resources
Potential impacts to greater sage-grouse and raptors would
be mitigated. There would be minimal impacts to other
species. ISR operation would only disturb 101 acres of
vegetation over life of project. Restoration and reclamation
of disturbed lands would take place during and after mining
activities.
No additional impact
beyond those that
already exist
Air Quality
There would be minimal impacts to air quality due to the
nature of ISR.
No additional impact
beyond those that
already exist
Noise
Minimal noise level increase from drilling operations. Drilling
only occurs during daylight hours.
No additional impact
beyond those that
already exist.
Cultural Resources
There would be no impacts to cultural resources. Surveys
have been conducted to identify cultural sites. Measures
would be taken to minimize/avoid disturbance of sites.
No additional impact
beyond those that
already exist.
Visual Resources
There would be minimal impacts on visual resources. The
Jane Dough Unit is located on entirely on private land in a
remote area with limited or no public access.
No additional impact
beyond those that
already exist.
Socioeconomic and
Environmental Justice
Positive effect on surrounding area through taxes, wages,
and jobs. Employees come from surrounding communities.
No impacts to housing and public infrastructure. No impacts
would result from the project since it is located in an area
where there are no concentrated minority populations or
centered areas of people living below the property level.
No additional impact
beyond those that
already exist.
Public and
Occupational Health
Minimal risk to public and occupational health. Radiological
detectors are placed on the permit boundaries to monitor
radiological effects of operation. Groundwater is closely
monitored so that an excursion would be detected quickly if
one occurs.
Impacts would be minimal to disposal facilities since waste
generated at ISR operations would be minimal. Estimated
landfill waste is 700 to 1,000 yd 3 per year. Estimated
contaminated waste is 60 to 90 yd 3 per year. All material
can be removed from project site and project life.
No additional impact
beyond those that
already exist
Waste Management
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No additional impact
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3.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT
3.1 LAND USE
3.1.1 Site Location and Layout
The Jane Dough Unit is located in the Pumpkin Buttes Mining District of the Powder River Basin
in Johnson and Campbell counties, Wyoming. The Jane Dough Unit encompasses approximately
3,680 acres of land located in Township 43 North, Range 76 West, Township 43 including all or
portions of Sections 20, 21, 27, 28, 29, 30, 31, 32, 33, and 34. The Jane Dough Unit would consist
of two wellfields and associated facilities, but there would be no uranium processing or exchange
plant, office building, or maintenance building. Access to the Jane Dough Unit site is either via
Wyoming State Highway 50 to Van Buggenum Road to T-Chair Livestock ranch roads, or from
U.S. Highway 387 north on the Iberlin road. Figure 2-1 (see map pocket) of the NRC Technical
Report shows the general location and access to the project areas.
The current land surface ownership of the Jane Dough Unit includes approximately 3,680 acres of
private ownership. Names and addresses of the surface and mineral owners of record within and
adjacent (within 0.5 mi of each permit boundary) to the project are provided in Table ER3-1,
Appendix A, and B of the attached NRC Technical Report. Appendix A lists and provides a map
of all surface and mineral owners located within the two project units. Appendix B lists and
provides a map of all surface and mineral owners for lands located within 0.5 mi of the project
units. The legal descriptions of the project units are contained in Appendix C including tabulations
of all lands in the project units and tabulation of No Right to Mine lands.
3.1.2 Uses of Lands in and Adjacent the Project Area
3.1.2.1 General
The lands within the Jane Dough Unit have historically been used for cattle grazing and wildlife
habitat. Presently the lands are used for a variety of purposes. Livestock grazing, oil and gas
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.
Table ER3-1
Jane Dough Unit
Nearest Residents to the Jane Dough Unit.
Nearest Residences
-Chair (Rolling Pin) Ranch
Pfister Ranch
Pumpkin Buttes Ranch
Van Buggenum Ranch
Ruby Ranch
Dry Fork Ranch
Christensen Ranch
Number of Inhabitants
Distance From
Pennit Area (mi)
Direction
5
3
2
0
2
3
1
1.0
6.3
6.3
8.7
10.7
1.1
5.4
East
Northeast
East
East
East
West
South
extraction, coalbed methane extraction, and uranium recovery activities are all currently taking
place on or near the Jane Dough Unit. The immediate future land use for the project area and
adjacent areas will be continued livestock grazing, in situ uranium recovery, coalbed methane
extraction, and oil and gas extraction.
Four NRC licensed in ISR facilities are located within 50 mi of the Jane Dough Unit. The Nichols
Ranch ISR facility is located immediately north of the Jane Dough Unit, Uranium One's
Christensen Ranch ISR facility is located approximately 7.0 mi north of the Nichols Ranch Unit.
Cameco Resources (CR) licensed North Butte amendment area lays approximately 8.0 mi to the
north of the Jane Dough Unit. Cameco's Smith Ranch Highlands (CR-SRH) ISR facility is located
approximately 44 mi to the Southeast of the Jane Dough Unit.
Two of the licensed facilities, Christensen Ranch and CR-SR-, currently have existing yellowcake
processing plants with the CR-SRH being in operation. The Christensen Ranch plant was idle, but
is back in production. Cameco's North Butte amendment area consists of satellite and wellfield
facilities.
Figure 1-4 (see map pocket) of the NRC Technical Report Chapter 1.0, Proposed
Activities, shows the location of each facility in relation to the Jane Dough Unit.
After mining activities are completed, the land would be returned to the pre-mining land use of
wildlife habitat and livestock grazing. Decommission and reclamation activities of the affected
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areas resulting from the uranium recovery activities are detailed in the NRC Technical Report
Chapter 6.0 of this application.
3.1.2.2 Livestock Grazing
Livestock grazing is the main activity currently occurring on the project area and adjacent lands.
No known sources of mass food production for human consumption exist within 10 kilometer
(6.2 miles) of the Jane Dough Unit.
The National Resources Conservation Service (NRCS)
stocking rate for the Jane Dough Unit ranges from 1.0 to 3.0 animal units per acre, per month on
range that varies from average to excellent as listed in the NRCS Technical Guides for the Northern
Plains.
3.1.2.3 Recreation
Recreational activities within a fifty mile radius of the Nichols Ranch ISR Project are mainly
dispersed outdoor activities such as camping, hiking, fishing, and hunting. All of the land on and
adjacent to the Jane Dough Unit is privately owned with no access for the public. There are some
limited public lands located on Pumpkin Buttes area but access is restricted because of no public
roads or rights-of-way to these areas. Portions of the Thunder Basin National Grassland, located
approximately 24 mi to the east/southeast of the project area, and the Bighorn Mountains,
approximately 27 air mi to the west, provide areas for recreational activities on public lands. The
Powder River, located approximately 9.0 mi to the west of the project area, also provides
recreational opportunities for public use. Figure 1-1 (see map pocket) of the NRC Technical
Report shows the recreation spots in regard to the proposed project area.
3.1.2.4 Water Rights
Surface and ground-water rights on, adjacent to, and within 3 miles of the Jane Dough Unit are
listed in Table JD-D6F.1-1 in Addendum F for the surface water and Tables JD-D6G.1-1 and
JD-D6G.1-2 permitted water wells in Appendix JD-D6 of the NRC Technical Report.
Table
JD-D6G.I-1 lists the wells within the Jane Dough Unit while Table JD-D6G.1-2 in Addendum
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JD-D6G list wells in and within three miles of the Jane Dough Unit.
Table JD-D6F. 1-2 in
Addendum JD-D6F lists the abbreviations used by the State Engineers Office for both the surface
and ground-water rights.
Figures JD-D6-4 and JD-D6-14 present the locations of the Jane Dough Unit surface rights.
Exhibit JD-D6-1 shows the locations of the permitted wells within three miles of the Jane Dough
Unit. No adjudicated surface water rights are located in or adjacent to (within 1/2 mile of the
project unit) the Jane Dough Unit. The surface water rights that do exist within the proposed
mining project area are limited to stock/storage ponds and ephemeral creeks. Groundwater rights
in the Jane Dough Unit area are mainly associated with the old monitoring wells and stock wells.
No other adjudicated water rights are in the project area and lands adjacent to the project area
according to the Wyoming State Engineers Office.
Uranerz also does not hold any adjudicated water rights in the project area. Most wells that are
located within the Jane Dough Unit area were previously installed by uranium exploration
companies, the T-Chair Livestock Company, or CBNG companies. Several additional wells have
been completed in the project areas by Uranerz for use in collecting base line ground water quality
data. The current regional ground water use in this area is mainly wells for wildlife and livestock.
A few domestic wells exist at the ranch houses. The production of water from coal bed methane
has been occurring in the region for approximately 15 years.
Wells in the area of the proposed project area are uniformly distributed over the area excluding
monitoring/sampling wells that are permitted by Uranerz. Most of the wells are used for livestock
watering through the use of windmills or electric well pumps. Non-mining or oil company well
depths vary from 135 feet to 1,593 feet in depth, and most wells are completed in sands other than
the ore bearing sands. Those wells that are completed in the ore bearing sand will be abandoned
using acceptable WDEQ methods or will be used as monitoring wells if not completed in multiple
sands. No wells in or adjacent to the project area are used for domestic water consumption. The
extensive ground-water monitoring program utilized during the mining project will detect any
problems prior to this wellbeing adversely affected by mining activity.
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Seventeen permitted wells that are not related to the mining operations also exist within 1/2 mile
of Jane Dough Unit. The Pat #1 well is thought to be completed in the A or B Sands based on its
well depth. Water levels in this well could be affected by the Jane Dough Unit operation. Wells
East Dry Fork #1, Dry Fork Flowing #3, and Pug well #1 are thought to be completed in the
B Sand. Small drawdowns in these wells could be caused by the Jane Dough ISR wellfield. The
Taylor #22-1 is thought to be completed in the C Sand and should not have drawdowns from the
Jane Dough operations.
Six of the ranch wells within or within one half mile of the Jane Dough permit boundary are
completed below the I Sand. These wells are Taylor Unit #9, Doughstick #2, Pug Well #2, Chair
12-22, Car Body Well #1, and Brown 21-6. Also Dry Fork Samson #1 is completed in the 1 Sand
and below. The Jane Dough wellfield should not have any effects on this well. Taylor #21-3,
Seventeen Mile #1, and Fetty Well #1 are thought to be completed in the 1 Sand and should not
be affected by Jane Dough.
The Brown 20-9 well is within the Nichols Ranch Unit and flows at approximately one gpm. This
well is thought to be completed in the A Sand and has a total depth of 740 feet with perforations
from 495 to 695 feet. The Nichols #1 well, which is located in Section 19, is completed down to
a depth of 310 feet. This well is likely completed in the C Sand and flows at approximately one
gpm.
Based on a conversation with the current owner of the property where the Nichols Ranch once
stood, the source of water was a well which was located approximately 200 yards from the old
ranch house towards Cottonwood Creek and was thought to be artesian in nature. The depth of
the well was not known but it was likely hand dug and fed off the waters of Cottonwood Creek.
3.1.2.5 Industrial - Energy and Mineral Development
Oil and gas and CBNG development have and would be taking place in the proposed project area
and on the lands adjacent to the Jane Dough Unit for several years. The Jane Dough Unit lies
within the Hartzog/Pumpkin Buttes Oil Fields. Presently there are three conventional oil/gas wells
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Jane Dough Unit
exist on the lands within the Jane Dough Unit and 47 CBNG wells are located within the Jane
Dough Unit. According to the Wyoming Oil and Gas Conservation Commission, no further oil
and gas development would take place in the Nichols Ranch ISR Project.
The locations of
the conventional oil/gas wells and CBNG wells in the Jane Dough Unit are shown in Exhibit JDD6-4 and JD-D6-3 (see map pocket) of the attached Appendix JD-D6, Hydrology.
3.2 TRANSPORTATION
Access to the Nichols Ranch ISR Project site is either via Wyoming State Highway 50 to
Van Buggenum Road to T-Chair Livestock ranch roads, or from U.S. Highway 387 north on the
Iberlin road. Figure 2-1 (see map pocket) of the NRC Technical Report shows the general location
and access to the project areas. The Van Buggenum Road is a county maintained gravel road that
provides access to several ranches located in the project region. This road consists of a 24-ft wide
crowned-and-ditched road that is wide enough to handle two tractor trailers passing one another.
The speed limit is posted at 45 miles per hour.
Ranch roads occurring on the T-Chair Livestock Company are also gravel crowned-and-ditched
roads. Recent activities by coalbed methane producers have improved the major ranch roads that
Uranerz would use. These roads range from 15 to 20-ft wide and are constructed and maintained
by the landowner and the CBNG producers. These roads would allow for safe passage of both
passenger cars and tractor trailers when traveling to and from the Jane Dough Unit. The speed
limit for these roads is 30 miles per hour. Figure 2-1 (see map pocket) of Chapter 2.0 of the NRC
Technical Report outlines the roads that Uranerz would use for the Jane Dough Unit.
Wellfield access roads would follow existing two track roads and coalbed methane well access
roads. If a new wellfield access road is needed, the road would be constructed in such a manner
as required by the landowner. The construction of the wellfield road would also be designed to
provide year round access to the welifield in both dry and wet seasons.
Construction of the wellfield access roads consists of blading approximately the top 6.0-inches of
soil to each side and constructing a drain on each side with the topsoil windrowed to the outside
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of each drain (Actual topsoil depths and volumes would be determined once the decision is made
to construct a new wellfield access road since topsoil depths change depending on location.). After
the drain is constructed the topsoil would be placed in the bottom of the drain and seeded. Next,
a layer of approximately 3.0-inches of gravel, conglomerate or scoria material will be placed on
top of the bladed surface to provide an all-weather base. This method of construction would keep
the driving surface higher than the adjacent land providing for a good drainage and preventing
bogs from forming during the wet season. A 2.0-ft buffer will exist on each side of the road where
topsoil would not be placed. This method of construction is fully supported by the landowner and
has been used successfully by the landowner. At the conclusion of all mining at the Jane Dough
Unit and all restoration in a production area, the wellfield access roads will be reclaimed, or turned
over to the landowner if desired.
3.3 GEOLOGY AND SOIL RESOURCES
3.3.1 Geologyr
Geologic information for the Powder River Basin region and specific geologic information
regarding the proposed project area is found in Appendix JD-D5 of the attached NRC Application.
The geologic information is also found in Chapter 2.0 of the NRC Technical Report and will not
be repeated here.
3.3.2 Soils
Soils within the Jane Dough Unit were inventoried and mapped based on standards of a National
Cooperative Soil Survey (U.S. Department of Agriculture 1993) and include an inventory of soil
types (soil map units) and soil series based on an Order 3 soil survey conducted in 2011. A soil
map delineating the soil types was prepared as directed by the WDEQ, soil samples from potential
disturbance areas were collected and analyzed. Physical and chemical characteristics of the topsoil
within the potential disturbance areas and estimated depths of salvageable topsoil from the
potential disturbance areas for future reclamation purposes were also estimated.
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dane Dough Unit
Soils occurring in the Jane Dough Unit are generally fine textured throughout with patches of
sandy loam on upland areas and fine-textured soils occurring in or near drainages. The project
area contains deep soils on lower toe slopes and flat areas near drainages with shallow and
moderately deep soils located on upland ridges and shoulder slopes.
Based on the results of the soil sampling, there are no factors that would limit the suitability of
topsoil as a plant growth medium during the reclamation phase. In accordance with WDEQ
procedures no soil samples were collected from the Jane Dough Unit; however, soils samples were
collected from the Nichols Ranch Unit (located immediately north of the Jane Dough Unit).
Laboratory values were compared to Table 1-2 of WDEQ-LQD Guideline No. 2 (1994) and the
results were determined to be within the suitable range, except for marginal soil texture for four
soil profiles from samples collected in the Nichols Ranch Unit. These four soil profiles were
determined to have clay soil textures. Additionally, based on a reconnaissance survey conducted
by Natural Resource Conservation Service, no prime farmland was identified within the
Jane Dough Unit.
Detailed soils information for the Jane Dough Unit is presented in Appendix JD-D7 of the NRC
Technical Report and includes a literature review, results, and interpretations of the soil survey,
analytical results of soil sampling, and an evaluation of soil suitability as a plant growth medium.
3.4
WATER RESOURCES (INCLUDING SURFACE WATER, WETLANDS, AND
GROUNDWATER)
A detailed discussion of the hydrology of the Jane Dough Unit is presented in the attached
Appendix JD-D6 and JD-DI 1 Section 2.7 and 2.8 of Chapter 2.0 of the NRC Technical Report.
Appendix JD-D6 contains all information regarding baseline water quality sampling, pump tests,
surface and groundwater rights, abandoned drill holes, CBNG wells, and oil/gas wells in and near
the Jane Dough Unit and Section 2.8 contains information concerning wetlands. Appendix JD-D6
should be referred to for any water information/questions regarding the Jane Dough Unit.
Appendix JD-D 1I contains information concerning the radiation component.
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3.5 ECOLOGICAL RESOURCES
3.5.1 Topography
The Jane Dough Unit is located in southwest portion of the Powder River Basin in northeast
Wyoming (Knight 1994). The project area is composed of two noncontiguous units located west
and southwest of the North Middle Butte in the Pumpkin Butte area. The Jane Dough Unit is
located on the border between Johnson and Campbell counties.
Topography in this area is
relatively flat with gently rolling hills and low ridges that drain toward Cottonwood Creek in the
north and Seventeenmile Creek that drains the southwest comers of the Jane Dough Unit.
Elevations in the Jane Dough Unit range from 4,670 to 4,960 ft AMSL.
3.5.2 Vegetation
3.5.2.1 General
Baseline vegetation studies of the Nichols Ranch ISR Mine permit area were conducted in June
and July 2010 in accordance with a vegetation study plan approved by the WDEQ for noncoal
permit areas. The sampling design and methods used for the vegetation study followed Rule 1-V
(revegetation performance standards): Noncoal Rules, Chapter 3 (WDEQ amended April 25,
2006), WDEQ-LQD Guideline Number 2 (WDEQ 1997), and WDEQ-LQD Draft Guideline 2
(WDEQ 2004).
The project area is composed of seven vegetation/habitat types, with approximately 83% of the
project area composed of two vegetation types (sagebrush shrubland and mixed grasslands)
(Table ER3-2). Only one wetland area was identified within the Jane Dough Unit, and they would
be avoided by project activities (refer to Chapter 10.0 of the NRC Technical Report). No federal
threatened, endangered, candidate, or proposed plant species were found, and none are known to
occur in the project area. Only one designated noxious weed species (Canada thistle) was found
during
surveys;
both
were
found
in
small
numbers
in
Table ER3-2 presents the results of vegetation studies conducted in July 2010.
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areas.
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Table ER3-2 Vegetation/Habitat Types, Number of Acres, and Sampling Intensity, Jane Dough
Unit, 2010.
Estimated
Vegetation/Habitat
Type
Adequate Sample
Premine No. of
Acres
Percent of
Project Area
Affected
Acres'
Minimum
Sample Size2
Size (Nmin) for
Vegetative Cover
2,682.7
72.9
61.7
20
2.6
Mixed grassland
Bottomland
754.4
114.1
20.5
3.1
39.3
0
20
20
4.7
0.2
Hay meadow
66.2
1.8
0
Not sampled
--
Wetland
2. I
<0.1
0
Not sampled
--
Rock outcrop
Disturbed lands3
5.3
55.2
<0.1
1.5
<0.1
0
Not sampled
Not sampled
--
3,680.0
100
101
Sagebrush shrubland
Total
--
Estimated disturbance from wells, pipelines, and additional access roads is estimated.
2
Based on WDEQ-LQD (2004) and on approved sampling plan for the project submitted
3
WDEQ-LQD prior to sampling.
Includes 9.3 acres of previously disturbed lands from CBM pads and ponds, and 12.6 miles (46.6 acres) of roads
(30-foot wide disturbance).
Detailed vegetation information for the Jane Dough Unit is presented in Appendix JD-D8 of the
NRC Technical Report Application and includes results of vegetation mapping and a description
of the vegetation communities, results of cover sampling, a species list, and a discussion of noxious
weeds, and selenium indicator species.
3.5.2.2 Federal Threatened, Endangered, Proposed and Candidate Plant Species
The only threatened, endangered, proposed or candidate plant species listed to potentially occur in
Johnson and Campbell counties is the Ute Ladies'-tresses (USFWS 2012). Ute Ladies'-tresses
prefer moist soils near wetland meadows, springs, lakes and perennial streams where it colonizes
early successional point bars or sandy ledges. Soils where Ute ladies'-tresses have been typically
found are fine silt/sand, gravels and cobbles, and highly organic and or peaty soils. This species
is not found in heavy or tight clay soils or growing in saline or alkaline soils (USFWS 2012).
Based on an assessment of suitable habitat for Ute Ladies'-tresses, no suitable habitat occurs within
the Jane Dough Unit and subsequently to site specific surveys were conducted.
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.
Jane Dough Unit
3.5.3 Wildlife
3.5.3.1 General
The Jane Dough Unit is located within the 10- to 14-inch Northern Plains (10-14NP) zone of
northeastern Wyoming (Natural Resources Conservation Service 1988) and the project area
provides habitat for wildlife that is typical for the region. The study area has the potential to
provide habitat for mule deer, pronghorn antelope, jackrabbit, cottontail rabbit, coyote, bobcat,
mountain lion, red fox, badger, raccoon, skunk, chipmunk, rodents, songbirds, waterfowl, eagles,
hawks, owls, greater sage-grouse, chukar, wild turkey, Hungarian partridge, mourning dove,
magpie, and crow. Most species are yearlong residents; however, some species such as songbirds,
and waterfowl are more abundant during migration periods (Cerovski et al. 2004).
Mammal and bird species found during site specific surveys of the project area included
pronghorn, mule deer, bobcat, coyote, badger, desert cottontails, white-tailed jackrabbits, greater
sage-grouse, and gray partridge.
Small mammals included black-tailed prairie dogs and
thirteen-lined ground squirrels. Raptors confirmed breeding included great horned owl, long-eared
owl, golden eagle, red-tailed hawk, and prairie falcon.
Detailed wildlife information for the Jane Dough Unit area is presented in Appendix JD-D9 of the
NRC Technical Report Application and includes a complete species list, methods, and results of
site-specific species surveys, potential wildlife impacts and mitigation measures, and information
concerning threatened and endangered species.
3.5.3.2 Federal Threatened, Endangered, Proposed and Candidate Animal Species
One federal threatened, endangered, proposed, and candidate (TEPC) animal species is known to
occur within or in the vicinity of the Jane Dough Unit (greater sage-grouse a candidate species)
(USFWS 2012).
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Jane Dough Unit
As a preemptive measure to prevent the formal listing of the greater sage-grouse, the Governor of
Wyoming initiated a Wyoming Sage Grouse Implementation Team (WSGIT) in July 2007 to make
recommendations on management of greater sage-grouse populations relative to development in
Wyoming with the goal of maintaining healthy greater sage-grouse populations. The WSGIT and
eight local working groups identified and defined core population areas (CPAs) in Wyoming,
addressed the need for connectivity among geographically important populations, recommended
guidelines for development activities both within and outside of the CPAs, and assessed needs for
further research regarding habitat protection and population monitoring (WSGIT 2010a). CPAs
encompass habitats and existing populations for at least two-thirds of the greater sage-grouse in
Wyoming (WSGIT 2008).
WSGIT (2008) predicted that, based on peak male attendance,
approximately 83% of the males attending leks in Wyoming were within initially-identified CPAs,
as were approximately 61% of the occupied leks in the state. After further review, the CPAs were
refined in June 2010--and Version 3.0 of the core area map was released to the public--to exclude
some areas of the state where greater sage-grouse habitat was marginal or the level of human
development in the area warranted exclusion and to include areas required to maintain connectivity
between and among important populations (WSGIT 2010b).
On June 2,2011, the Governor of Wyoming signed Executive Order 2011-5, updating the previous
Executive Order (2010-4) regarding the protection of greater sage-grouse (State of Wyoming
2011).
The most restrictive conservation measures and recommendations are for proposed
development activities inside of greater sage-grouse CPAs, which are areas identified by the State
of Wyoming as high-quality habitat for greater sage-grouse nesting and brood-rearing and
necessary to maintain sage-grouse populations.
This Executive Order applies to all actions
(including issuance of state authorized permits) undertaken by all Wyoming state agencies
including permits issued by WDEQ-LQD (State of Wyoming 2010). The Jane Dough Unit is
located outside of any greater sage-grouse CPA, connectivity areas, or winter concentration areas
(WSGIT 2010b).
One occupied greater sage-grouse lek (38-Cottonwood Creek 1) occurs within the Jane Dough
Unit (0.25 miles inside the southeast boundary of the Jane Dough Unit), and three additional
occupied greater sage-grouse leks occur within 2.0 miles of the Jane Dough Unit: 38-Cottonwood
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Creek 1 Satellite, 38-Cottonwood Creek 2, and 38-Cottonwood Creek 3 (refer to Figure JD-D9-3
in Appendix JD-D9 of the NRC Technical Report). All of these leks have been surveyed annually
since 2005 using the WGFD-approved survey methodology. Each lek was visited three times at
sunrise and the maximum number of males and female birds were recorded.
38-Cottonwood
Creek I was active from 2005-2009; 38-Cottonwood Creek 1 Satellite was active in 2006 and
2007; 38-Cottonwood Creek 2 was active in 2005-2010; and 38-Cottonwood Creek 3 was active
in 2005-2007. Very little activity has been noted at any of these leks since 2010; however, one
male and one female were recorded at 38-Cottonwood Creek 2 in 2010 and one female was
recorded at 38-Cottonwood Creek 3 in 2012 (refer to Table JD-D9-2 in Appendix JD-D9).
There are several potential explanations for these decreases, including natural population
responses to recent drought conditions in the general area and natural degradation of sagebrush
habitat (Knick et al. 2003). However, recent studies have also documented that intensive gas
development can have adverse impacts on greater sage-grouse populations (Holloran and
Anderson 2005; Lyon 2000; Lyon and Anderson 2003; and Walker, Naugle, and Doherty 2007).
A large number of gas (CBNG) wells (between 4 and 12 wells per section) have been drilled
throughout the project area over the past 3 years. In addition, there also appears to be an indirect
impact associated with an increased number of avian predators (e.g., corvids) and mammalian
predators (e.g., foxes, coyotes) associated with increased gas development that have also been
documented as having adverse impacts on nesting greater sage-grouse (Hollaran and Anderson
2005; Lyon and Anderson 2003). In addition, work on the adjacent Nichols Ranch ISR project
did not begin until late 2011. Therefore, any decrease in the attendance of male greater sage-grouse
and related population declines within the general project area are likely the result of a combination
of natural and manmade factors not associated with the Jane Dough Unit.
3.6 METEOROLOGY AND AIR QUALITY RESOURCES
3.6.1 Introduction
The Jane Dough Unit is located in northeastern Wyoming, where the climate is generally classified
as steppe or semiarid; defined by the American Meteorological Society as the type of climate, in
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which precipitation is very slight but sufficient for the growth of short sparse grass. This climate
is due in part to the effective barrier to moisture from the Pacific Ocean offered by numerous
mountain ranges that run primarily north and south throughout the state, perpendicular to the
prevailing west winds. The topography in this portion of Wyoming tends to restrict the passage
of storms and thereby restrict precipitation in eastern Wyoming (Curtis and Grimes 2004).
Uranerz installed a meteorological station at the central processing plant within the Nichols Ranch
Unit. This meteorological station became operational in July 2011 and data for temperature, wind
speed and wind direction have been collected, analyzed, and is presented in Appendix JD-D4.
Precipitation data from the Midwest, Wyoming meteorological station (approximately 27 miles
southwest of the Jane Dough Unit) is presented as representative of the Jane Dough Unit for a
2 year period of time. To ensure the representativeness of the short-term on-site meteorological
data to the long-term meteorological data, the 2-years of on-site meteorological data were
compared to long-term data from three representative NWS Station located at the Antelope site,
Casper site, and Gillette site.
This analysis is presented in Addendum JD-D4-A of
Appendix JD-D4 in the NRC Technical Report application and the comparison shows that the onsite data are consistent with long-term conditions.
Average annual lake evaporation, annual evapotranspiration, and humidity data was obtain from
Martner (1986).
3.6.2 Temperature
Summer temperatures vary widely across the state of Wyoming, with the typical climate
characterized by warm sunny days and cool nights. A discussion on regional temperature data is
presented in Appendix JD-D4 in the NRC Technical Report.
State record high and low
temperatures are 116'F and -66°F, respectively (Curtis and Grimes 2004). Based on 2 years
of
weather
data
collected
at
the
Nicholas
Ranch
meteorological
station,
the
maximum temperature recorded was 100.8°F and the minimum temperature was -9.6°F.
On average, for this
region of Wyoming, summer temperatures reach 90'F or above about
48 times per year, while winter temperatures fall to 0°F or below about 18 times per year
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Table ER3-3
Jane Dough Unit
Mean Monthly Temperatures for Jane Dough Unit'.
Month
January
February
March
April
May
June
Daily Mean Temperature ('F)
26.9
26.7
40.2
42.4
54.3
67.5
July
74.3
August
September
October
November
December
72.7
61.9
46.5
36.1
26.4
Data collected at the Nichols Ranch Meteorological Station.
(Martner 1986). On average, there are 100-125 frost-free days a year in the project area, with the
length of frost-free days decreasing with increasing elevation (Martner 1986).
The mean monthly temperatures for the Nichols Ranch ISR Project area based on 2 years of data
collected in the project area and are summarized in Table ER3-3.
Figure ER3-1 compares monthly average temperature for Year 1, the Baseline Year and Year 2
and the monthly average high and low temperature for both years. Temperatures were similar in
Year I and 2 with the exception of a cooler spring in 2013 compared to 2012.
3.6.3 Precipitation
Precipitation data was not collected at the Nichols Ranch ISR Project area.
The nearest
precipitation station is the National Weather Service Midwest 1SW weather station, which is
located approximately 27 mi southwest of the project area.
Average monthly and annual
precipitation values for data collected at the Midwest 1SW weather station for the 30-year period
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Monthly Temperature Comparison
100
..---
Baseline Year Avg Daily Hi
90
....
BaselineYear Avg Daily Lo
-
Year 2 Avg
80of.
Year 2 Avg Daly Hi
70
.
--
-
Year 2Avg Daily Lo
60
S50
40
30
,
20
-
10
0
I
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Month
Figure ER3-1
Monthly Temperature Comparison, for the Jane Dough Unit.
1971-2000 are summarized in Table ER-4.
During this 30-year period, average maximum
precipitation occurs during the month of May, and average minimum precipitation occurs during
the month of January (Curtis and Grimes 2004).
In winter, mean annual snowfall totals are
45-53 inches (Curtis and Grimes 2004). The average number of days with snowfall totals of
1 inch or more is 16 to 26 days for the area, with the highest average monthly snowfall occurring
from February to April (Martner 1986).
3.6.4 Wind
The entire state of Wyoming is windy and ranks 1st in the US with an annual average wind speed
of 12.9 mph. During the winter there are frequent periods when the wind reaches 30 to 40 mph
with gusts of 50 or 60 mph (Curtis and Grimes 2004). Detailed on-site information concerning
wind speed and direction is presented below.
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Table ER3-4
Jane Dough Unit
Average Precipitation Values. '
Month
Inches
January
0.54
February
0.61
March
0.95
April
1.71
May
2.55
June
1.95
July
1.35
August
0.72
September
0.86
October
1.13
November
0.69
December
Annua--------------------------------------------
0.70
Annual
I
13.76
Data from the Midwest, Wyoming Meteorological Station (MW I) (1971-2000) (Curtis and Grimes 2004).
3.6.4.1 Wind Speed
Based on 2 years of wind data collected hourly at the Nichols Ranch meteorological station, the
average wind speed is 10.6 mph. The highest wind speed collected was 51.3 mph. The weakest
winds occur in the mornings and the strongest winds generally occur in early to mid-afternoon.
Figure ER3-2 provides a monthly comparison between the Baseline Year, Year I to Year 2 and a
second year of data. Figure ER3-3 compares the wind roses for the two, 12-month monitoring
periods for the baseline year and second year of data collected at the Nichols Ranch ISR Project
area meteorological station. The wind roses demonstrate fairly consistent wind speed and direction
from year to year.
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Monthly Wind Speed Comparison - Baseline Year and Year 2
55
50
45
40
-
35
S30 25
20
-
D~cn
Baseline Year Avg
Baseline Year Max
................
Year 2Avg
20
-
15
Year 2 Max
10
5
0
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Month
Figure ER3-2 Monthly Wind Speed Statistics, Baseline (Year 1) and Year 2 Comparison for the
Jane Dough Unit.
3.6.4.2 Wind Speed Frequency
The MILDOS-AREA model was used to determine wind speed frequency wind distribution based
on 2 years of collected data. The wind speeds were divided into six classifications ranging from
mild (zero to three mph) to strong (>24 mph). A seventh classification is denoted as "calm,"
indicating wind speeds below the instrument threshold.
The percent of the time that winds occur in each of the seven wind speed categories can be
represented as a wind speed frequency distribution. Figure ER3-4 compares the frequency of
occurrence of each of the seven classifications during the Baseline Year and Year 2 at the Nichols
Ranch meteorological station. The percent of the time the wind speed falls within each of the
seven wind speed classes shown, is quite similar for the two monitoring periods.
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2nd YEAR WIND ROSE
Nichols Ranch Met Station
N
HWY
7W2. I
713202181.1t4 b 713r2013Hr.10
15%
10%
E
10%
15%
400
740
121
190
258
S
Baseline Year WIND ROSE
Nichols Ranch Met Station
N
w"ht.WY
6128MM011
Hr. 14to 71312012Hr.13
15%
-10%
W!
4t00
%0
S
Figure ER3-3
2014
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April
740
121
190
258
WMIII
Wind Rose Comparison, Baseline (Year 1) and Year 2 for the Jane Dough Unit.
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Wind Speed Frequency Distributions
40%
I I Baseline Year
35%
E Year 2
30% 1
25%
I
I
20%I
15%
10%
5% +
0%
0-3
I
m
4-7
8-12
13-18
19-24
Wind Speed Category (mph)
> 24
Calm
Figure ER3-4 Wind Speed Frequency Distributions Year 1 and Year 2 for the Jane Dough Unit.
3.6.4.3 Wind Direction
Predominant wind direction was from the predominately from east accounting for 16.8% of the
possible winds (see Figures ER3-3 and ER3-4). Wind direction was similar from year to year.
3.6.4.4 Wind Direction Freauencv
The MILDOS-AREA model was also used to determine wind direction frequency wind
distribution based on 2 years of collected data at the Nichols Ranch meteorological station. Wind
directions were divided into 16 categories corresponding to the compass directions illustrated in
the wind roses (refer to Figure ER3-3). A 17th category is denoted as "calm," indicating wind
speeds below the threshold to move the wind vane. The percent of the time that winds blow from
each of the 17 directions can be represented as a wind direction frequency distribution.
Figure ER3-5 shows that the percent of the time the wind direction falls within each of the 17 wind
direction categories shown, is quite similar for the two monitoring periods.
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Wind Direction Frequency Distributions
18% 16% ,
14% •
12% 10%
-
-
-____________~
8% .
6%
4%
JJifi
2%O
N
NNE
NE
ENE
E
L
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
NW
NNW
Calm
Wind Direction Category
Figure ER3-5 Nichols Ranch Wind Direction Frequency Distributions Year I and Year 2.
3.6.5 Humidity
Wyoming's annual average relative humidity is quite low and is particularly low in the summer.
In the project area, the mean annual relative humidity is between 52% and 60%. However, during
the warmer part of the summer days, the humidity across the state can drop to about 25 to 30%
and on a few occasions it would be as low as five to 10%. Late at night, when the temperature is
lowest, the humidity would generally rise to 65 or 75%. This results in an average diurnal variation
of about 40 to 45% during the summer, but in the winter the variation is much less (Curtis &
Grimes 2004).
3.6.6 Evaporation
Wyoming's low humidity, abundant sunshine, and relentless winds contribute to a high rate of
evaporation. Annually, statewide evaporation rates range from 30 to about 50 inches.
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Jane Dough Unit evaporation is likely 40 to 45 inches annually. Evaporation in Wyoming varies
much less on a yearly basis than precipitation. Even extreme variations in annual total evaporation
are within 25 percent of the long term annual average (Curtis and Grimes 2004).
3.6.7 Severe Weather
Information on severe weather in the region of interest is not available; however, severe weather
in Wyoming is relatively uncommon in part because of the Rocky Mountains' ability to separate
and block prevailing air flows from the Gulf of Mexico, north-central North America, and the
Pacific Ocean thus minimizing clashes between contrasting air masses that produce severe weather
(Curtis and Grimes 2004). Thunderstorms and hailstorms are the most common severe weather
events in the state and region and hailstorms are the most destructive type of events. Severe hail
(size 0.75 inch or larger) events occur about 29 times a year across the state with the greatest
frequency by far occurring over the extreme southeast part of the state. The annual frequency of
thunderstorms range from about 30 days per year on its western border; to about 50 days per year
in the extreme northeast and southeast comers of the state (Curtis and Grimes 2004).
Tornados are not a common occurrence in the area and "significant" tornados are much rarer.
Tornado intensity is measured by the Fujita (F-Scale) and range from the weakest intensity storms
(FO) to the strongest storms (F5). Significant tornadoes are considered to be F2 intensity winds,
between 113 and 157 mph or stronger, or if a weaker tornado kills a person. Significant tornadoes
occur in about four out of 100 tornadoes in Wyoming (Curtis and Grimes 2004).
3.6.8 Effects of Local Terrain
Approximately 6 mi east of the Jane Dough Unit is a series of buttes known as Pumpkin Buttes.
These buttes rise approximately 1,200 feet above the proposed project area of the Jane Dough Unit.
The proximity of the Pumpkin Buttes to the Jane Dough Unit cannot be ignored and likely creates
a microclimate on the surrounding area. Considering that the prevailing winds in the area are from
the east, the change in elevation is relatively minor, temperature and relative humidity in the region
are quite low, topographically generated weather systems are expected to be nominal. However,
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it is possible that the buttes do produce some microclimatic effects on the local precipitation pattern
but these effects would be variable and diverse especially given the variable nature of summer
precipitation events.
The along-slope wind systems, while certainly present, are expected to be insignificant since the
daytime adabatic or upslope wind has just a few hundred meters to gather strength before reaching
the apex of the buttes. Returning katabatic or down slope winds in the evening should also be
minimal as winds in the area tend to decrease with nightfall. The potential for mountain-gap wind
between North Butte and North Middle Butte exists but is expected to be negligible. First, the
narrow dimensions of the buttes do not allow for a buildup of wind speed as would be expected in
a true valley situation. Secondly, in general when air stratification is stable, the air flow tends to
be from high to low pressure and wind could emerge through a gap as a 'jet" known as mountaingap wind. However, joint frequency distribution data shows stability class F winds, the most
stable, to be quite light in the region. Therefore, while the buttes themselves are a striking visual
characteristic of the landscape topographically speaking they are of limited magnitude.
3.6.9 Air Ouality
The Jane Dough Unit is located in and adjacent to counties that are designated as attainment with
EPA National Ambient Air Quality Standards (NAAQS) for all criteria pollutants (EPA 2010a).
The nearest and only designated nonattainment area in Wyoming is the city of Sheridan, in
Sheridan County (EPA 2010a). The city of Sheridan is approximately 88 miles northwest of the
Jane Dough Unit. The terrain within the region where the proposed site is located, combined with
windy conditions provides good conditions for dispersion of air pollutants (BLM 2003). The
nearest residence to the Jane Dough Unit is Dry Fork Ranch., approximately I mile to the west.
The nearest residence along the path of the predominant wind direction (refer to Figure ER3-3) is
the Dry Folk Ranch located approximately 1.0 mile west of the Jane Dough Unit.
The EPA has established air quality standards to promote and sustain healthy living conditions.
These standards, known as NAAQS, address six pollutants EPA refers to as criteria pollutants:
carbon monoxide (CO), lead (Pb), nitrogen dioxide (NO 2), particulate matter (PMio and PM 2. 5),
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ozone (03), and sulfur dioxide
Jane Dough Unit
(SO 2 ).
EPA revised the NAAQS standards after the preparation of
the Generic Environmental Impact Statement (GELS).
This includes a new rolling 3-month
average standard for lead at 0.15 jg/mi3 and a new 1-hour nitrogen dioxide standard at 100 parts
per billion. EPA revisions to S02 and 03 standards are under consideration but are not finalized
(EPA 201 Ob). WDEQ adopted the EPA NAAQS. States may develop standards that are stricter
than, or that supplement, the NAAQS. Wyoming has a more restrictive standard for sulfur dioxide
(annual at 60 jtg/m 3 and 24-hour at 260 jig/mi3) and supplemental standards for particulate matter
(annual PMio at 50 itg/mi3 and 24 hour PM 2.5 at 65 ttg/mi3) (WDEQ 2008). The principal nonradiological emissions from activities at the Jane Dough Unit include diesel combustion engine
emissions and fugitive road dust (particulate matter).
Particulate matter (PM) refers to particles found in the air. Some particles are large enough to be
seen as dust, soot, or smoke, while others are too small to be visible. As noted previously, NAAQS
limit the allowable concentration of PM particles to smaller than for PMio and PM 2. 5 jg/m3 .
Emissions from highway and non-road construction vehicles comprise approximately 28 percent
of total PMio and PM2.5 emissions. The largest source of PM includes fugitive dust from paved
and unpaved roads, agricultural and forestry activities, wind erosion, wildfires, and managed
burning.
The WDEQ-Air Quality Division analyzes measurements from 26 stations located
throughout Wyoming to ensure ambient air quality is maintained, in accordance with NAAQS.
The results are synthesized into the Wyoming Ambient Air Monitoring Annual Network Plan
(WDEQ 2009).
The baseline air quality conditions of the Jane Dough Unit were determined by evaluating data
from four monitoring stations in the region to provide a reasonable representation of the air
pollutant levels that could be expected to occur at the site. Monitoring data were reviewed for the
Gillette., Campbell County South, Wright, and Antelope monitoring locations. Furthermore, the
NRC GElS reported that all areas within the Wyoming East Uranium Milling Region were
classified as being in attainment for NAAQS (NRC 2009).
WDEQ monitors air quality and annually reports the results to EPA. Table 3-10 presents the air
quality monitoring data for all of the monitoring stations within a 50 mile radius of the Jane Dough
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dane Dough Unit
Unit. These monitoring sites are located northeast, east, and southeast of the proposed project area
in the general direction of the prevailing winds. The monitoring results for the 3 year period from
2006 through 2008 are consistent with the area's attainment status (WDEQ 2009; EPA 2010a).
WDEQ uses the entire monitoring network to meet various objectives; therefore, all criteria
pollutants are not monitored at each site and the data for monitoring sites in the vicinity of the Jane
Dough Unit are limited.
The Prevention of Significant Deterioration (PSD) requirements identify maximum allowable
increases in concentrations for particulate matter, SO2, and N02 for areas designated as attainment.
There are several different classes of PSD areas, with Class I areas having the most stringent
requirements. Wind Cave National Park, the closest Class I area to the Jane Dough Unit is located
about 115 miles to the east of the site. Cloud Peak Wilderness Area, the closest Class II area to
the Jane Dough Unit, is located about 68 miles to the northwest of the site (NRC 2009).
3.7 NOISE
The A-weighted sound pressure level, or A-scale, is used extensively in the U.S. for the
measurement of community and transportation noise; and is a measure of noise in A-weighted
decibels (dBA) that is directly correlated with commonly heard sounds (Table ER3-5).
Noise-sensitive receptors in and adjacent to the ISR Project area include residences, nesting
raptors, and greater sage-grouse. No ambient noise measurements have been made in the Jane
Dough Unit; however, noise levels are likely to be in the range reported for "farm in valley" sites
by Wyle Laboratories (1971), where median noise levels ranged from 29 to 39 dBA, depending
on the time of day. The NRC estimated existing ambient noise levels in the undeveloped rural
areas if the Wyoming East Uranium Milling Region (in which the Jane Dough Unit would be
located located) would be 22 to 38 dBA (NRC 2009). High winds, trucks, and traffic likely range
from 50 to 60 dBA on occasion. Use of agricultural equipment, as well as oil and gas drilling and
completion operations in the general area, likely result in temporary noise levels of 70 dBA to
more than 100 dBA (NRC 2009).
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Table ER3-5
dane Dough Unit
Comparison of Measured Noise Levels with Commonly Heard Sounds.'
dBA
Description
Normal breathing
10
Barely audible
Rustling leaves
20
Soft whisper (at 16 ft)
30
Library
40
Quiet office
50
Normal conversation (at 3 fit)
60
Busy traffic
70
Noisy office with machines, factory
80
Heavy truck (at 49 ft)
90
Source
Very quiet
Quiet
Constant exposure endangers hearing
(Wyle Laboratories 1971).
3.8 HISTORIC, CULTURAL, AND PALEONTOLOGICAL RESOURCES
Reports containing information regarding historic, cultural, and paleontological resources for the
Jane Dough Unit are discussed in detail in Appendix JD-D3 of the NRC Technical Report.
Addendum JD-3A contains the cultural resource report for the Jane Dough Unit and Addendum 3B
contains the results of a paleontological survey conducted for the Jane Dough Unit. All addendums
are considered confidential and not for public disclosure under 10 CFR 2.390. Please refer to the
affidavit regarding the withholding of this information from public disclosure.
3.8.1 Historic and Cultural Resources
3.8.1.1 Class I Literature Search for the Jane Dough Unit
A file search Wyoming State Historic Preservation Office (WSHPO) [File Search No. 25735] was
conducted through the Cultural Records Office of the WSHPO for Sections 20, 21, 27, 28, 29, 30,
31, 32, 33, and 34, T43N, R76W, on May 14, 2010, and includes a description of archaeological
and historical resources within the Jane Dough Unit and includes the full sections of land directly
associated with this project.
The Jane Dough Unit occurs within a majority of these legal
descriptions. Once the list of sites is obtained from the WSHPO database, the sites within each
section were plotted to determine if they occur within the physical boundaries of the Jane Dough
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Jane Dough Unit
Unit. The file search for this area indicates that 10 projects have been conducted with 31
archaeological and historic sites located within the full sections listed above.
The 10 projects conducted within the full sections listed above were completed between 1984 and
2008 for a variety of energy development projects, including five CBNG plans of development
(PODs), four oil/gas wellfield surveys, and one seismic project (Table JD-D3-1). The projects
consist of nine (9) Class III inventories and one historic trail evaluation project. Of the nine
inventory projects seven contain inventory areas that overlap within the current project area.
Table ER3-6 Cultural Resource Inventories Completed Within or near Uranerz's Jane Dough
Unit.
Accession
No. I
2
Type
Legal Location
77 Drill Holes and Block
TVA
B
Section 27, T43N, R76W
84-725
Taylor Unit No. 9
PAS
B
Section 33, T43N, R76W
99-1041
Dry Fork Block Survey
PAS
B
Sections 29, 30, 31, 32, and 33, T43N,
R76W
99-1142
West Pumpkin Buttes Prospect
PAS
B
Section 34, T43N, R76W
4-2191
East Bullwhacker CBNG POD
SWCA
B
Sections 20, 29, 30, 3 1, and 32, T43N,
R76W
4-2191-3
East Bullwhacker CBNG POD
Trails Evaluation
ACR
B/L
6-615
Mojave 3-D Seismic Project
TRC
L
Section 31, T43N, R76W
6-1465
Dry Willow Phase 2 POD
Arcadis
B
Section 27, R43N, R76W
7-1669
Blade CBNG POD
ACR
B/L
8-425
Tex Draw Federal POD
WLS
B
Jane Dough Unit ISR Project
TRC
B
-- =
3
Contractor
84-540
--
2
Project Name
Sections 30 and 31, T43N, R76W
Sections 20, 21, 28, and 29, T43N,
R76W
Sections 20, 21, 27, 28, and 29, T43N,
R76W
Sections 20, 28, 29, and 32, T43N,
R76W
report has not been accessioned.
ACR = ACR Consultants, Inc.; Arcadis = Arcadis U.S. Inc.; PAS = Pronghorn Archaeological Services;
SWCA = SWCA Environmental Consultants; TRC = TRC Environmental Corporation; TVA = Tennessee Valley
Authority; WLS = Western Land Services.
B = block; B/L = combination block/linear; L = linear.
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Based on comprehensive inventory area and project accession dates, four of these inventory
projects (WSHPO Project Nos. 99-1041, 99-1142, 4-2191, and 8-425) were utilized to determine
which portions of the current project area did not require additional Class III inventory.
Approximately 2,660 acres of the 3,680-acre Jane Dough Unit had been previously inventoried in
association with these four projects and are shown on Exhibit JD-D3-1 (presented in
Appendix JD-D-3 of the NRC Technical Report) and discussed below.
The northern portion of the Jane Dough Unit, including the S1/2N1/2, NSE1/4, and S1/4ESE1/4
of Section 20, all of the project portions in Sections 21 and 27, the N1/2 of Section 28, and the
E1/2NE 1/4 of Section 29, T43N, R76W, was inventoried by Western Land Services as part of the
Tex Draw Federal POD project. The inventory report for that project was accessioned by WSHPO
in 2008 (Project No. 8-425). The El/2SW1/4 and SWl/4SE1/4 of Section 20 in the northern
portion of the Jane Dough Unit and all of southwestern portion of the project area in Sections 30
and 31 were inventoried by SWCA Environmental Consultants (SWCA) as part of the East
Bullwhacker CBM POD. The report was accessioned by WSHPO in 2004 (Project No. 4-2191).
The central portion of the Jane Dough Unit, including the WI/2NE1/4 and SE1/4 of Section 29,
the S1/2 of Section 32, and all of the project area within Section 33, was inventoried by Pronghorn
Archaeological Services (PAS) in 1999 as part of the Dry Fork Block Survey. The report was
accessioned by WSHPO in 1999 (Project No. 99-1041).
The portion of the project area in
Section 34 in the southeastern portion of the Jane Dough Unit was inventoried by PAS in 1999 as
part of the West Pumpkin Buttes Prospect. The report was accessioned by WSHPO in 1999
(Project No. 99-1142).
TRC evaluated the current Jane Dough Unit area and determined that a majority of the project area
had been previously inventoried as described above. However, a total of 1,040 acres had not been
inventoried. As a result, TRC inventoried the remaining uninventoried portion of the project area
(portions of Sections 20, 28, 29, and 32, T43N, R76W) in 2010 and the report is presented in
Addendum JD-D3-A and it has been added to Table ER3-6. Results of the 2010 inventory indicate
that no newly identified historical or archaeological sites were found; however, one newly
identified segment and three previously identified segments of the Deadwood Road were recorded.
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This report will be reviewed by NRC and WDEQ-LQD and will be submitted to the WSHPO for
review after it is accepted by the NRC.
Fourteen sites have been recorded within the Jane Dough Unit boundary covered by the file search
and the inventory completed in 2010 by TRC. The 14 sites consist of nine prehistoric and five
historic sites (Table ER3-7).
The results of the current and previously conducted Class III inventories indicate that 14 sites and
two IRs are located within the project area for Uranerz's Jane Dough Unit (refer to Table ER3-7).
The 14 sites consist of two sites that are eligible for listing on the National Register of Historic
Places (NRHP) and 12 that are ineligible.
Table ER3-7. Recorded Sites Within or near the Jane Dough Unit.
Site No.
48CA 1568/
48JO2292
Time
Period'
H
NRHP Eligibility
Site Type
Deadwood
Road
Status
2
E/WSHPO
Legal Location
Sections 27, 28, 29, 30, 31, 33, and 34,
T43N, R76W
48CA5393
48CA5394
P
H
Lithic scatter
Trash scatter
NE/WSHPO
NE/WSHPO
Section 20, T43N, R76W
Section 21, T43N, R76W
48CA5395
P
Lithic scatter
NE/WSHPO
Section 2 1, T43N, R76W
48CA5396
P
Lithic scatter
NE/WSHPO
Section 21, T43N, R76W
48CA5397
P
Lithic scatter
NE/WSHPO
Section 21, T43N, R76W
48CA5398
H
NE/WSHPO
Section 21, T43N, R76W
48CA5399
P
Oil/gas
wellfield
Lithic scatter
NE/WSHPO
Section 2 1, T43N, R76W
48CA5400
P
Lithic scatter
NE/WSHPO
Section 21, T43N, R76W
48CA5401
P
Lithic scatter
NE/WSHPO
Section 21, T43N, R76W
48CA5412
P
Lithic scatter
NE/WSHPO
Section 28, T43N, R76W
48CA6583
H
Trash scatter
NE/WSHPO
Section 27, T43N, R76W
48JO134
H
Bozeman Trail
48JO3452
P
Lithic scatter
E/WSHPO
NE/WSHPO
Sections 30 and 3 1, T43N, R76W
Section 32, T43N, R76W
H = historic; P = prehistoric.
2
E
=eligible, E/WSHPO = eligible with WSHPO concurrence; NE = not eligible; NE/WSHPO = not eligible
with WSHPO concurrence; U/WSHPO = unevaluated with WSHPO concurrence.
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3.8.2 Paleontological Resources
A paleontological survey was conducted of the Jane Dough Unit. The survey did not produce any
vertebrate fossil bearing strata and no vertebrate fossils were discovered. However, some limited
invertebrate fossils (e.g., clams and mollusks) were discovered; however, these resources were
located on private lands and are not scientifically important.
The complete paleontological survey is attached as Addendum JD-D3-B in Appendix JD-D-3 of
the NRC Technical Report.
3.9 VISUAL RESOURCES
The Jane Dough Unit is located in southwest portion of the Powder River Basin in northeast
Wyoming (Knight 1994). The project area is unit located west and southwest of the North Middle
Butte in the Pumpkin Butte area. The Jane Dough Unit is located approximately 6.0 mi west of
South Butte Unit on the border between Johnson and Campbell counties. Topography in this area
is relatively flat with gently rolling hills and low ridges that drain north toward Cottonwood Creek
(an intermittent stream) that is located outside of the unit and the remaining portion of the Jane
Dough Unit drains southwest toward Seventeenmile Creek which cuts through a small portion of
the Jane Dough Unit. Elevations in the Nichols Ranch Unit range from 4,670 to 4,960 ft AMSL.
Figure 3-8C (see map pocket in the NRC Technical Report) depicts the Jane Dough Unit drainages
and elevations.
The Jane Dough Unit encompasses approximately 3,680 acres and surface ownership is completely
privately-owned. The two closest residences are the Dry Fork Ranch and Rolling Pin Ranch. The
Dry Fork Ranch is located approximately 1.0 mile to the west of the northwest corner of the
Jane Dough Unit and the Rolling Pin Ranch is located is located approximately 1.0 mile east of
the eastern boundary Jane Dough Unit (refer to Figure JD-D 11-1 in Appendix JD-D 11 of the NRC
Technical Report).
Because the Jane Dough Unit is located entirely on private land in a remote location, the operations
aesthetic impact is limited to only the landowner and those that have permission to be on the
landowner's property. In addition, there are no visually sensitive areas within 4.0 miles of the
Jane Dough Unit.
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3.10 SOCIOECONOMICS (INCLUDING ENVIRONMENTAL JUSTICE)
The population within 50 mi of the Nichols Ranch ISR Project consists mainly of rural areas. The
community of Gillette, Wyoming, is the closest major urban area to the mine site located
approximately 46 mile away. Casper, Wyoming, is the next closet major urban area to the mine
site located approximately 61 mile away. These two communities provide the major locations of
public services such as schools, churches, medical care facilities, public parks, and commodities.
Wright and Buffalo, Wyoming also provide public services near the mining site. Table ER3-8 lists
the cities, and the estimated populations of all major towns within 50 mi of the project area.
Chapter 2.0 of the NRC Technical Report gives further detailed information, including figures and
tables, regarding the areas surrounding the Jane Dough Unit.
Gillette, Wyoming is the county seat of Campbell County. The city has been experiencing major
growth over the last few years. Coalbed methane, oil and gas development, and coal mining have
played significant roles in expanding the city's population by almost 12% from April 2000 through
July 2005. According to the Campbell County Economic Development Corporation, Campbell
County Housing Needs Assessment of January 2005, Campbell County is projected to grow at a
consistent pace between 7% and 11% for the next 15 years due to the expansion of the work force
and natural population growth. With the influx of industry, Gillette also serves a regional center
for oil and gas, mining, and CBNG support services.
Table ER3-8
City
Population'
Distance From Permit Area (mi)
Direction
28,729
46
Northeast
4,888
57
Northwest
Kaycee
263
35
West
Midwest
404
25
Southwest
Edgerton
195
23
Southwest
1,807
22
East
54,874
61
Southwest
Gillette
Buffalo
Wright
Casper
2
Cities Within a 50-mile Radius of the Jane Dough Unit.
2
2
Source: U.S. Census Bureau Population Division (2010).
Major Wyoming cities just beyond 50 mi.
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Casper, Wyoming, is the County Seat of Natrona County and the second largest city in Wyoming.
The city serves as the economic center of central Wyoming servicing a 150 mi radius that
encompasses all or part of seven counties. Oil and gas, mining, and retail services are all found in
the city. Casper also is home to the Casper Events Center which hosts many public events such as
concerts, trade shows, and sporting events. The population of Casper is in an upward trend with
the recent resurgence in oil and gas development and uranium mining. According to the U.S.
Census Bureau, the estimated population in Casper has increased 4.0% from April 2000 to July
2005. The population of Casper is expected to continue to follow an upward trend with an average
growth rate comparable to the state growth rate of 2.58%.
Several small communities exist in Johnson County, Wyoming. The county seat, Buffalo, is the
largest town in Johnson County. Buffalo is located approximately 57 mi to the northwest of the
project area and houses the Bureau of Land Management office that oversees all federal land in
Northeast Wyoming. The population of Johnson County is expected to grow at a rate of 1.5% to
1.7% from 2005 to 2012 according the Johnson County Comprehensive Land Use Plan of 2005.
Much of the population growth is expected to come from the development of coalbed methane in
Johnson County.
Two ranches are found within five miles of the Jane Dough Unit. The closest inhabited dwellings
are the Dry Fork and Rolling Pin Ranches. Each ranch is located approximately 1.0 mile west and
east, respectively of the Jane Dough Unit. Currently three people reside at the Dry Fork Ranch
and five people reside at the Rolling Pin Ranch. Five other ranches are located between 5 and
11 miles from the Jane Dough Unit. The name of the ranches and the number of inhabitants are
listed in Table ER3-1. All together, the two ranches result in a total of eight people residing within
5.0 mi of the Jane Dough Unit. This results in an occupational density of 0.06 persons per square
mile for the area within 5.0 mi of the project area.
Because of the absence of public lands in the Jane Dough Unit, the public does not have
unrestricted access to the Jane Dough Unit. In addition, visitation to the Jane Dough Unit would
be limited to Uranerz employees, vendors, contractors, regulatory agency personnel, coalbed
methane and oil and gas operators, and prearranged public tours.
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Figures 4-1 through 4-3 of the NRC Technical Report provides detailed information regarding the
county profiles of Campbell, Johnson, and Natrona counties. Included in this information are data
about demographics, county employment statistics, and landowners in the county.
The Jane Dough Units economic contribution to the state of Wyoming the counties surrounding
the project would be through such avenues as the 4% severance tax rate applied by the state on the
mining of the uranium, sales tax revenue generated by the money spent by Uranerz and its
employees for goods and services in the surrounding counties, and the wages paid to Uranerz
employees. The monies collected by the state and counties would go to support the funding of
items such as state public schools, county infrastructure projects, and special county projects.
Regarding environmental justice, the estimated population of Campbell, Johnson, and Natrona
counties in 2010 by the U.S. Census Bureau was approximately 122,800. Minority populations
accounted for a small percentage, -4.6%, of the total population with percentages of minorities
being similar to or smaller than those of the rest of the state of Wyoming. The 2014 unemployment
levels for the three counties averaged -2.8% and in 2009 the average yearly earning was -$42,000
per year in Johnson County, -$50,000 per year in Natrona County, and -$74,000 per year in
Campbell County. The average county earning for the areas surrounding the Jane Dough Unit are
above the 2013 poverty level of $23,550 for a four family household. Figures 4-1 through 4-3 of
the NRC Technical Report (see map pockets) detail employment, population, and earnings data
for the Campbell, Johnson, and Natrona counties, Wyoming.
3.11 PUBLIC AND OCCUPATIONAL HEALTH
3.11.1 Background Radiation
Because background radiation varies significantly across the U.S., it follows that population
exposure varies. Factors determining the level of radiation include elevation and the natural
concentration of radionuclides in the soils and rocks. Table ER3-9 shows several examples of how
radiation dose rates from natural sources vary from place to place. The higher cosmic value
(twice the U.S. average) shown for Denver, Colorado is a reflection of elevation, and the
higher-than-average terrestrial level listed for the Rocky Mountains can be attributed to the
elevated (in comparison to other areas in the U.S.) radioactive isotopes in soil and rock.
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Table ER3-9 Natural Background Radiation Dose Rates (mrem/year).'
Cosmic
Total
Terrestrial
East Coast
16
Rocky Mountains
40
Colorado Plateau
90 (Total Background)
Gulf Coast
23 (Total Background)
Central U.S.
46 (Total Background)
Denver, Colorado
50
Sea Level
26
U.S. Average
27
28
55
U.S. Average
300 (Natural Sources)
U.S. Average
360 (All Sources)
Sources:
U.S. Department of Energy. Draft Environmental Impact statement: Management of Commercially Generated
Radioactive Waste. Vol. 1. Washington, D.C. (1979).
National Research Council. Committee on the Biological Effects of Ionizing Radiation (BIER V). Washington,
D.C. (1990).
Idaho State University. Radiation and Risk. Physics Department. Pocatello, Idaho. (2007).
Convention divides radiation sources into two categories; natural and artificial.
Natural
background radiation comes from cosmic, terrestrial and internal sources, while artificial radiation
consists of contributions from medical procedures, occupational exposure, nuclear medicine,
consumer products and very small amounts from the nuclear fuel cycle.
By far, natural sources of radiation account for the largest percentage of the average annual
exposure to the population. Table ER3-10 shoes natural background sources account for 82% of
the total exposure, and within this source category, radon accounts for 55% of the total. Of the
artificial sources, medical X-rays are the frontrunner at 11%.
Within the other category,
occupational exposure (radiation workers) is less than 0.3%, and lowest contributions come from
the nuclear fuel cycle.
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Table ER3-10 Radiological Exposure from Various Sources in the United States.'
Natural Background
Source Categories of Radiation Exposure
Radon
55%
Cosmic
Terrestrial
Internal
8%
8%
11%
Total Natural
82%
Artificial
Medical X-rays
Nuclear Medicine
Consumer Products
11%
4%
3%
Other
Occupational Exposure
Nuclear Fuel Cycle
Fallout from Nuclear Weapons Testing
Miscellaneous
<0.3%
<0.03%
<0.03%
<0.03%
Total Artificial
18.0%
Sources:
National Research Council. Committee on the Biological Effects of Ionizing Radiation (BIER V). Washington,
D.C. 1990.
To provide additional perspective on how the public is exposed to radiation from various sources
and activities, Table ER3-10 has been prepared. A review of the table readily illustrates that the
highest doses come from medical procedures. Smoking is a major source of radiation dose. At
280 mrem, a person would receive nearly 78% of the total 360 mrem annual average from all
sources. With respect to energy, it can be seen from the table that natural gas in the home imparts
9 mrem - this is 2.5% of the annual average from all sources. Dosage from nuclear power
generation is very low at <0.1 mrem. Doses from modem ISR operations are also in the very low
ranges.
As part of developing an application for a radioactive material license, NRC requires an applicant
to conduct a radiological assessment. A model known as MILDOS is used to generate estimates
of dose to the public.
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The dose rates are then compared the protective regulatory levels to
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demonstrate that no member of the public would be exposed to radiation levels in excess of the
standards. To avoid redundancy, details of the model run would not be discussed here. However,
to illustrate minimal impact that the project would have on public health Table ER3-11 has been
prepared from data obtained from the MILDOS model run. Values in the table represent the
Time-Step 4, which is the period of maximum activity from a combination of production and
restoration at the Jane Dough Unit.
Table ER3-11
Radiation Dose Comparisons.'
Dose Rate
(mrem)
Medical:
1,100
CT- Head Scan
405
245
130
83
10
8
53
Lower GI
Upper GI
Spine X-Ray
Hip
Dental X-Ray
Chest X-Ray
Medical (average all radiological uses)
Activities:
-280
5
Smoking
Air Travel (coast-to-coast round trip)
Materials:
5
3
Drinking water (average per year)
Concrete (average per year)
Energy:
9
Natural gas in home (cooking/heating)
Coal Burning Plant
0.2
Nuclear Power
Annual Average from an ISR Operation
(Whole Body)
<0. I
<1*
U.S. Annual Average from all sources
360
Sources:
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Health Physics Society. McLean, Va. (2007).
National Academy of Sciences. Biological Effects of Ionizing Radiation. (1972).
University of Missouri. Nuclear Engineering. (2007).
*Uranerz MILDOS Modeling Results. November (2007).
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Table ER3-12 lists seven of the nearest ranches to the Jane Dough Unit and four license boundary
receptors. The boundary receptors were located in four different directions; north, south, east, and
west. The ranches are located at varying distances and directions from the facilities. It was noted
above that the values in the table represent the worst case scenario-that is, the period in the
operation's life that has the highest expected impacts.
The MILDOS model also used
meteorological data collected at the on-site Nichols Ranch meteorological station (refer to
Section 3.6 of this report). During this period, the maximum dose is projected to be 0.40 mrem at
the Pumpkin Butte Ranch Receptor. When compared to the public dose limit of 100 mrem, the
minimum impact is clearly evident. This dose is over a two hundred fifty times lower than the
federal standard. Values for the other public receptors are even lower.
Table ER3-12
Projected Dose Rates to Hypothetical Receptors at the License Boundaries and
to Public Receptors (Time-Step 4, Maximum Activity Period).
Dose
Receptor
(mrem/yr)*
Public Receptors
T-Chair (Rolling Pin) Ranch
Dry Fork Ranch
Christensen Ranch
Pfister Ranch
Pumpkin Butte Ranch
Van Buggenum Ranch
Ruby Ranch
0.20
0.10
0.30
0.30
0.40
0.10
0.10
License Boundary Receptors
Jane
Jane
Jane
Jane
Dough
Dough
Dough
Dough
Unit
Unit
Unit
Unit
North-central
East-central
South-central
West-central
0.50
0.60
0.30
0.40
Public Dose Limit
100
*Total Effective Dose Equivalent (whole body).
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3.11.2 Major Sources and Levels of Background Chemicals
The remote location of the proposed operation is characterized by sparse population settlements,
and the predominant land uses are agriculture and energy exploration. The region does not have
any industrial activities that constitute a major source of chemical generation. As described in
Section 2.10 of the NRC Technical Report, chemicals associated with an ISR process include C02,
HCL, H202, and NaOH. Emission rates for these chemicals are well below the threshold that
would trigger a permit. With respect to fugitive dust, the same can be said; the levels are too low
to warrant a permit. In conclusion, because emissions are all below permitting action levels, the
concentrations are protective of the public.
3.11.3 Occupational Health
The nuclear fuel cycle industry is one of the most, if not the most, regulated industries in the U.S.,
and it is no wonder that all of the measures and comparisons given above show doses to the public
from this source category are indeed very small. The same highly protective regulations given in
10 CFR 20, Standards for Protection Against Radiation, apply to workers in the uranium recovery
industry. Specifically, 10 CFR 20.1201, Occupational Dose Limits, are the protective occupational
health standards. An operator, such as Uranerz, must show compliance with these standards.
Compliance is demonstrated through a number of checks and balances, which include: (1)
measurements with numerous instruments during operations; (2) bioassays; (3) unannounced
inspections by the Radiation Safety Officer (RSO); (4) annual independent audits: (5) preparation
of Standard Operating Procedures (SOPs); (6) NRC inspections; (7) record-keeping and other
mechanisms that provide assurance that worker exposure to radioactive materials is kept As Low
As Is Reasonably Achievable (ALARA).
3.11.4 Regional Public Health Studies
After making a reasonable literature search for public health studies that may have been completed
or are being completed for the project region, there are no studies of record. The absence of
regional health studies for this sparsely populated area is not unexpected for two reasons: (1) for
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reasons of statistical significance, epidemiological studies must involve a significant population
and (2) the region at issue does not have any major sources of contaminants that are known to
cause health problems.
3.12 WASTE MANAGEMENT
Liquid wastes generated at the Jane Dough Unit would be disposed of through the deep disposal
wells located at the CPP in the Nichols Ranch Unit. These wastes include the production bleed
stream; wash down water, and groundwater restoration water from groundwater sweeping and
groundwater treatment activities. The Uranerz deep disposal wells have been permitted and
approved through WDEQ. Deep disposal wells are completed and operated in accordance with all
applicable permit requirements.
No sanitary waste facilities would be provided in the Jane Dough Unit. Restrooms and a lunch
room would be provided at the CPP located in the Nichols Ranch Unit. Sanitary wastes from these
facilities would be disposed of in approved septic systems. The septic system at the Nichols Ranch
ISR Project has been approved by the State of Wyoming.
Solid wastes would be generated at the Jane Dough Unit and these wastes would include both
contaminated and noncontaminated wastes.
Contaminated wastes include rags, trash, packing
material, worn or replaced parts from equipment, piping, and sediments removed from process
pumps and vessels.
1 le2 by-product with contamination levels requiring disposal at a licensed
NRC disposal facility would be isolated in drums or other suitable containers prior to disposal
offsite. Until the wastes are disposed of, they will be held in an area with a restricted boundary.
Noncontaminated wastes would be disposed of at a state-approved landfill located near Casper in
Natrona County, Wyoming.
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4.0 ENVIRONMENTAL IMPACTS
The following chapter analyzes and describes the potential impacts for those resources discussed
in Chapter 3.0, Description of the Affected Environment. The potential impact of each alternative
(the no action alternative and proposed project) are analyzed for each resource.
4.1 LAND USE
4.1.1 Proposed Action
As required by NRC regulations, the wellfield within the Jane Dough Unit would be fenced off
during construction and operation to prevent unauthorized entry. Implementation of the Proposed
Action would eventually affect the availability for livestock grazing on approximately 101 acres
within the entire Jane Dough Unit. As each area is developed, Production Area #1 would be fenced
out first followed by Production Area #2. Livestock grazing on approximately 101 acres on private
lands would be prevented over the life of the operation. The surface disturbance and loss of
foraging opportunity for livestock would occur over a 9-year period as the two proposed
production areas are developed, reclaimed, produced, restored, and decommissioned. Areas not
needed for operations would undergo reclamation and soil stabilization within the year of the
disturbance or the first planting season following wellfield construction.
During the life of the project, the areas would be fenced to prevent livestock entry and to enhance
reclamation success and safeguard equipment. WDEQ-LQD Type III fences would be installed;
to prevent livestock entry but would not prevent wildlife entry. Grasses and forbs comprise the
landowner and WDEQ-LQD approved seed mix, and over the long term locally dominant shrub
species would invade the disturbed areas. Approximately 101 acres would be unavailable for a
majority of the LOP. Assuming an average stocking rate of 2 acres per animal unit month (AUM),
the Proposed Action would result in a life of project reduction of approximately 50 AUMs.
Long-term fenced out areas would be unavailable for livestock grazing for approximately (9 years
life of project plus 5 years for reclamation) or until ISR activities are completed, wellfield and
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facilities have been abandoned, and all remaining disturbed areas have been reclaimed and
approved for livestock grazing by WDEQ-LQD.
Once successful reclamation is deemed
successful, project-related fencing would be removed, forage production would return as
permanent vegetation is reestablished, and livestock grazing would be allowed if and when
authorized by WDEQ-LQD in accordance with the approved reclamation standards.
As discussed in Section 3.1, there are limited recreational opportunities within the Jane Dough
Unit as there no developed recreational sites or facilities exist within the Jane Dough Unit. In
addition, land lands with the project area are private and access to the project area is controlled by
private landowners and they will continue to maintain control over access to the Jane Dough Unit.
Therefore, the Proposed Action would have limited impacts on recreational opportunities.
The primary impact on mineral resources from the Proposed Action would be the removal of
uranium from that portion of the Wasatch Formation occurring within the Jane Dough Unit. As a
result, uranium from the exploited zones would not be available in the future.
As discussed in Section 3.0, leasable oil and gas resources have been developed in the project area
as documented by the existence of 46 CBNG wells and three conventional oil and gas
currently operating within the Jane Dough Unit (refer to Exhibits JD-D6-2 and JD-D6-3 in
Appendix JD-D6). CBNG is typically produced at a depth of approximately 1,000 feet below the
surface, which is approximately 300-500 feet deeper than the uranium mineralization found in the
Jane Dough Unit and typical depths of conventional oil and gas wells-bearing strata in this area
generally ranges from 10,000 to 12,400 feet below the surface which is approximately 3,400 to
19,900 feet deeper than the uranium mineralization. Therefore, there could be no conflict in areas
of target mineralization between the Proposed Action and the existing CBNG and conventional oil
and gas wells.
It is possible that some subsurface conflicts between other developing energy resources could
occur. In accordance with NRC policy environmental safeguards would be implemented. These
safe guards are as follows: if there are oil, gas, CBNG, or other production layers near the uranium
ISR production zone, and if NRC determines that there could be potential for cross contamination
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between the ISR production zone and other production layers based on environmental impact
assessments, the NRC may require Uranerz to expand the groundwater monitoring well ring for
detection of potential contamination between the ISR production zone and other mineral
production layers (NRC 2011). However, the NRC determined that cross contamination between
production zone and CBNG or conventional oil and gas production was unlikely in the Nichols
Ranch ISR project area (NRC 2011). Uranerz has also indicated that, if excursions are detected,
the monitoring well would be placed on excursion status and reported to the NRC. Corrective
actions would be taken and the well would be placed on a more frequent monitoring schedule until
there is no longer an excursion.
Since CBM activity is already occurring in the Jane Dough Unit, engineering safeguards would be
put in place to preclude cross contamination. For example, both the CBNG and ISR processes are
designed to work on a negative pressure basis. In other words, each process pulls product from
the production zone into recovery wells for the specific process and materials from each process
are not comingled. Therefore, the processes and materials from CBNG and ISR are kept separated.
The prospective zones of interest (uranium as opposed to CBNG) are vertically separated by at
least 400 ft. In addition, the respective regulatory processes (NRC and WDEQ-LQD for ISR
uranium and WOGCC for CBNG development) require well casing to be cemented from the
surface to the total depth, with the exception of the production or injection interval. Uranerz would
take care while drilling occurs to avoid interference with other production zones. Uranerz could,
if necessary, enhance the ISR monitoring requirements should the potential for cross
contamination be determined to exist (NRC 2011). Thus, this additional monitoring would allow
Uranerz to detect and document possible cross contamination.
It is also possible oil and gas exploration of deeper formations is likely in the future as evidenced
by existing conventional oil and gas development in the general area. Uranerz would continue to
coordinate with other developers to ensure uranium ISR operations and deeper development to not
compromise the integrity of the uranium production zones.
The prospective formations are
generally 4,000-13,500 ft deep and are separated by hundreds of feet of shales (aquitards); thus,
there would be no conflict between the Proposed Action and deep oil and gas exploration. As with
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CBNG development, deep hydrocarbon wells are cased and cemented in accordance with BLM
and WOGCC regulations to preclude cross contamination between formations.
4.1.2 No Action Alternative
The no action alternative would result in no land use impacts. There would be no project related
land disturbances, and no impacts to existing grazing, recreation and mineral development.
Selection of the No Action Alternative would not preclude other energy resources from being
developed in the future.
4.2 TRANSPORTATION
4.2.1 Proposed Action
4.2.1.1 Introduction
The NRC completed analyses of accidents at ISR uranium extraction facilities that consider the
likelihood of occurrence and/or consequence (NRC 2001; NRC 1980).
These analyses
demonstrate that consequences are minor in the presence of effective emergency procedures and
properly trained personnel. The facility design, site features, and operating assumptions of the
Jane Dough Unit are consistent with those of the existing NRC license. Therefore, independent
accident analyses will not be conducted for the Jane Dough Unit. However, assessments are
provided of applicable accident types and scenarios to individual site specific conditions. The
primary difference to traffic as a result of the Proposed Action would be the continuation of traffic
and associated risk for an additional 9 years beyond that which is already been approved by the
NRC and WDEQ-LQD. Assessments are provided of applicable accident types and scenarios to
include site specific conditions. More specifically, discussion is provided with respect to CBNG
recovery, which is unique to the region.
Existing written operating procedures prepared by Uranerz for the Nichols Ranch ISR Project will
be maintained and utilized to describe requirements for responses to postulated accidents and
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mitigation of consequences for the Jane Dough Unit. Uranerz has written appropriate operating
procedures for accidents related to radon releases from process streams, uranium spills from
process upsets (e.g. pregnant lixiviant, loaded resin, thickener, or dryer), leaks in buried lixiviant
piping, and chemical releases as they might affect radiological accidents.
4.2.1.2 Transportation Incidents
Materials transportation to and from the Jane Dough Unit can be classified into four categories:
1) Shipment of refined yellowcake from the Nichols Ranch CPP to a uranium conversion
facility.
2) Shipment of loaded resin from the Nichols Ranch CPP to the Smith Ranch Central
Processing Plant.
3) Shipment of process chemicals from suppliers to the Nichols Ranch Units.
4) Shipments of I I(e)2 by-product material to a NRC licensed facility for disposal.
One other transportation classification is the transporting of employees to and from the plant site.
4.2.1.3 Shipment of Refined Yellowcake
Refined yellowcake produced at the Nichols Ranch CPP would not differ from the refined
yellowcake produced at conventional mills.
The NRC evaluated transportation accidents
associated with yellowcake shipments from conventional mills and published the results in a
generic environmental impact statement, NUREG-0706, NRC, 1980. As previously discussed, no
refined yellowcake will be shipped from the Jane Dough Unit. The following information on
transportation accidents is based on the analysis on the earlier NRC study.
Refined yellowcake produced at the Nichols Ranch CPP would be packaged in 55-gallon steel
drums. Yellowcake would be shipped approximately 1,200 mi to a uranium conversion facility.
This conversion facility is the first manufacturing step in converting the yellowcake into reactor
fuel. An average truck shipment contains approximately 40 drums, or up to 19 tons of yellowcake.
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Based on the initially projected annual production rate of 800,000 pounds of yellowcake per year,
approximately 21 shipments of 40 drums each would be required annually for the Nichols Ranch
ISR Project. By increasing the annual production rate to 2.0 million pounds per year per the
vacuum dryer designed throughput, approximately 53 shipments would be required annually. The
development of the Jane Dough Unit would only extend the operating life of the Nichols Ranch
CPP rather than increase the annual production rate.
According to NUREG-0706, published accident statistics predict the probability of a truck accident
under three different scenarios: 1) on interstate highways in rural areas, 2) on interstate highways
in urban areas, and 3) on two-lane roads typical of those in the vicinity of the proposed project.
The overall average probability of a truck accident for the Nichols Ranch ISR Project based on the
NUREG-0706 data is 2.2x 10 6/mi. This takes into account that most of the shipping of yellowcake
would be on interstates in both rural and urban areas.
The truck accident statistics also include three categories of events: collisions, noncollisions, and
other events. Collisions are considered to be between the trucks and other vehicles or any other
object, whether moving or stationary. Noncollisions are accidents involving only the truck that
result in accidents such as the truck leaving the road and rolling over. Other events include
personal injuries that are suffered from someone on the truck, someone falling from or being
thrown against the truck, cases of stolen trucks, and fires occurring on a standing truck. The
probability of a truck being involved in any of the accidents types during a one year period is
approximately 10 percent.
A generalized accident-risk evaluation conducted by the NRC classified accidents into eight
categories, depending on the combined stresses of impact, puncture, crush, and fire. Using this
classification scheme as a basis, conditional accident probability was developed for eight severity
levels. Two radioactive material release models were then developed to calculate the amount of
yellowcake that could be released based up what severity of accident occurs.
Model I is
hypothetical assuming a complete loss of yellowcake drum contents when an accident occurs.
Model II is based on actual tests assuming a partial loss of yellowcake drum contents. The quantity
of the release for Model I and Model II in the event of an accident is 17,000 pounds and
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1,200 pounds respectively, (NUREG 0706, NRC, 1980). Most of the yellowcake that is released
from the container would be directly deposited on the ground in the immediate vicinity of the
accident location. Some fraction of the released material would be dispersed to the atmosphere.
The following expression was utilized by the NRC to estimate the amount of released material
dispersed to the atmosphere:
4
F = 0.001/4.6x10- (1-e-
0 5ut) u1. 78
Where:
F = the fractional airborne release
u = the wind speed at 50 ft expressed in m/s
t = the duration of the release (hours)
In this expression, the first term represents the initial "puff' that is immediately airborne when the
yellowcake drum fails in an accident. Assuming a wind speed of 10 mph (5 m/s) and a release
time of 24 hours, the environmental release fraction would be 9x10-3 . Since the conversion facility
is located in the eastern United States, a population density of 160 people per square mile was used
to calculate the 50 year dose commitments to the lungs of the general public. The calculated
50-year dose commitments are 2 man-Sv (200 man-rem) and 0.14 man-Sv (14 man-rem) for
Model I and Model II.
The integrated dose estimate would be lower for the more sparsely
populated areas.
Any accident that results during the shipment of yellowcake product could result in some
yellowcake being spilled. In the unlikely event that such an accident does occur, all yellowcake
and contaminated soil would be removed, processed through a uranium mill, or disposed of in a
licensed NRC disposal facility.
All areas that are disturbed by the accident would then be
reclaimed in accordance to all applicable NRC and State regulations.
The risk of an accident involving the transporting of yellowcake resulting in a yellowcake spill
would be kept to a minimum by the use of exclusive use shipments. If an accident were to occur,
impact to the environment would be further reduced by following instruction outlined in the
Uranerz Incident Response Guide.
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yellowcake that leaves the Nichols Ranch CPP. The carrier would also be required to maintain
accident response capability to specifically include spill response.
With the shipment of yellowcake product to a conversion facility located approximately 1,200 mi
away, all risks associated with the transportation of the product cannot be eliminated. However,
the potential impacts to the environment in the event of an accident can be minimized by having
proper procedures in place to ensure that any yellowcake that is spilled is contained as soon as
possible and the area affected by the spill is secured and cleaned up to avoid contact with
unauthorized personnel.
4.2.1.4 Shipments of Loaded Resin
In 2013, Uranerz and Cameco Resources entered into an agreement in which Uranerz could
transport uranium-loaded resin beads to Cameco Resources' Smith Ranch-Highland CPP, if
needed. Should Uranerz not need to ship loaded resin, any transportation risk would be reduced.
Once delivered to either CPP, the uranium would be processed into yellowcake.
Cameco
Resources' Smith Ranch-Highland CPP is located approximately 50 miles south of the Jane Dough
Unit. Access to the Smith Ranch CPP would begin at the Nichols Ranch CPP on existing T-Chair
Ranch and Iberlin Ranch roads to State Highway 387. Uranerz has a road use agreement with the
surface owner for use of the T-Chair and Iberlin Ranch roads. Once on State Highway 387, traffic
would turn south on Ross Road (County Road 31) to Cameco Resource's Smith Ranch-Highland
CPP. Uranerz has road use agreements with the specific surface owners for use of nonpublic roads,
and no separate approvals are required for use of public roads.
The uranium that is loaded onto the resin beads at the Nichols Ranch CPP would remain attached
to the resin until it is removed by a strong brine solution at the Smith Ranch CPP. When the loaded
resin is transferred to a truck, it is moved using barren lixiviant. The barren lixiviant can have
uranium concentrations of approximately 1-3 mg/L U30 8. The loaded resin is transferred to
specially designed tanker trailers that would hold approximately 500 ft3 of loaded resin. Most of
the barren lixiviant is removed prior to shipping to minimize that amount of water weight in the
tanker trailer. Because of the size of the trucks hauling the resin being consistent with a standard
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tractor-trailer combination, the trucks hauling the loaded resin should withstand the impact of most
collisions.
If an accident were to occur with a loaded resin truck, a rupture to the tanker trailer carrying the
loaded resin could happen. The ruptured tank could result in a portion of the loaded resin to be
spilled on the ground. The uranium that is attached to the loaded resin would remain attached to
the resin, but any residual barren lixiviant contained in the tank could spill to the ground carrying
the resin a short distance from the accident scene. The environmental impact that would result
would be minimal. The uranium on the resin would stay attached to the resin as would the uranium
contained in any barren lixiviant that might spill. No airborne release of uranium would result
from the spill. The spilled resin and lixiviant would typically collect in the low areas surrounding
the accident scene trapping the resin for cleanup. The loaded resin and contaminated soil from the
barren lixiviant would be removed and processed at a uranium mill or disposed of in a NRC
licensed facility. The disturbed areas would then be reclaimed in accordance with all applicable
NRC and State regulations.
4.2.1.5 Shipment of Process Chemicals
Truck shipments of process chemicals to the Nichols Ranch ISR Project site could result in local
environmental impacts if the trucks are involved in an accident. Any spills would be removed
with the affected area cleaned up and reclaimed. The process chemicals used at an ISR facility in
truck load quantities are common to many industries and present no abnormal risk. Table ER4-1
lists the process chemicals that may be utilized at the Nichols Ranch ISR CPP and the Jane Dough
Unit. Since most of the material would be recovered or could be removed, no significant
long-term environmental impacts would result from an accident involving the process chemicals.
Uranerz may use anhydrous ammonia in the precipitation circuit at the Nichols Ranch CPP. A
significant environmental impact could result if a truck carrying the anhydrous ammonia was
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Table ER4-1
Bulk Chemicals Required at the Nichols Ranch CPP and Jane Dough Unit.
Shipped As Dry Bulk Solids
Shipped as Liquids or Gases
Salt
NaCI
Hydrochloric Acid
HCL
Sodium Bicarbonate
NaHCO 3
Hydrogen Peroxide
H20 2
Sodium Carbonate
Sodium Hydroxide
Na 2CO 3
NaOH
Carbon Dioxide
Oxygen
CO 2
02
Diesel
Gasoline
Bottled Gases
Ammonia
involved in an accident.
NH3
The ammonia "cloud" that could develop from a release during an
accident could pose an environmental hazard if it were to occur in a populated area.
S
The anhydrous ammonia would be trucked to the Nichols Ranch CPP in bulk shipments of
approximately 7,500 gallons. The frequency of shipments would be approximately 10-12 trucks
per year. The trucks would originate from Casper and travel to the project site. The distance to
be covered is approximately 85 road miles. Using the accident rate of 4.8x10-7 accidents/mile
from the Generic Environmental Impact Statement for Uranium Mills, (NUREG-0706, NRC,
1980), the chance of a traffic accident involving these trucks is very low.
4.2.1.6 Shipment of 1 le(2) By-product Material for Disposal
All 1 l e(2) by-products generated at the Nichols Ranch CPP and Jane Dough Unit would be
transported to an off-site NRC licensed disposal facility. The risk involved in shipping the material
to a disposal facility is inherently lower that the risk involved in shipping yellowcake to a
conversion facility since the distance between the disposal facility and the Nichols Ranch ISR
Project site is considerably less than the distance between the conversion facility and the Nichols
Ranch ISR Project site.
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In the event that an accident would occur while transporting 11 e(2) by-product material, the impact
to the environment would be minimal.
Any waste that is spilled on the ground and any
contaminated soil would be removed and sent to the disposal facility.
Because the 11 e(2)
by-products could contain some uranium, an airborne release could occur, but would not be any
greater than the amount of released determined in Section 4.2.1.3 using the Model I criteria.
The risk of an accident involving the transporting of I le(2) byproduct material and resulting in a
spill would be kept to a minimum by the use of proper packaging and exclusive use shipments. If
an accident were to occur, impact to the environment would be further reduced by following
instruction outlined in the Uranerz Incident Response Guide. This guide would be included with
every shipment of 1 e(2) byproduct material that leaves the Nichols Ranch CPP. The carrier
would also be required to maintain accident response capability to specifically include spill
response.
4.2.1.7 Transporting Employees To and From Project Site
Employees working at the Jane Dough will first be transported to the Nichols Ranch CPP and then
they would travel to the Jane Dough Unit. The Jane Dough Unit is in a remote location in
Wyoming. Employees that work at the Jane Dough Unit would more than likely have to commute
to the project site from areas such as Gillette, Wright, or Casper, Wyoming. The distances involved
could be from 22 miles away to as far as 61 miles away from the project site. Transportation to
and from the project site would either be from personal vehicles or company provided
transportation.
Potential risks to employees coming to and from the Jane Dough Unit (via the Nichols Ranch CPP)
site include fatigue, animals, and adverse weather conditions. Fatigue and animal risks can be
minimized by taking precautions such as resting and defensive driving, but adverse weather
conditions can be more involved. If weather conditions exist such that roads leading into and out
of the Jane Dough Unit are impassible or closed, then measures would be taken so that employees,
contractors, vendors, and visitors would have a place to take shelter and be provided meals and a
place to stay until the roads are passable.
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The likelihood of an accident occurring while going to and from the Jane Dough Unit is estimated
at 2.2x10-6/mi based on NUREG 0780 (NRC 1980). All travel would be on either two lane rural
highways with some rural interstate travel depending if employees come from Casper. Work
schedules would be developed with the goal of trying to minimize the amount of time that
employees are traveling to and from the project site to help in reducing the risks of commuting to
the project site.
4.2.2 No Action Alternative
Under the No Action Alternative, the Proposed Action would not be implemented and
transportation impacts would continue at their current level. Traffic in the area would continue to
be limited to the landowners, oil/gas and CBNG operators, and personnel associated with the
existing Uranerz Nichols Ranch ISR project.
4.3 GEOLOGY AND SOIL RESOURCES
4.3.1 Proposed Action
ISR mining activities would not result in the removal of any rock matrix or structure. No
subsidence would result at the site from the collapse of overlying rock strata in the mining zone
which would happen in underground mining operations. No other geologic impacts are anticipated
to occur with the ISR mining method.
Impacts to the soils of the area would be limited to approximately 101 acres during the life of the
project. Soils would be disturbed in the area of the wellfields and any access roads that would be
constructed. These disturbances would be temporary as any disturbance affected by the project
would be restored and reclaimed after the project has reached the end of its life.
Soils that are impacted during the life of the project would be handled accordingly. All topsoil
removed from construction activities would be preserved by adopting construction practices the
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prevent erosion and loss of topsoil. Chapter 5.0 in the NRC Technical Report presents detailed
methods that would be utilized when handling topsoil.
Additional impacts on soils could result from spills from processing equipment, leaks from
pipeline breaks and ruptures, or transportation accidents resulting in yellowcake or ion exchange
resin spills. If soil were contaminated by a spill, the soil would be removed and disposed of at a
licensed NRC disposal facility.
All decontamination procedures would be confirmed with
radiation surveys, and would be required to meet NRC's regulations addressing radioactive
materials in soils in areas released for unrestricted use.
4.3.2 No Action Alternative
Under the No Action Alternative, the mining activities described in the Proposed Action would
not be undertaken on any lands within the Jane Dough Unit. No additional ground would be
disturbed and no additional impacts to soils would take place beyond those that already exist.
4.4 WATER RESOURCE (INCLUDING WETLANDS)
4.4.1 Proposed Project
4.4.1.1 Surface Water Impacts
Surface water impacts that result from the Jane Dough Unit would be minimal and temporary.
Implementation of appropriate mitigation measures (presented in Chapter 5.0) would reduce the
intensity and duration of any impacts.
Key surface water features in the Jane Dough Unit is limited to one identified jurisdictional
wetlands. The wetland is in such a location that it would not be disturbed by the mining activities.
In the event that any disturbance would occur in a jurisdictional wetland, consultation with the
Corp of Engineers would be initiated to establish mitigation and control plans. Appendix JD-D10
if the NRC Technical Report provides more information regarding wetlands.
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The potential for erosion and potential movement of sediments into drainages may occur during
construction and reclamation activities associated with processing facilities and wellfield. To
minimize impacts to surface water resources from sedimentation and erosion, Uranerz will
implement appropriate best management practices according to the WDEQ Mine Permit and Storm
Water Pollution Prevention Plan. Re-seeding with landowner- and WDEQ-LQD-approved seed
mixture would also occur upon completion of construction and decommissioning operations.
Seeding of an area would take place during the appropriate growing seasons, either spring or fall,
whichever comes first.
Surface water runoff should not be affected by the presence of any surface facilities including the
wellfields and associated structures, access roads, and pipelines. In the event that surface runoff
flows are impeded by any facilities, culverts and diversion ditches would be implemented to
control the runoff and prevent excessive erosion. If the surface runoff is concentrated in an area,
best management practices such as energy dissipaters would be used to slow the flow of the runoff
so that erosion and sediment transport are minimized.
One wetland area exists on the Jane Dough Unit; however, this area would be avoided and not
disturbed by ISR activities. Approximately 2.47 miles of Waters of the US occur within the Jane
Dough Unit.
The potential impact to Waters of the U.S. would be mitigated through the
implementation of BMP for the Uranerz WYPDES storm water permit that would obtain from the
WDEQ-WQD before operations commence.
In addition, if required Uranerz would secure
coverage under an individual permit or Nationwide Permit 12 or 44 from USACE and comply with
all applicable requirements of the permit. Therefore, impacts to wetland resources would be
minimal.
4.4.1.2 Ephemeral Drainages Impacts
There are only ephemeral channels with the Jane Dough Unit and impacts to ephemeral drainages
may occur with some of the production activities such as wellfield operations or the construction
of access roads. To avoid impacts to the drainages, existing roads within the project area would
be utilized as much as possible.
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wellfield operations, appropriate measures would be taken to minimize the impact to the ephemeral
drainage including the implementation of appropriate best management practices. Uranerz will
not block off any ephemeral drainages and will maintain surface water flow through all ephemeral
drainages.
Access road construction would be minimized where possible by using existing roads within the
project area. When new roads are needed, design and construction practices would incorporate
such parameters as drainages, elevations contours, location with regard to weather conditions, and
land rights to ensure the least amount of impact. If a new road has to cross an ephemeral drainage,
efforts would be made to cross the drainage at right angles to minimize erosion with the appropriate
sized culverts installed. In the event that a drainage has to be crossed, but cannot be crossed at a
right angle or along elevation contours, appropriate measures for erosion control would be
examined and implemented.
Wellfield construction activities would result in some short term or temporary impacts on erosion.
The ongoing drilling, well development, pipeline construction, header house construction, lateral
pipeline placement, and access road construction activities would incorporate best management
practices based on the conditions where construction activities are taking place.
Protection
measures that may be used are: grading and contouring, placement of hay bales, culvert
installation, sedimentation breaks, or placement of water contour bars.
In areas where steep grades are encountered during construction activities, seeding of the disturbed
areas would take place along with the erosion protection measures mentioned above. Temporary
and permanent seeding operations would take place at the first seasonal appropriate opportunity
after the construction activity has been completed.
Wells that are constructed in any ephemeral drainage will use the appropriate erosion protection
controls to minimize the impact to the drainage. Protection controls that could be used, but not
limited to, are: grading and contouring, placement of hay bales, culvert installation, placement of
water contour bars, and designated traffic routes. The drainage bottoms would be restricted to the
work activities that are needed to construct and maintain the wells. If the wells are placed in a
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location in the drainage where runoff has the potential to impact the well, measures would be taken
to protect the well and wellhead. Barriers surrounding the well such as cement blocks, protective
steel casing around the wellheads, or other measures to protect the wells from damage would be
utilized.
4.4.1.3 Groundwater Impacts
During the uranium recovery process, the groundwater in the immediate project area would be
impacted by the elevated concentration of certain constituents that are present in the groundwater
in the ore zone. These impacts would be temporary as the groundwater would be eventually
returned to pre-mining condition or class of use as defined by the WDEQ when the mining and
groundwater restoration phase of the project is completed.
As discussed in Appendix JD-D6, groundwater would be removed from the ore zone aquifers
during the life of the Jane Dough Unit from the wellfield bleed. The water that is removed from
the ore zone aquifers would result in a net loss of water from the ore zone aquifer, but the water
that is lost would be replaced over time by the recharging of the aquifer. Water that is removed
from ore zone aquifers would be sent to a deep disposal well.
Jane Dough production will occur after the Nichols Ranch Unit production is over. Therefore
production and restoration water balance usage will not increase with Jane Dough Unit but will
only extend the same usage for a longer period of time. Uranerz will use a 1% bleed rate for the
Jane Dough Unit.
During the uranium recovery process, the groundwater in the immediate project area would be
impacted by the elevated concentration of certain constituents that are present in the groundwater
in the ore zone. These impacts would be temporary as the groundwater would be eventually
returned to pre-mining condition or class of use as defined by the WDEQ when the mining and
groundwater restoration phase of the project is completed.
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As discussed in Appendix JD-D6, groundwater would be removed from the ore zone aquifers
during the life of the Jane Dough Unit from the wellfield bleed. The water that is removed from
the ore zone aquifers would result in a net loss of water from the ore zone aquifer, but the water
that is lost would be replaced over time by the recharging of the aquifer. Water that is removed
from ore zone aquifers would be sent to a deep disposal well.
Jane Dough production will occur after the Nichols Ranch Unit production is over. Therefore
production and restoration water balance usage will not increase with Jane Dough Unit but will
only extend the same usage for a longer period of time. Uranerz will use a 1% bleed rate for the
Jane Dough Unit.
The bleed rate from the ISR operation at Jane Dough Unit would cause a steady stress on the
A Sand aquifer. For production of 3,500 gpm and a 1% bleed rate, the bleed rate would average
35 gpm. This stress for a four and one quarter year operation at Jane Dough Unit was simulated
in a numerical model with the same aquifer properties used in the Nichols Ranch Unit simulations.
This model also simulated the previous three years of the Nichols Ranch Unit operation to account
for the cumulative stresses on the A Sand aquifer. NRC Addendum 3D presents the results of
these drawdowns.
These drawdowns were calculated from stresses from the two different
wellfields at Jane Dough. Recovery wells were simulated at an equal rate where their total equaled
the 3,500 gpm production rate while the injection rates were varied to balance the wellfield with
an average bleed rate of 1%. These predictions show that 20 feet of the drawdown at the end of
the Jane Dough mining would be nearly two miles outward from the wellfields. The 5.0 foot
contour is projected to extend out approximately 6.0 miles to the north and two miles to the south
from the Jane Dough Unit ISR Project area.
The flowing wells that are inside the 10 foot contours and produce the majority of its water from
the A Sand are likely to cease flowing. Most of the flowing wells in the area only have a few PSI
pressure when they are shut in. Brown 20-9 and Pats #1 flowing wells are completed in the A Sand
and would very likely cease flowing during the ISR operation. In a 3.0-mile radius of the Jane
Dough Unit, there are approximately 10 free flowing wells. Most of these flowing wells are not
thought to be completed in the A Sand. If any of these wells are completed in the A Sand they
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may be impacted by the drawdown associated with the Jane Dough Unit. Exhibit JD-D6-1 shows
the approximate location of the wells in relation to the Jane Dough Unit. As stated in the Technical
Report, Uranerz has confidential surface use agreements in place with the landowners detailing
mitigation measures that Uranerz would implement if a free flowing well is impacted by the
Nichols Ranch ISR Project.
4.4.2 No Action Alternative
Under the No Action Alternative, the Proposed Action would not be implemented. No additional
ground would be disturbed, ISR operation would not be undertaken, and no additional impacts to
surface water or groundwater resources would take place beyond those that already exist.
4.5 ECOLOGICAL RESOURCES
4.5.1 Proposed Action
4.5.1.1 Threatened, Endangered, Proposed, and Candidate Species
As discussed in Chapter 3.0, Section 3.5.2.2 and 3.5.3.2 of this document, only one threatened,
endangered, proposed, or candidate plant or animal species, the greater sage-grouse
(Centrocercus urophasianus), a candidate species, was documented as occurring in the Jane
Dough Unit (refer to Appendix JD-D9).
As discussed in Appendix JD-D9, the Proposed Action is not located in a core population area
(CPA) and would therefore not impact any greater sage-grouse CPAs. The closest CPA is located
approximately 9.4 miles northwest of the Jane Dough Unit. In addition, the WGFD has not
identified any winter concentration or connectivity areas within or near the Jane Dough Unit.
Development activities are restricted in CPA, winter concentration areas, and connectivity areas;
however, none of these restrictions applies to the Jane Dough Unit.
However, one occupied greater sage-grouse lek (38-Cottonwood Creek 1) occurs within the
Jane Dough Unit (0.25 miles inside the southeast boundary of the Jane Dough Unit), and three
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O
additional
occupied
greater
sage-grouse
leks occur within
2.02,miles
of the
Jane Dough Unit:
38-Cottonwood
Creek
1 Satellite,
lek 38-Cottonwood
Creek
and lek
38-Cottonwood
Creeklek3
(refer to Figure JD-D9-3 in Appendix JD-D9 of the Technical Report). All of these leks have been
monitored
annually
since
2005
using
the
WGFD-approved
survey
methodology.
Lek 38-Cottonwood Creek 1 was active from 2005-2009; lek 38-Cottonwood Creek I Satellite
was active in 2006 and 2007; lek 38-Cottonwood Creek 2 was active in 2005-2010; and lek 38Cottonwood Creek 3 was active in 2005-2007 and had one male and one female in 2010 (refer to
Table JD-D9-2 in Appendix JD-D9). Very little activity has been noted at any of these leks after
2010; however, one female was recorded at 38-Cottonwood Creek 3 in 2012 (refer to
Table JD-D9-2 in Appendix JD-D9). Based on this data, the WGFD classifies all four of these
leks as occupied. An occupied lek is defined as any lek that has been active during at least one
strutting season within the past 10 years.
Based on the location of the proposed wellfields and know leks, the Proposed Action would have
S
no physical impacts to greater sage-grouse leks. The closest portion of the Jane Dough Unit
wellfield is approximately 0.75 mi away from Cottonwood Creek 1 lek (Figure JD-D9-3 of
Appendix JD-D9 of the NRC Technical Report). In addition, the Wyoming Governor's Executive
Order 2011-5, identifies areas outside of CPA and within 0.25 mile of any occupied leks as no
surface occupancy areas; meaning that no development can be permitted through any state agency
to occur in these areas. Uranerz would not conduct any activities within the 0.25 mile no surface
occupancy area around Cottonwood Creek 1 lek.
It is also possible that noise from construction activities could impact nesting and brood rearing
activities of greater sage-grouse and they might avoid using nesting and brood rearing habitat near
any occupied lek (Knick and Connelly 2011).
Based on the location of the proposed wellfields and this lek, the Jane Dough Unit will have no
direct physical impacts on any greater sage-grouse leks. The closest portion of the Jane Dough
Unit wellfield is approximately 0.75 mile away from Cottonwood Creek I lek. In addition, the
Wyoming Governor's Executive Order 2011-5, identifies areas outside of CPA but within
0.25 mile of any occupied leks as no surface occupancy areas; meaning that no development can
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be permitted through any state agency to occur in these areas. Therefore, Uranerz will not conduct
any ground-disturbing activities within the 0.25 mile no surface occupancy area around any
occupied lek.
It is also possible that construction activities could impact nesting and brood rearing activities of
greater sage-grouse and they might avoid using nesting and brood rearing habitat near any
occupied lek. Therefore, to address the potential disturbance near occupied greater sage-grouse
leks, Executive Order 2011-5 indicates that "a two (2) mile seasonal buffer should be applied to
occupied leks." To comply with this portion of the Executive Order, Uranerz will:
1. monitor attendance at this lek annually during the lekking season (April 1 through May 7);
2. not conduct any surface-disturbing activities (e.g., topsoil removal) within 2 miles of any
occupied lek from March 15 through June 30; and
3.
if an area is physically disturbed (i.e., stripped of topsoil) prior to March 15, Uranerz will
be able to continue all non-surface disturbing activities (e.g., construction, drilling, well
completion, pipeline installation, etc.) within 2 miles of any occupied lek between March
15 and June 30.
During the seasonal buffer period, Uranerz will limit non-surface
disturbing activities to daylight hours and will minimize noise to the extent possible.
4. Once uranium extraction facilities have been installed, Uranerz will be able to conduct
year-round routine and emergency maintenance and service on all facilities within the Jane
Dough Unit.
To reduce raptor predation on greater sage-grouse, the construction of overhead power lines,
permanent high-profiled structures such as storage tanks, and other perch sites would not be
constructed within 0.25 mi of any active lek. In addition, some greater sage-grouse could be lost
due to vehicle collisions. Therefore, Uranerz will advise project personnel of appropriate speed
limits for specific access roads, that they are not allowed to haze or harass the animals, and that
they should minimize any direct disturbance to all wildlife whenever possible.
Some greater sage-grouse could be lost due to vehicle collisions. Therefore, Uranerz would advise
project personnel of appropriate speed limits for specific access roads, that they are not allowed to
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O
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haze
or harass
the animals, and that they should minimize any direct disturbance to all wildlife
whenever
possible.
4.5.1.2 Wildlife
4.5.1.2.1 Big Game
The entire project area lies within winter/yearlong pronghorn antelope and mule deer range of the
Pumpkin Buttes Herd Units (WGFD 201 la and WGFD 201 ib). Direct impacts to big game as a
result of project activities will include the disturbance of a portion of winter/yearlong range, loss
of forage, increased potential for poaching, vehicular collision accidents, and the displacement of
big game into surrounding areas. An estimated 101 acres will be incrementally disturbed during
the life of the operation at the Jane Dough Unit. As a result of these habitat disturbances, the
winter/yearlong range carrying capacity for big game will be reduced during the life of the Jane
Dough Unit and for approximately 1-3 years following mining until vegetative growth on the
revegetated areas becomes productive enough to support big game. Only approximately 50-60
acres will be disturbed for approximately 2 years and these areas will be withdrawn from use as
wildlife habitat at any given time. Therefore, the Jane Dough Unit is not expected to have any
adverse impacts on pronghorn antelope or mule deer.
Uranerz will also perform interim
reclamation operations that will minimize displacement of big game species.
No significant increase in the potential for vehicle collision with big game is expected because of
the short distances and low speeds allowed on the project access roads. Levels of vehicular traffic
associated with mine development and use of the roads are not expected to increase above current
levels.
The number of employees and the nature and intensity of mining activities will be comparable to
those already taking place near this site, and no increase in the potential for poaching and general
harassment of big game is anticipated.
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The number of employees and the nature and intensity of mining activities would be comparable
to those already taking place on this site, and no increase in the potential for poaching and general
harassment of big game is anticipated. Mitigation plans such as speed limits and fencing would
aid in the reduction of big game conflicts associated with the Jane Dough Unit.
4.5.1.2.2 Upland Game Birds, Shorebirds, and Waterfowl
The only upland game bird in the Jane Dough Unit is the greater sage-grouse and it is discussed
above. Limited habitat for shorebirds and waterfowl occur in the project area due to the fact that
aquatic habitats on the project area are generally seasonal in nature and higher-quality waterfowl
habitat is located outside the project area. Therefore, the Jane Dough Unit is not expected to have
any adverse impacts on waterfowl or shorebirds.
4.5.1.2.3 Mammalian Predators, Lagomorphs, and Small Mammals
The use of the project area by mammalian predators would be temporarily reduced due to mining
activities at the Jane Dough Unit. In addition, occasional outbreaks of Tularemia may have an
effect on the prey base (i.e., rabbits) for mammalian predators, which may have already resulted
in a shift of predators to other areas to seek prey. Therefore, the Jane Dough Unit is not expected
to have any adverse long-term impacts on mammalian predators.
Rabbits were abundant within the project area and wildlife study area.
Direct impacts to
lagomorphs as a result of the project may include vehicular collision accidents, loss of habitat,
increased motorized access by the public leading to legal and illegal harvest; and the displacement
of lagomorphs into surrounding areas due to human activity and project-related noise. It also
appears that natural and cyclical outbreaks of Tularemia can result in noticeable decrease in the
number of rabbits in the area. Since lagomorphs are relatively abundant in the project area, and
the fact that they show an affinity to disturbed areas with existing facilities such as culverts and
well pads, the Jane Dough Unit is expected to have a negligible short-term adverse impacts on
lagomorph populations and no adverse long-term impacts are likely to occur.
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Because suitable habitat exists throughout the project area, some small mammals may be displaced
mining-related activities over the life of the operation. Whenever possible, Uranerz would take
steps to minimize disturbance to known small mammal habitat such as black-tailed prairie dog
towns; however, some disturbance will be unavoidable.
Because of the limited amount of
disturbance (101 acres over the life of the operation), the Jane Dough Unit would have negligible
short-term and long-term impacts on small mammal populations in the immediate project area.
4.5.1.2.4 Raptors and Nongame/Migratory Birds
In 2013, 79 raptor nests were located within the Jane Dough wildlife study area, of which two
golden eagle nests were determined to be active. Based on the project area boundary, these trees
with nests would be removed during project activities. The principal impact to these nests from
project activities and associated increased human access is potential disturbance during nesting,
which could result in nest abandonment and decreased reproductive success. Potential conflicts
between active nest sites and project-related activities would be mitigated by annual raptor
monitoring and mitigation plans as presented in the Mine Plan.
The temporary disturbance of approximately 101 acres of raptor prey species' habitat is unlikely
to result in a reduction in the raptor population in the area because only 50-60 acres would be
disturbed during construction for approximately 2 years.
This reduction is expected to be
short-term and negligible. Therefore, the Jane Dough Unit is not expected to have any adverse
long-term impacts on raptor populations.
The short-term disturbance of approximately 101 acres of habitat would likely result in some
temporary reduction in the carrying capacity for nongame/migratory birds within the project area.
Birds may be displaced by the mining activities and the temporary disturbance of wildlife habitat;
however, the amount of habitat lost would be minimal in relation to the amount of comparable
habitats that are available in the general area. Therefore, the Jane Dough Unit is not expected to
have any adverse long-term impact on any passerine bird populations.
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4.5.1.2.5 Reptiles and Amphibians
No reptiles or amphibians were documented in the Jane Dough Unit; however, it is possible that
some individuals could be found in the project area.
The mining activities and temporary
disturbance may result in some reduction in the population levels of reptile and amphibian species
in the area; however, these impacts are expected to be short-term and negligible. Therefore, the
Jane Dough Unit is not expected to have any adverse long-term impacts on any reptiles or
amphibian populations.
4.5.1.3 Vegetation Impacts
Approximately 101 acres or less of land would be disturbed by the proposed Jane Dough Unit.
The impacts to vegetation will be short term as most disturbances are associated with the
development of the wellfields, access roads, and pipelines that would be immediately reclaimed
and reseeded. Additionally, the small amount of vegetation that may be affected by the proposed
project would occur over the life of the project with only 50-60 acres of land over approximately
a 2 year period of construction. With a large amount of land available outside of the disturbed
areas, the effect to the vegetation is minimal.
One impact that could result to the vegetation is the introduction of non-native species or weeds
associated with the activity of the Jane Dough Unit. One noxious weed species, Canada thistle, is
found in the proposed project area. Mitigation measures such as keeping vehicles that come into
the Nichols Ranch Project washed and possible spraying of weeds may be used to aid in reducing
the spread of these species.
4.5.2 No Action Alternative
Under the No Action Alternative, the Proposed Action would not be implemented. No additional
surface would be disturbed and no additional impacts to wildlife resources including threatened,
endangered, proposed, or candidate species would take place beyond those that already exist. Land
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would continue to be used for pastureland and mineral extraction activities.
CBNG and
conventional oil and gas operations in the Jane Dough Unit would continue.
4.6 AIR QUALITY RESOURCES
4.6.1 Proposed Action
The air quality impacts of the proposed project in the local and regional areas are minimal. The
main impact to the air quality would be from fugitive dust that is generated from the construction
of facilities, construction, and operation of the wellfields and the increase in traffic from the
operation of the proposed project. Fugitive dust releases are estimated to be the same during the
construction of the Jane Dough Unit as they are during the operation of the proposed project since
the amount of vehicle traffic is expected to be the same. Detailed calculations of the amount of
estimated fugitive dust that would be released by the project are presented in Appendix JD-D4 of
the NRC Technical Report). The estimated release of fugitive dust from the proposed project is
under the allowable 250 tons per year increment for prevention of significant deterioration of air
quality.
The potential for fugitive dust emissions from wind erosion would be minimized by promptly
reclaiming disturbed soil and establishing vegetative cover on soil stockpiles. Most of the work
associated with wellfield installation would take place with stationary equipment hence any
additional fugitive dust releases resulting from vehicular traffic in the wellfield would be small
because of low traffic volume.
Air quality in the wellfields could be affected by radon gas. It is possible that radon gas could be
released as result of operations in the wildlife. This gas can be present in the processing solutions
and could escape into the atmosphere in several locations. In order to escape, the dissolved radon
gas would first have to be vented in the wellfield from either individual well vents or from the
header house.
The radiological effects of radon or any radiological emission upon the local and surrounding area
was completed using the NRC MILDOS model for predicting radiological doses. The results of
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the MILDOS modeling are described in Chapter 7.0, Section 7.3 of the NRC Technical Report.
The estimated releases from the Jane Dough Unit are small fractions of the allowable does limit
for the general public.
4.6.2 No Action Alternative
Under the No Action Alternative, the Proposed Action would not be implemented. No additional
surface would be disturbed and no additional air quality impacts would take place beyond those
that already exist.
4.7 NOISE
4.7.1 Proposed Action
Noise related to development of the Jane Dough Unit would primarily be associated with drilling
and operation of the wells, including the use of heavy equipment necessary to scrape and level the
ground surface for drilling, travel, etc. The NRC and WDEQ (2008) estimated that noise impacts
from construction, operations, and aquifer restoration generally would be "small to moderate," and
that noise impacts from decommissioning generally would be "small."
Figure ER4-4 presents the noise levels generated by various kinds of heavy equipment, including
that used at the proposed project. These noise levels generally range from 70 to 95 dBA at 50 ft.
Noise levels decrease at approximately 6 dBA with each doubling of distance, so a dBA of 95 at
50 ft would be reduced to approximately 55 dBA at 1.0 mi--the distance from the Jane Dough Unit
boundary to the nearest residence (i.e., T-Chair Ranch). Referring to Table ER3-1, this would be
an increase in noise levels from "very quiet" to "normal conversation." In the same way, a dBA
of 75 at 50 ft would be reduced to approximately 40 dBA at 1.0 mi--a level very similar to the
ambient noise level in the area. Noise levels would not be constant, but would occur only when
equipment was operating. Noise levels would be highest during construction, after which they
would decrease for the operating phase when noise would be generated primarily by trucks and
the processing facility itself. Traffic would be approximately eight pickup trucks per day and six
tractor-trailer trucks per week during all phases of the project-a small to moderate increase in
traffic.
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CONSTRUCTION EQUIPMENT NOISE LEVELS
NOISE LEVEL (dBA AT So FEET
60
Ii
RTH MOVING
70
II
00
II
II
O0
U1
LFRONT LOADER
E2
110
',b
II
]
JOERIALS HAPWIMING
[CONCRETE PUMPS
MOTOR CRANE
ETERIATORS
A•
; II
I--
COMPRESSORS
IWO
I1
70
80
90
100
II
110
SOURCE: EPA, 1971; "NOISE FRO MCONSTRUCTION EQU IPM ENT AN D OPERATIONS, BUILDING EQU IPM ENT.
AND HOME APPLIANCES'. NTID 900.1
Figure ER3-6
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Construction Equipment Noise Levels.
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4.7.2 No Action Alternative
Under the No Action Alternative, the Jane Dough Unit would not be developed and noise levels
would remain at the level that currently exists.
4.8 HISTORIC, CULTURAL, AND PALEONTOLOGICAL RESOURCE IMPACTS
4.8.1 Proposed Action
4.8.1.1 Historic and Cultural Resources
The results of the current and previously conducted Class III inventories indicate that 14 sites and
two IRs are located within the project area for Uranerz's Jane Dough Unit (Table ER4-2). The 14
sites consist of six sites that are eligible for listing on the NRHP and 12 that are ineligible. There
will be no effect to the 12 ineligible sites and the two IRs because of their NRHP eligibility, and
no further work is recommended for those cultural resources. A discussion of the project effects
and management recommendations for the two NRHP-eligible sites is provided below.
Two segments of the NRHP-eligible Bozeman Trail (Site 48JO 134-Segments 65 and 66) and four
segments of the NRHP-eligible Deadwood Road (Site 48CA1 568-Segment 31 and Site 48JO2292Segments 14, 15, and 16) were revisited or recorded within the project area in 2010. One of the
two Bozeman Trail segments (Site 48JO134-Segment 65) and three of the four segments of the
Deadwood Road (Site 48CA1568-Segment 31 and Site 48JO2292-Segments 14 and 15) are
recommended as noncontributing segments. There would be no adverse effect to these segments
because of their NRHP eligibility, and no further work is recommended.
The remaining segments of the Deadwood Road (48JO2292-Segment 16) and the Bozeman Trail
(48JO134-Segment 66) are both recommended as contributing to their sites' overall eligibilities.
While the two segments are both located outside the proposed wellfield, they could be potentially
disturbed by other project-related activities. However, the project would have no adverse physical
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Table ER4-2
Jane Dough Unit
Summary of Project Effects and Management Recommendations for Sites Within
the Jane Dough Unit.
Current NRHP Eligibility
Recommendation
Project Effects and Management
Recommendations
Bozeman TrailSegment 65
Bozeman TrailSegment 66
Deadwood RoadSegment 14
Deadwood RoadSegment 15
El igible-Noncontributing
No adverse effect
Eligible-Contributing
No adverse effect with physical
avoidance; no adverse visual effects
Eligible-Noncontributing
No adverse effect
Eligible-Noncontributing
No adverse effect
Deadwood RoadSegment 16
Deadwood RoadSegment 31
Eligible-Contributing
No adverse effect with physical
avoidance, no adverse visual effects
Eligible-Noncontributing
No adverse effect
Not Eligible Sites
48CA5393
Lithic scatter
Not eligible
No effect
48CA5394
Trash scatter
Not eligible
No effect
48CA5395
Lithic scatter
Not eligible
No effect
48CA5396
Lithic scatter
Not eligible
No effect
48CA5397
Lithic scatter
Not eligible
No effect
48CA5398
Oil/gas well field
Not eligible
No effect
48CA5399
48CA5400
48CA540 I
Lithic scatter
Lithic scatter
Not eligible
Not eligible
No effect
Not eligible
Not eligible
No effect
48CA5412
Lithic scatter
Lithic scatter
48CA6583
Trash scatter
Not eligible
Not eligible
No effect
Not eligible
No effect
Not eligible
No effect
Site No.
Eligible Sites
48JO 134Segment 65
48JO 134Segment 66
48JO2292Segment 14'
48JO2292Segment 15'
48JO2292Segment 16'
48CA 1568Segment 3 1
Site Type
48JO3452
Lithic scatter
Isolated Resourcees
IR-I
Lithic scatter
IR-2
Biface
No effect
No effect
No effect
Site 48CA 1568 and 48JO2292 (Deadwood Road) are treated as one historic site.
effect on either segment because Uranerz will avoid direct ground-disturbing activities to the
segments. Furthermore, there would be no adverse visual effects to either segment because the
integrity of the setting has been significantly compromised and no longer contributes to either
segment's overall eligibility status.
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In addition, Uranerz activities would not significantly impact the viewshed of any NRHP-eligible
sites (e.g., Bozeman Trail and Deadwood Road segments) located outside the Jane Dough Unit
project area because the proposed disturbances are consistent with the existing widespread visual
disturbances associated with ongoing CBNG and conventional oil and gas development and ISR
development on the surrounding landscape.
Uranerz would not conduct any ground-disturbing work within the boundaries of Sites 48JO 134Segment 66 or 48J02292-Segment 16. In addition, Uranerz would not conduct any grounddisturbing work in areas that have not been previously inventoried and cleared for cultural
resources.
Uranerz would instruct all employees, contractors, subcontractors, and any additional parties
involved in the project not to search for, retrieve, deface, or impact archaeological materials
(e.g., arrowhead hunting), and that it is a violation of the federal Archaeological Resources
Protection Act (16 U.S.C. 470aa-mm) to do so on federal land.
If previously unknown cultural resources are discovered at the site, Uranerz would immediately
stop the ground-disturbing activities in the area of the discovery and would immediately notify the
NRC, WDEQ/LQD, and WSHPO.
Uranerz would have any discovered cultural materials
evaluated for NRHP eligibility by a professional meeting the Secretary of Interior's Standard for
Archaeology and History. Documentation of the discovery and evaluation would be promptly
provided to the NRC. The NRC would then consult with the WSHPO on the determination of
eligibility and adverse effect. If WSHPO determines that there is an adverse effect to a historic
property, NRC would follow the procedure to resolve the adverse effect as described above. Work
may continue in other areas of the site; however, work in the area of discovery may not resume
until such time as any additional actions are completed or deemed unnecessary. Assuming the
discovery is located on private property the cultural resource(s) would remain under the ownership
of the specific private landowner. Applicable federal, state, or local laws would apply to the
discovered cultural resources.
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If human remains or associated funerary objects as defined in the NAGPRA are encountered on
private land, work would immediately stop in the vicinity of the discovery, the area would be
secured, and Uranerz would immediately contact local law enforcement and the county coroner
per Wyoming Statute (W.S.) 7-4-104. If the remains are not associated with a crime, then Uranerz
would contact the NRC, WDEQ-LQD, and WSHPO and the landowner to further consult on the
treatment of the remains. Uranerz would assure compliance with applicable federal, state, and
local regulations relating to burial discoveries through inadvertent construction-related disturbance
of graves.
4.8.1.2 Paleontological Resources
A paleontological survey was conducted for the Jane Dough Unit. The survey did not produce any
vertebrate fossil bearing strata and no vertebrate fossils were discovered. However, some limited
invertebrate fossils (e.g., clams and mollusks) were discovered, these resources were located on
private lands and are not scientifically important. The results of the survey indicate that the Jane
Dough Unit will not have any impact to significant fossil remains because of the geology and poor
exposures of fossil bearing sediments.
4.8.2 No Action Alternative
Under the No Action Alternative, the Proposed Action would not be implemented. No additional
ground would be disturbed and no additional impacts to the existing historic, cultural, or
paleontological resources would take place beyond those that already exist.
4.9 VISUAL RESOURCES
4.9.1 Proposed Action
Because the Jane Dough Unit is located entirely on private land in a remote location, the operations
aesthetic impact is limited to only the landowners and those that have permission to be on the
landowner's property.
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CBNG and conventional oil and gas well are present in the Jane Dough Unit and surrounding area.
There are no sensitive visual resources within 4.0 miles of the Jane Dough Unit and the visually
sensitive Pumpkin Buttes area is more than 4.0 miles away. Therefore, the Jane Dough Unit would
have no visual impacts on the surrounding area.
4.9.2 No Action Alternative
Under the No Action Alternative, the Proposed Action would not be implemented. No additional
ground would be disturbed and no additional impacts to visual resources would take place beyond
those that already exist.
4.10 SOCIOECONOMICS (INCLUDING ENVIRONMENTAL JUSTICE)
4.10.1 Proposed Action
The socioeconomic impacts/benefits of the Jane Dough Unit would be a continuation of those seen
as a result of the Nichols Ranch ISR project as development of the Jane Dough Unit would be an
extension of approximately 9 years during the life of the Jane Dough Unit. The continued
impacts/benefits would be seen by the communities in the surrounding area of the project.
Businesses in towns such as Gillette, Wright, and Casper would continue to see some additional
income from purchase of goods and services by Uranerz and its employees. Currently, Uranerz
does not anticipate that additional employees would be required to run the Jane Dough Unit. The
approximate 45-55 current jobs at the Nichols Ranch Unit would continue to work in the Nichols
Ranch ISR project area and then transition to the Jane Dough Unit starting in approximately 2016
continuing to the end of the project in about 2024.
The continued employment of the approximate 45-55 people would not have an impact to the
current health and social services and educational services in the communities surrounding the
Jane Dough Unit and would not add to any change in housing in the region.
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The proposed project would continue to generate revenue for the State of Wyoming, Johnson and
Campbell counties, and the communities surrounding the project area through the collection of
state severance taxes, property taxes, and sale taxes. This continued collection of taxes would go
to the funding of schools, local city and county projects, and special county projects such as
improved water/sewer lines, community centers, and county road maintenance.
Regarding environmental justice, the estimated population of Campbell, Johnson, and Natrona
counties in 2010 by the U.S. Census Bureau was approximately 122,800. Minority populations
accounted for a small percentage, -4.6%, of the total population with percentages of minorities
being similar to or smaller than those of the rest of the state of Wyoming. The 2014 unemployment
levels for the three counties averaged -2.8% and in 2009 the average yearly earning was -$42,000
per year in Johnson County, -$50,000 per year in Natrona County, and -$74,000 per year in
Campbell County. The average county earning for the areas surrounding the Jane Dough Unit are
above the 2013 poverty level of $23,550 for a four family household. Figures 4-1 through 4-3 (see
map pockets in the NRC Technical Report) detail employment, population, and earnings data for
the Campbell, Johnson, and Natrona counties, Wyoming.
Based on the data above, no concentrations of people living below the poverty level or no
concentrated minority populations are located near the Jane Dough Unit; therefore, no adverse
environmental impacts would result to minority populations or those living below the poverty
level.
4.10.2 No Action Alternative
Under the No Action Alternative, the Proposed Action would not be implemented. No additional
impacts to socioeconomic resources (including environmental justice) due to not mining of the
Jane Dough Unit would take place beyond those that already exist or have been identified.
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4.11 PUBLIC AND OCCUPATIONAL HEALTH
4.11.1 Proposed Action
The values in Table ER4-3 show the maximum dose rates (based on MILDOS modeling) to seven
public receptors near the Jane Dough Units. The highest dose is projected to be 0.40 mrem at the
Pumpkin Butte Ranch Receptor. When compared to the public dose limit of 100 mrem specified
in 10 CFR 20, the minimum impact is clearly evident; the maximum dose is 250 times lower than
the protective standard. Values for the other public receptors are even lower. Another important
measure is the 10 rem effective dose, a level well in excess of the maximum predicted 0.40 mrem
value shown in the table below. According to the Health Physics Society, "Radiogenic health
effects (primarily cancer) are observed in humans only at doses in-excess of 10 rem delivered at
high dose rates. Below this dose, estimation of adverse health effects is speculative." In addition
to the seven nearby public receptors discussed here, the radiological assessment completed by
Uranerz included population bases that extended out to 80 km and in 16 compass directions from
the proposed process facilities. The model results showed that no member of the public would
receive a dose in excess of the standards. To summarize, the proposed operations would not have
a significant radiological impact on public health.
From a nonradiological perspective, chemicals associated with an ISR operation include C02,
HCL, H2 0 2, and NaOH. Emission rates for these chemicals are well below the threshold that
would trigger a requirement for a permit. With respect to fugitive dust, the same can be said; the
levels are too low to warrant a permit. In conclusion, because emissions are all below permitting
action levels, the concentrations are considered to be highly protective of the public.
The nuclear fuel cycle industry is one of the most, if not the most, regulated industry in the
U.S., and it is no wonder that all of the measures and comparisons discussed in other sections of
the NRC license application demonstrate that impacts to the public from this source category are
indeed very small. The same highly protective regulations given in 10 CFR 20, Standards for
Protection Against Radiation, apply to workers in the uranium recovery industry. Specifically,
10 CFR 20.1201, Occupational Dose Limits, are the protective occupational health standards.
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Table ER4-3
Jane Dough Unit
Projected Dose Rates to Public Receptors (Time-Step 4, Maximum Activity
Period).
Dose
(mrem/yr)*
Receptor
Public Receptors
T-Chair (Rolling Pin) Ranch
Dry Fork Ranch
Christensen Ranch
Pfister Ranch
Pumpkin Butte Ranch
Van Buggenum Ranch
Ruby Ranch
0.20
0.10
0.30
0.30
0.40
0.10
0.10
License Boundary Receptors
Jane
Jane
Jane
Jane
Dough
Dough
Dough
Dough
Unit
Unit
Unit
Unit
North-central
East-central
South-central
West-central
0.50
0.60
0.30
0.40
Public Dose Limit
100
*Total Effective Dose Equivalent (whole body).
An operator, such as Uranerz, must show compliance with these standards.
Compliance is
demonstrated through a number of checks and balances which include: (1) measurements with
numerous instruments during operations; (2) bioassays; (3) unannounced inspections by the
Radiation Safety Officer (RSO); (4) annual independent audits; (5) preparation of Standard
Operating Procedures (SOPs); (6) worker exposures measured with thermoluminescent dosimeter
badges; (7) NRC inspections; and (8) record-keeping and other mechanisms that provide assurance
that worker exposure to radioactive materials is kept As Low As Is Reasonably Achievable
(ALARA).
In summary, the close oversight listed provides a high level of assurance that
occupational health is well protected and there would be no significant impacts as a result of
implementation of the Proposed Action.
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4.11.2 No Action Alternative
Under the No Action Alternative, the Proposed Action would not be implemented. No additional
impacts to public health or occupational health risks would take place beyond those that already
exist or have been identified (specifically the Nichols Ranch ISR project).
4.12 WASTE MANAGEMENT
4.12.1 Proposed Project
Three types of waste will be generated with the proposed project; liquid, solid, and sanitary. All
liquid wastes generated as a result of the Jane Dough Unit at the Nichols Ranch CPP will be
disposed of through deep disposal wells located in the Nichols Ranch Unit. These liquid wastes
normally consist of wellfield bleed streams, plant wash down water, groundwater restoration water
from groundwater sweeping and groundwater treatment, and any other plant liquid effluent. The
deep disposal wells have been permitted through the WDEQ and will be operated according to
permit requirements. The deep disposal wells would be designed to handle a maximum flow rate
of -150 gallons per minute or as allowed by WDEQ permit.
Solid wastes generated at the proposed project include both contaminated and noncontaminated
wastes. Contaminated wastes include rags, trash, packing material, worn or replacement parts
from equipment, piping, and sediments removed from process pumps and vessels. Radioactive
solid wastes with contamination levels requiring disposal at a licensed NRC disposal facility would
be isolated in drums or other suitable containers prior to disposal offsite. Until wastes are disposed
of they would be held in an area with a restricted boundary. Any noncontaminated wastes would
be disposed of at a landfill located near Gillette in Campbell County, Wyoming. Other solid
contaminated wastes such as wellfield piping would either be reused in a different production area,
or flattened, surveyed, and shipped to a licensed NRC disposal site.
No restrooms, change houses, or lunchrooms would be installed in the Jane Dough Unit. However,
sanitary wastes from the restrooms, change houses and/or lunchrooms used at the Nichols Ranch
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O
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[SR
CPP
be disposed
of in approved
septic in
systems.
The with
septicWDEQ
systems
at the Nichols
Ranch
ISRwould
CPP would
be approved
and maintained
accordance
regulations.
4.12.3 No Action Alternative
Under the No Action Alternative, the Proposed Action would not be implemented. No additional
impacts to the environmental from wastes would take place beyond those that already exist or have
been identified (specifically at the Nichols Ranch ISR project).
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5.0 MITIGATION MEASURES
5.1 INTRODUCTION
The mitigation measure that are planned for the Jane Dough Unit are intended to reduce or avoid
adverse environmental impacts and to return the surface and subsurface of the Jane Dough Unit to
conditions compatible with the pre-mining uses. All groundwater that is affected by the Jane
Dough Unit would be restored to a condition of use equal to or exceeding that which existed prior
to project construction. All disturbed land would be reclaimed and restored to the pre-mining
condition of livestock grazing and wildlife habitat.
5.2 GROUNDWATER RESTORATION
Groundwater restoration is an important part of an ISR operation. The time it takes to restore the
groundwater is primarily linked to the capacity of the deep waste disposal well. If the capacity of
a deep waste disposal well is such that the time involved for groundwater restoration is
unacceptable, then measures such as installing another deep disposal well would be implemented
to decrease the restoration time.
5.2.1 Water Quality Criteria
The primary goal of the groundwater restoration efforts would be to return the groundwater quality
of the mined ore zone, on a production area average, to the pre-mining baseline water quality
condition that has been defined by the baseline water quality sampling program. During the
groundwater restoration, all parameters on an average basis would be returned to baseline or as
close to average baseline values as is reasonably achievable. If the average baseline values of
some of the parameters are unachievable using the best practical technology (BPT), Uranerz would
then use a secondary goal of returning the groundwater to the WDEQ class of use designation.
This would return the groundwater to a quality consistent with the use of the water prior to the ISR
extraction.
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The use categories of the groundwater are those established by the WDEQ. Pre-mining baseline
water quality data, groundwater use category, available technology, and economics would be
criteria used in attaining the final level of water quality during restoration.
5.2.2 Restoration Criteria
Groundwater restoration criteria in a production area would be based on the baseline water quality
data collected for each production area. The baseline water quality data would include data
collected from wells completed in the ore zone and perimeter monitoring ring wells. Baseline
water quality parameters would be used, on a parameter by parameter basis, to monitor restoration
activities in returning the affected groundwater back to pre-mining quality as reasonably as
possible.
Specific restoration values would be established prior to mining in each production area by
computing specific restoration values for specific parameters. The restoration values would be the
mean plus two standard deviations of the pre-mining water quality for each parameter listed in
Table 5-1 of the NRC Technical Report. These restoration target values would not change unless
the operational monitoring program indicates that baseline water quality has changed in a
production area because of accelerated movement of groundwater, and that such change justifies
re-determination of the baseline water quality. If this were to occur, resampling of monitor wells
would be conducted along with the WDEQ and NRC reviewing and approving the change to
restoration values.
The success of the restoration would be determined after the completion of the stability monitoring
period (see Section 5.1.1.4). If no significant increasing trends in restoration values are identified,
restoration would be deemed complete.
A summary report requesting approval would be
submitted along with the appropriate water quality data to the regulatory agencies. When approval
is received from the regulatory agencies, final decommissioning of the wellfield would commence.
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5.2.3 Groundwater Restoration Methods
For ISR operations, a common commercial groundwater restoration program consists of two
stages, the restoration stage and the stability monitoring stage. The restoration stage typically
consists of three phases such as groundwater sweep, groundwater transfer, and groundwater
treatment. The stability monitoring stage includes a six month or longer time period in which the
groundwater is monitored for successful restoration by monitoring the restoration targets for
consistency.
The three phases used in groundwater restoration are designed to efficiently and effectively restore
the groundwater so that groundwater loss is kept to a minimum and restoration equipment is
optimized. Monitoring of the quality of groundwater would occur in selected wells as needed
during restoration to determine the efficiency of the operations and to determine if additional or
alternate techniques are necessary.
Online production wells would be sampled for
certain parameters, such as uranium and conductivity, to determine restoration progress on a
pattern-by-pattern basis.
The sequence of the restoration methods used would be determined based on operating conditions
and waste water system capacity. Depending on the progress of restoration, it is possible that not
all phases of the restoration stage would be utilized. Uranerz would determine the need for certain
restoration steps based on the progress of restoration and the monitoring of restoration values.
During groundwater restoration, a reductant may be added to lower the oxidation potential of the
ore zone.
Either a sulfide or sulfite compound may be added to the injection stream in
concentrations sufficient to reduce the mobilized species. The use of reductants is beneficial
because several of the metals typically found in the ore zone groundwater become solubilized
during the recovery process. These metals can then form stable insoluble compounds that are
usually in the form of sulfides.
Dissolved metal compounds that are precipitated by such
reductants include those of molybdenum, selenium, uranium, and vanadium.
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Once restoration activities have returned the average concentration of restoration parameters to
acceptable levels, the WDEQ and NRC would be contacted for agreement that restoration has
been achieved in the production area. After this, the stability monitoring stage would begin. This
phase of restoration consists of monitoring the water quality in the restored production area for
six months after the successful completion of the restoration stage. When the stability monitoring
stage is completed, Uranerz would make a request to the WDEQ and NRC that the production
area be deemed restored.
5.2.3.1 Groundwater Transfer
During the groundwater transfer phase, water may be transferred between a production area
beginning restoration operations and a production area beginning mining operations.
Also, a
groundwater transfer may occur within the same production area, if one section of the production
area is in a more advanced state of restoration than another.
Pre-mining baseline quality water from the production area beginning mining may be pumped and
injected into the production area in restoration. The higher Total Dissolved Solids (TDS) water
from the production area in restoration would be recovered and injected into the production area
beginning mining. The direct transfer of water would act to lower the TDS in the production area
being restored by displacing affected groundwater with pre-mining baseline quality water.
The goal of the groundwater transfer is to blend the water in the two production areas until they
become similar in conductivity. The water recovered from the restoration production area may be
passed through ion exchange columns and/or filtered during this phase if suspended solids are
sufficient in concentration to present a problem with blocking the injection well screens.
For the groundwater transfer to occur between production areas, a newly constructed production
area must be ready to begin mining. Because of this condition, a groundwater transfer can occur
at any time during the restoration process, if needed. If a production area is not available to accept
transferred water, then groundwater sweep would be utilized as the first phase of restoration.
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The advantage of using the groundwater transfer technique is that it reduces the amount of water
that must ultimately be sent to the deep disposal well during restoration activities.
5.2.3.2 Groundwater Sweep
During the groundwater sweep stage, the groundwater from a production area beginning
restoration is pumped from the production area to the processing plant though all production wells
without any re-injection. By doing this, native groundwater is drawn into the production area to
flush contaminants from the mining zone thus "sweeping" the mining aquifer.
The cleaner
baseline water has lower ion concentrations that act to strip off the cation that have attached to the
clays during mining. The water produced during groundwater sweep is usually then sent to the
processing plant for treatment and removal of any uranium that could be in the production area
water. Ra-226 and dissolved solids are also removed. After the treatment, the swept water is
disposed of in an approved manner such as injection into a deep disposal well.
The rate of groundwater sweep would be dependent upon the capacity of the deep disposal wells
and the ability of the production area to sustain the rate of withdrawal. A hydraulic barrier may
be employed during this stage if there is an adjacent operation production area to prevent drawing
groundwater from the operational production area to the production area undergoing restoration.
5.2.3.3 Groundwater Treatment
Either following or in conjunction with the groundwater sweep, water would be pumped from the
mining zone to treatment equipment at the surface.
Ion exchange and reverse osmosis (RO)
treatment equipment would then be utilized during this phase of restoration.
Groundwater recovered from the restoration production area may be passed through the ion
exchange system prior to RO. The groundwater would either be sent to waste disposal system or
it would be re-injected into the production area. The ion exchange columns exchange the majority
of the contained soluble uranium for chloride or sulfate. Additionally, prior to or following ion
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exchange treatment, the groundwater may be passed through a de-carbonation unit to remove
residual carbon dioxide that remains in the groundwater after mining.
At any time during treatment, an amount of reductant sufficient to reduce any oxidized minerals
may be metered into the restoration production area injection stream. The concentration and
amount of reductant injected into the restoration production area is determined by how the ore
zone groundwater reacts with the reductant. The goal of reductant addition is to decrease the
concentrations of oxidation-reduction sensitive elements through reduction of these elements.
All or some portion of the restoration recovery water can be sent to the RO unit. The use of an
RO unit 1) reduces the total dissolved solids in the groundwater being restored, 2) reduces the
quantity of water that must be removed from the aquifer to achieve restoration limits,
3) concentrates the dissolved contaminates in a smaller volume of brine to facilitate waste disposal,
and 4) enhances the exchange of ions from the formation due to the large difference in ion
concentration. The RO passes a high percentage of the water through the membranes, leaving
60 to 90 percent of the dissolved salts in the brine water or concentrate. The clean water, called
permeate, would be either re-injected, or stored for use in the mining process, or sent to the waste
water disposal well.
The permeate may also be de-carbonated prior to re-injection into the
wellfield. The brine water that is rejected contains the majority of the dissolved salts in the affected
groundwater and is sent to the disposal system. Make-up water, which may come from either
water produced from a production area that is in a more advanced state of restoration, or water
being exchanged with a new production area, water being pumped from a different aquifer, or the
purge of an operating production area, or a combination of these sources, may be added prior to
the RO or production area injection stream to control the amount of "bleed" in the restoration area.
If needed, the reductant (either biological or chemical) added to the injection stream during this
stage would scavenge any oxygen and reduce the oxidation-reduction potential of the aquifer.
During mining operations, certain trace elements are oxidized. By adding the reductant, the
oxidation-reduction potential of the aquifer is lowered thereby decreasing the solubility of these
elements. Regardless of the reductant used, a comprehensive safety plan regarding reductant use
would be implemented.
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If necessary, sodium hydroxide may be used during the groundwater treatment phase to return the
groundwater to baseline pH levels. This would assist in immobilizing certain parameters such as
trace metals.
The number of pore volumes treated and re-injected during the groundwater treatment phase would
depend on the efficiency of returning the production area back to pre-mining baseline water quality
conditions. This relies on the efficiency of the RO in removing contaminates from the restoration
production area groundwater and the success of the reductant, if used, in lowering the uranium and
trace element concentrations.
5.2.3.4 Restoration Monitoring
During restoration, lixiviant injection is discontinued while improving the quality of the
groundwater back to restoration standards. Because of this, the possibility of an excursion is
greatly reduced. The monitor ring wells, overlying aquifer wells, and underling aquifer wells
sampling frequencies would be changed from once every two weeks to once every 60 days during
restoration. The wells are analyzed for the excursion parameters chloride, total alkalinity and
conductivity. Water levels are also obtained at these wells prior to sampling.
In the event that unforeseen conditions (such as snowstorms, flooding, and equipment
malfunction) occur, the WDEQ would be contacted if any of the wells cannot be monitored within
65 days of the last sampling event.
5.2.4 Restoration Stability Monitoring Stage
Once a production area has been designated as restored by the WDEQ, a six month stability period
begins to ensure that the restoration goal of returning the production area groundwater to baseline
water quality or pre-mining class of use category is maintained. The following restoration stability
monitoring program would be in place during the stability period:
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1. The monitor ring wells are sampled once every two months and analyzed for the UCL
(upper control limits) parameters: chloride, total alkalinity and conductivity; and
2. At the beginning, middle, and end of the stability period, the production wells would be
sampled and analyzed for the parameters in Table 5-1.
In the event that unforeseen conditions (such as snowstorms, flooding, and equipment
malfunction) occur, the WDEQ would be contacted if any of the monitor or production wells
cannot be monitored within 65 days of the last sampling event.
5.2.5 Well Abandonment
When the groundwater has been adequately restored and determined stable by the regulatory
agencies, surface reclamation, and well abandonment would begin. All production, injection,
monitor wells, and drill holes would be abandoned in accordance with WS-35-11-404 and
Chapter VIII of the WDEQ Rules and Regulations to prevent adverse impacts to groundwater
quality or quantity, and to ensure the safety of people, livestock, wildlife, and machinery in the
area.
Wells would be abandoned using the following procedure:
1. All pumps and piping would be removed from wells, when practicable.
2. All wells are plugged from total depth to within 5 ft of the collar with a well
abandonment plugging gel formulated for well abandonment and mixed in the
recommended proportion of 10 to 20 lbs per barrel of water, to yield an abandonment
fluid with a 10 minute gel strength of at least 20 lbs/I 00 sq ft and a filtrate volume
not to exceed 13.5 cc.
3. The casing is cut off at least two feet below the ground surface. Abandonment fluid
is used to fill the void to the top of the cut-off casing.
4. Cement or a plastic plug would be placed at the top of the abandoned well casing. The
area is backfilled, smoothed, leveled, and reseeded to blend with the natural terrain.
Any deviation from the above procedure would be approved in advanced by the NRC and WDEQ.
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5.3 SURFACE RECLAMATION AND DECOMMISSIONING
5.3.1 Introduction
At the completion of mining of the Nichols Ranch ISR Project, all lands disturbed by the mining
project would be restored to their pre-mining land use of livestock grazing and wildlife habitat.
Any buildings or structures would be decontaminated to regulatory standards, and either
demolished and trucked to a disposal facility or turned over to the landowner if desired. Baseline
soils, vegetation, and radiological data would be used as guide in evaluating the final reclamation.
A final decommissioning plan would be sent to the NRC for review and approval at least 12 months
prior to the planned decommissioning of a wellfield or project area.
5.3.2 Surface Disturbance
Because of the nature of ISR mining, minimal surface disturbance would be associated with the
Jane Dough Unit. Surface disturbance would consist of construction activities associated with the
construction of the wellfields including well drilling, pipeline installations, and road construction.
Disturbances associated with the wellfield impact a relatively small area and have short term
impacts.
Surface disturbances associated with the construction of the central processing plant, satellite
plants, and wellfield header houses would be for the life of those activities. Topsoil would be
stripped from these areas prior to the construction of the facilities. Disturbances associated with
the wellfield drilling and pipeline installation are limited and reclaimed as soon as possible after
completion of these items. Access roads to and from the wellfield are also limited with minimum
surface disturbance.
5.3.3 Topsoil Handling and Replacement
Topsoil would be salvaged from any building sites, permanent storage areas, main access roads,
and chemical storage areas prior to construction in accordance with WDEQ requirements. To
accomplish this, typical earth moving equipment such as rubber tired scrapers and front end loaders
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would be utilized. Topsoil salvage operations for the wellfield would be limited to the removal of
topsoil at header house locations. Wellfield access roads topsoil removal would be in accordance
with the landowner's road construction practices. These practices are outlined in the letter attached
in Addendum 5A. Altogether, an estimated 101 acres of topsoil would be salvaged, stockpiled,
and reapplied during the life of the Jane Dough Unit.
Topsoil that is salvaged during construction activities would be stored in designated topsoil
stockpiles. These stockpiles would be located so as to minimize topsoil losses from wind erosion.
Topsoil stockpiles would also not be located in any drainage channels or other locations that could
lead to a loss of material. Berms would be constructed around the base of the stockpiles along
with the seeding of the stockpiles with a mixture of western wheatgrass and thickspike wheatgrass
at a seeding rate of 7 pounds pure live seed per acre per wheatgrass species to reduce the risk of
sediment runoff. Additionally, all topsoil stockpiles would be identified with highly visible signs
labeled "Topsoil" in accordance with WDEQ requirements.
During excavations of mud pits associated with well construction, exploration drilling, and
delineation drilling activities, topsoil is separated from the subsoil with a backhoe. The topsoil is
first removed and then placed at a separate location. The subsoil is then removed and deposited
next to the mud pit. When the use of the mud pit is complete (usually within 30 days of initial
excavation), the subsoil is then redeposited in the mud pit followed by the replacing of the topsoil.
Pipeline ditch construction utilizing a backhoe will follow a similar path with the topsoil stored
separately from the subsoil with the topsoil deposited on the subsoil after the pipeline ditch has
been backfilled. Trenching equipment may be used for trenching a nominally 6-inch, and no more
than 12-inch, wide trench line. Topsoil will not be salvaged unless specifically required or
requested in the surface owner agreement. Following installation, the trench is backfilled with the
excavated material. These methods of topsoil salvaging have proven to be adequate as
demonstrated by the successful revegetation and reclamation at prior and existing ISR operations.
5.3.4 Vegetation Reclamation Practices
All revegetation practices would be conducted in accordance with the WDEQ regulations and the
methods outlined in the mining permit. Topsoil stockpiles, along with as many as practical
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disturbed areas of the wellfield, would be seeded with vegetation throughout the mining operation
to reduce wind and water erosion. Final revegetation of the mine area would consist of seeding
the area with the permanent reclamation seed mix (Table ER6-1). This mixture was developed
through discussions with the landowner and approved by the WDEQ. A seeding rate of 15 pounds
of pure live seed per acre would be used when using a rangeland drill. On areas where it is not
practicable to use a drill, the seed would be broadcast at a rate of 30 pounds pure live seed per
acre.
The success of the final revegetation would be determined by measuring the revegetation in
meeting prior mining land use conditions and reclamation success standards as compared to the
"Extended Reference Area" outlined in WDEQ Guideline No. 2. The Extended Reference Area
allows for a statistical comparison of the reclaimed area with an adjacent undisturbed area of the
same or nearly the same vegetation type. The area that the Extended Reference Area has to
encompass; needs to be at least one half the size of the reclaimed area that is being assessed, or at
least no smaller than 25 acres in size.
In choosing the Extended Reference Area, the WDEQ would be consulted. This would ensure that
the Extended Reference Area adequately represents the reclaimed area being assessed.
success of the final revegetation and final bond release would be determined by the WDEQ.
Table ER6-1
Permanent Reclamation Seed Mixture.
Species
Percent of Mix
Pounds PLS/acre
Western Wheatgrass
16.7
3.10
Pubescent Wheatgrass Luna
16.7
3.10
Bozoisky Russian Wildrye
16.7
3.10
Intermediate Wheatgrass Rush
16.7
3.10
Slender Wheatgrass Pryor
16.7
3.10
Alfalfa/Inocculated Falcata
16.7
3.10
Total
100
18.6
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5.3.5 Road Reclamation
The wellfield access roads would allow vehicular traffic to move from the plants to the wellfields
and from one wellfield to another wellfield. The construction design for the wellfield access roads
is present in Addendum 5A. At the time of decommissioning, the land owner would decide which
wellfield access roads would remain and which roads would be reclaimed.
If wellfield access roads are to be reclaimed, the first step in reclaiming the wellfield access roads
would be to pick up and remove the scoria/gravel so that the road bed is back to the approximate
original grade. Next, the road bed would be either disced or ripped. The disturbed area would
then be mulched and seeded with the permanent seed mixture.
5.3.6 Site Decontamination and Decommissioning
5.3.6.1 Wellfield
Following the successful conclusion of the aquifer restoration stability period in a particular
production area, the wellfield piping, well heads and associated equipment would be removed and,
if serviceable, taken to a new production area for continued service. Wellfield equipment that is
no longer usable would be gamma surveyed and placed in either a contaminated or
noncontaminated bone yard located near the central processing plant for subsequent removal from
the site. If the final production area is being reclaimed, the nonsalvageable contaminated piping,
well heads, and associated equipment would be trucked from the site to an approved NRC disposal
facility.
5.3.6.2 Plant Dismantling
After groundwater restoration is complete in the final production area, decommissioning of the
Nichols Ranch Unit CPP would commence. The Nichols Ranch CPP may continue to be used
after completion of mining to process materials from other satellite units. All process equipment
associated with the plants would be dismantled and either sold to another NRC licensed facility or
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decontaminated in accordance with NRC Regulatory Guide 1.86 "Termination of Operating
Licenses for Nuclear Reactors" and "Guidelines for Decontamination of Facilities and Equipment
Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source or Special
Nuclear Material." Any material that cannot be decontaminated to an acceptable level would be
disposed of at an approved NRC facility. After decontamination, materials that would not be
reused or that do not have any resale value, like building foundations would be removed and
disposed of at an off-site facility. Additional detailed information is presented in the Reclamation
Plan of Technical Report for the Nichols Ranch Unit and will not be repeated here.
The Nichols Ranch Unit plant site would be contoured to blend in with the natural terrain after all
buildings have been removed. Gamma surveying would then be completed to verify that gamma
radiation levels are within acceptable limits. Topsoil replacement and reseeding of the area would
then take place.
5.3.7 Final Contouring
Because of the nature of solution mining, very little, if any, construction activities would take place
which would require any major contouring during reclamation. Any surface disturbances that do
occur would be contoured to blend in with the natural terrain. No final contour map has been
included since no significant changes in the topography would result from the proposed mining
operation.
5.3.8 Financial Assurance
Uranerz would maintain surety instruments to cover the costs of reclamation for the Jane Dough
Unit. The surety instruments would cover the costs of groundwater restoration, decommissioning,
dismantling, and disposal of all facilities including buildings and the wellfield, and the reclamation
and revegetation of all affected mining areas. Additionally, the NRC and WDEQ require an
updated Annual Surety Estimate Revision to be submitted each year to adjust the surety instrument
amount to reflect existing operations and those planned for construction or operation in the
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following year. Uranerz would revise any surety instrument amount to reflect any changes to the
Annual Surety Estimate Revision after its review and approval by the NRC and WDEQ.
Once the WDEQ, NRC, and Uranerz have agreed to the estimated reclamation and restoration
costs, a reclamation performance bond, irrevocable letter of credit, or other acceptable surety
instrument would be submitted to the WDEQ with a copy to the NRC.
5.3 CULTURAL RESOURCE MITIGATION
Uranerz would comply with the following cultural resource mitigation measures.
1. Uranerz would not conduct any ground disturbing work in areas that have not been
previously inventoried and cleared for cultural resources.
2. Uranerz would protect all cultural properties that have been determined eligible to the
National Register of Historic Places within the permit area from ground disturbing
activities until appropriate cultural resource mitigation measures can be implemented as
part of an approved mining and reclamation plan unless modified by mutual agreement in
consultation with the WSHPO and other regulatory agencies.
3. If cultural resources are discovered during operations, Uranerz would immediately stop
ground disturbing activities in the area of the discovery and would immediately notify the
NRC, WDEQ, the WSHPO, and any other appropriate regulatory agency.
5.4 WILDLIFE MITIGATION
Uranerz would comply with the following wildlife mitigation measures.
1. Uranerz would not conduct any ground disturbing activities within 0.25 miles of any
occupied greater sage-grouse lek.
2. Uranerz will annually monitor attendance at all leks during the lekking season (April 1
through May 7).
3. Uranerz will not conduct any surface-disturbing activities (e.g., topsoil removal) within
2.0 miles of any occupied lek from March 15 through June 30.
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4. If an area is physically disturbed (i.e., stripped of topsoil) prior to March 15, Uranerz will
be able to continue all non-surface disturbing activities (e.g., construction, drilling, well
completion, pipeline installation, etc.) within 2 miles of any occupied lek between
March 15 and June 30.
5. During the seasonal buffer period, Uranerz will limit non-surface disturbing activities to
daylight hours and will minimize noise to the extent possible.
6. Once uranium extraction facilities have been installed, Uranerz will be able to conduct
year-round routine and emergency maintenance and service on all facilities within the Jane
Dough Unit.
7. To reduce raptor predation on greater sage-grouse, the construction of overhead power
lines, permanent high-profiled structures such as storage tanks, and other perch sites would
not be constructed within 0.25 mi of any active lek.
8. Some greater sage-grouse could be lost due to vehicle collisions. Therefore, Uranerz will
advise project personnel of appropriate speed limits for specific access roads, that they are
not allowed to haze or harass the animals, and that they should minimize any direct
disturbance to all wildlife whenever possible.
These mitigation measures have been reviewed and concurred with by the Wyoming Game and
Fish Department (refer to Figure ER5-1).
5.5 WATER PROTECTION MEASURES
To minimize potential impacts to groundwater resources, Uranerz would comply with all
appropriate well completion standards specified by NRC, WDEQ/LQD, and the Wyoming State
Engineer's Office
To minimize potential impacts to surface water resources, Uranerz would develop and implement
a SWPP Plan for the newly affected areas.
Uranerz's current Wyoming Pollutant Discharge
Elimination System (WYPDES) permit and SWPP Plan for the Nichols Ranch Unit would be
expanded to include the Jane Dough Unit. This permit would be maintained pursuant to the
Federal Water Pollution ControlAct (Public Law 101-380) (also known as the Clean Water Act),
the Wyoming Environmental QualityAct, Wyoming Statutes 35-11 -101 through 35-11-1802, and
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Uranerz Energy Corporation
Jane Dough Unit
GOVERNOR
MATTHEW
H MEAD
WYOMING GAME AND FISH DEPARTMENT
5400 Bishop Blvd. Cheyenne, VVY 82006
Phone: (307) 777-4600 Fax: (307) 777-4699
wgfd.wyo.gov
DORCTOR
SCOTTrTALBOTTr
COMMISSIONERS
RICHARDKLOUDA
- President
CHARLESPRICE-Vice.President
MARKANSELMI
AARONCLARK
KEITHCULVER
MIKEHEALY
T. CARRIELITTLE
April 29, 2014
WER 12776
Uranerz Energy Coporation
Letter of Compliance
Governor's Sage Grouse Executive Order 2011-5
Jane Dough Unit of the
Nichols Ranch In-situ Recovery Uranium Project
Johnson and Campbell Counties
Dawn Kolkman
Permitting Manager
Uranerz Energy Coporation
1701 East E Street
PO Box 50850
Casper WY, 82605
Dear Ms. Kolkman:
The staff of the Wyoming Game and Fish Department (WGFD) has reviewed the Governor's
Sage Grouse Executive Order 2011 -5, Letter of Compliance concerning the Jane Dough Unit of
the Nichols Ranch In-situ Recovery Uranium project for Uranerz Energy Coporation. We offer
the following comments for your consideration.
The project is located within two miles of the Cottonwood Creek 1 lek. Uranerz has agreed to
and understands the following:
0 There will be no surface occupancy within .25 miles of the lek.
4 Monitor attendance at Cottonwood Creek 1 lek. This should be done in coordination
with the WGFD Sheridan Regional Office (Erika Peckham, 307-670-8164)
• They will not conduct any surface-disturbing activities (e.g., topsoil removal) within 2
miles of any occupied lek from March 15 through June 30.
* If an area is physically disturbed prior to March 15, Uranerz will be able to continue all
non-surface disturbing activities (e.g., construction, drilling, well completion, pipeline
installation, etc.) within 2 miles of any occupied lek between March 15 and June 30.
During the seasonal buffer period, Uranerz will limit non-surface disturbing activities to
daylight hours and will minimize noise to the extent possible.
* Once uranium extraction facilities have been installed all production and maintenance
activities will be allowed within the Jane Dough Unit. However, and best management
"Conserving Wihllife - Serving People"
Figure ER5-1 Letter from Wyoming Game and Fish Department.
ER-I 12
2014
April 2014
April
ER-1 12
Uranerz Energy Corporation
Jane Dough Unit
Dawn Kolkman
April 29, 2014
Page 2 of 2 - WER 12776
practices that benefit sage-grouse should be applied as applicable (speed reduction, noise
reduction, etc).
Thank you for the opportunity to comment. If you have any questions or concerns, please contact
Mary Flanderka, Habitat Protection Coordinator, 307-777-4587.
Sincerely,
akKo shi
MK/mf/gb
cc:
USFWS
Erika Peckham, WGFD - Sheridan Region,
Figure ER5-1 Letter from Wyoming Game and Fish Department (Continued).
April 2014
ER-i 13
Jane Dough Unit
Uranerz Energy Corporation
the WDEQ-WQD Rules and Regulations Chapters 2 and 18. The SWPP Plan is designed to
prevent and reduce the release of storm water-related pollution such as sediment and runoff from
other exposed materials. The SWPP Plan would include erosion control measures to prevent and
limit storm water pollution and procedures for periodic inspections of storm water pollution
prevention devices and practices. Uranerz would install and maintain all appropriate runoff and
erosion control measures as described in the SWPP Plan such as water bars, berms, and interceptor
ditches. Since the Jane Dough Unit would not have any office facilities, copies of the SWPP Plan
and inspection reports would be on file in the Nichols Ranch CPP.
To minimize potential impacts to surface and groundwater resources, Uranerz and its contractors
would manage, store, handle, and dispose of all petroleum products and wastes in compliance with
all appropriate federal and state regulations. In addition, Uranerz would train its personnel to
properly handle, transport, and dispose of all petroleum products and hazardous materials and
waste to avoid and reduce the potential occurrence of spills, leaks or releases. Uranerz would also
develop and implement an emergency response plan to address potential spills, leaks, or releases
of such materials. Uranerz would also mitigate potential spills, leaks, or releases of petroleum
products and wastes by conducting routine maintenance and inspections on all appropriate vehicles
and equipment to catch and fix problems early.
In the event of a spill, leak, or release of petroleum products and wastes (i.e., non-wellfield
production fluid), Uranerz would clean up and dispose of the spill, leak, or release in accordance
with state and federal regulations. All spills of petroleum products or hazardous chemicals in
excess of the allowable quantity as determined by WDEQ-WQD would be reported to WDEQWQD and EPA. Spills, leaks, or releases of wellfield production fluids would be reported to the
NRC and WDEQ-LQD in accordance with applicable regulations.
Uranerz would develop and implement waste management programs to meet the applicable
WDEQ-Solid and Hazardous Waste Division regulatory requirements. All wastes generated from
these materials would be handled and disposed of in accordance with applicable federal and state
regulations.
April 2014
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Jane Dough Unit
Uranerz Energy Corporation
Any hazardous waste, such as organic solvents, paints, waste oil and paint thinners, empty
chemical containers, tank sediments/sludges, chemical waste, and spent batteries, would be
disposed of in accordance with a management program that the facility would develop to meet
applicable local, federal, and state regulatory requirements for the disposal of nonradioactive
hazardous waste.
During construction, portable self-contained chemical toilets would be provided for human waste
disposal. As required, the holding tanks for the chemical tanks would be pumped out and their
contents disposed of at an approved sewage facility in accordance with applicable rules and
regulations. Upon completion of construction operations, sanitary wastes from restrooms would
be disposed of in an on-site septic system that would be constructed and operated by Uranerz. The
septic system would be located at the Nichols Ranch ISR CPP. The septic system would be
designed in order to accommodate the estimated maximum of 35 permanent employees. Prior to
construction of this facility, Uranerz would obtain a permit to construct the septic system from
WDEQ-WQD.
5.6 SOLID WASTE DISPOSAL
Upon completion of construction activities, all debris and other waste materials not placed in the
dumpsters or trash cages would be cleaned up, removed from the construction area, and disposed
of in an approved landfill.
No potentially harmful materials or substances would be left on
location, and all solid waste would be disposed at an appropriate solid waste disposal facility. All
facilities that would be used by Uranerz would be properly permitted through the appropriate
state/local regulatory authority.
All radioactive wastes would be handled and disposed at a properly permitted and licensed waste
disposal facility in accordance with applicable federal and state regulations.
April 2014
ER-1 15
Uranerz Energy Corporation
dane Dough Unit
6.0 ENVIRONMENTAL MEASUREMENTS AND MONITORING PROGRAMS
6.1 RADIOLOGICAL MONITORING
This section describes the results of baseline radiological measurement and monitoring conducted
in support of the Jane Dough Unit. The radiological measurement and monitoring programs to be
implemented during operation of the Jane Dough Unit are described in the license application NRC
Technical Report at Section 5.7.7.
6.1.1 Surface Soil, Subsurface Soils and Sediment
6.1.1.1 Purpose and Procedure
An extensive soil and sediment sampling program was completed for the Jane Dough Unit. The
purpose of the effort was to develop a representative radiological baseline for surface and
subsurface soils and sediments.
Prior to conducting a field reconnaissance and collecting the samples, a map was prepared on a
large-scale U.S. Geological Survey topographic base showing the license boundary, plant site
location and ore zone footprint (in as much as it was known at the time). Because of their
importance in an assessment such as this, the location of cultural features (residences, ranches,
water wells, water impoundments, roads, etc.) with respect to the future process facility,
production areas and license boundary were considered in the sampling design.
After completing the base map described above, a field reconnaissance was conducted to visually
inspect the project area. All of the features just noted were considered in terms of their respective
locations to the license boundary. Following the reconnaissance, a sample site map was prepared.
Coordinates for each sample site were included with the map.
In determining the number, type (surface, subsurface and sediment) and areal distribution of
sampling locations, pertinent NRC documents were used, along with judgment based on many
April 2014
ER-I 16
Uranerz Energy Corporation
dane Dough Unit
years of experience developing pre-operational and operational environmental monitoring
programs for ISR operations. The primary documents included: (1) NRC Regulatory Guide 4.14,
"Radiological Effluent and Environmental Monitoring at Uranium Mills," USNRC, April 25,
1980; (2) NUREG-1569, Standard Review Plan for In Situ Leach Uranium Extraction License
Applications," Final Report, USNRC, June 2003; and (3) NUREG-1748 "Environmental Review
Guidance for Licensing Actions Associated with NMISS Programs," Final Report, USNRC,
August 2003.
Regulatory Guide 4.14 is the document that outlines the specifics of a pre-operational radiological
monitoring program. Table 1 in the guide, for example, lists the suggested number, type, location,
and frequency of samples. Because of the age of the guide, and because it primarily addresses
conventional mills, Uranerz employed a modified baseline sampling program designed for a
modem ISR facility. From a standpoint of physical disturbance and radiological alteration, it is
widely recognized that a modem-day ISR operation has minimal impact on surface and subsurface
soils.
There are three major reasons why the impacts are insignificant: (1) the recovery technique does
not require the removal of overburden nor does it require the physical removal of the ore zone; (2)
it is a wet process up to the stage of drying and packaging; and (3) modem dryers and packaging
systems do not have significant particulate discharges.
Thus in the absence of significant
particulate sources, radiological impacts on soils and sediments through aerial dispersal and
subsequent deposition are not associated with modem ISR operations.
Experience shows that potential radiological impacts are almost exclusively associated with
accidental spills from pipe leaks or ruptures that occur off of the process facility pad (i.e., within
the wellfields and between the wellfields and the process facility). Spills occurring on the process
pad are fully contained by the curbed volume of the pad and its sump system. It should be noted
that an accidental spill from a pipe break in a wellfield does not necessarily result in a major impact
on soils or sediments. Engineering controls and a management program based on the principles
of ALARA provide a high degree of assurance that impacts would be minimal. To illustrate, a
pipeline break would cause a loss in pressure and this would be quickly detected by the monitoring
April 2014
ER-I 17
UranerzEnergy Corporation
Jane Dough Unit
system. In addition to engineering controls, employees who are in the wellfields on a daily basis
are trained to observe routinely the condition pipelines and wellheads. Leaks or breaks would be
reported immediately. In the event of a break, the wetted area would be surveyed, sampled, and
recorded on a spill map. Soils with significantly elevated levels of uranium and radium-226 would
be removed and disposed at a licensed site.
Knowing that potential impacts are attributed to pipeline ruptures and leaks, the pre-operational
sampling program was designed to thoroughly characterize radiological baseline conditions in the
areas most likely to experience potential impacts. A review of Exhibit JD-D1 1-1, Jane Dough
Unit-Soil, and Sediment Sample Location Map in the attached Appendix JD-DI 1 clearly shows
that the focus of the baseline
characterization
was on the wellfield
areas
and the
intermittent/ephemeral streams passing through the license area. A close examination of the map
shows that sediment samples were collected from upstream and downstream locations in all of the
streambeds. In addition to thoroughly sampling the wellfields and water courses, the radiological
baseline was supplemented by including samples from areas within the license area (see sample
sites labeled LAS on the map), the process facility location and the Rn-222/Gamma monitoring
stations. Again, using Regulatory Guide 4.14 for general guidance, all soils and sediments were
analyzed for Ra-226 and a large percentage of the total number of samples included analyses for
U, Pb-210 and Th-230.
In brief, the extensive coverage of the sampling effort provides a
representative radiological baseline against which operational activities can be measured.
6.1.1.2 Sampling Methodology
The sample site map and coordinates described above, guided field personnel to the sample site
locations.
Surface and subsurface soils were collected with a 3-inch diameter bucket auger.
Surface soils were collected from surface to a depth of 6-inches, and subsurface soils were
collected in 12-inch increments to a total depth of 36 inches. The depth increments generally
follow Regulatory Guide 4.14.
To avoid cross-contamination, the sampler and other tools were cleaned after each use using paper
towels and de-ionized water. Samples were placed in 1-gallon plastic freezer bags and stored in
April 2014
ER-I 18
Uranerz Energy Corporation
Jane Dough Unit
ice chests prior to delivery to the laboratory.
While collecting the soil samples, gamma
measurements were taken using a Ludlum Model 19 RiR Survey Meter. While holding the meter
at waist level, the area at and proximate to the sample point was surveyed for approximately two
minutes. Gamma levels were recorded along with the GPS coordinates for each site.
The procedure for collecting sediment samples varied slightly from the soil sampling
methodology. Instead of a single incremental sample, several samples were taken around each site
to form a composite sample. As with the soil samples, sediments were placed in 1-gallon plastic
freezer bags and placed in ice chests prior to delivery to the laboratory. Gamma measurements
were taken following the protocol just described.
6.1.1.3 Results for the Jane Dough Unit
Table ER6-2, Surface Soil Radiological Baseline: Jane Dough Unit provides a summary of the
analyses for each sample point as well as some basic statistical measures (minimum, maximum,
average, and standard deviation).
The average background values are typical for surface soils in the U.S., averaging less than I pCi/g
for Ra-226, Pb-210 and Th-230.
According to (NCRP Report No.78), the average value of
Ra-226 reported in surface soil is 1 pCi/g. The average Ra-226 background at the Jane Dough
Unit is a little lower but similar to a mean of 1.1 pCi/g background reported in a survey covering
33 states. Not surprising, the background at the Jane Dough Unit and in the 33-state survey are
similar to the natural values reported in sandstone (0.71 pCi/g), shale (1.1 pCi/g) and igneous rock
(1.3 pCi/g). Similarly, the uranium values at the Jane Dough Unit comport with typical natural
background soils, which average approximately 2 pCi/g or 3 ppm (du Preez 1989; NCRP 1984a).
Although the single 2.4 pCi/g Ra-226 sample reported at sample site SS- 12 is somewhat above the
average found at the site, it is not outside the natural range of background Ra-226 in soils.
However, it could also be an outlier or a reflection of uranium exploration activity. Although the
2+ mg/kg uranium values at sample sites JD-6, JD-7 and SS-I I are above the average at the site,
these levels are in line with the 3 ppm average for U.S. soils.
One additional comparison,
Table ER6-3 shows that the values reported for the Jane Dough Unit are also in agreement with
April 20/4
ER-I 19
Uranerz Energy Corporation
.
Aine Dough Unit
Table
ER6-2 Depth
Radiological
Background
in Surface
andRa-226
Subsurface
Soil - Jane Dough Unit.
Sample
Uranium
Pb-210
Precision
Precision
Th-230
Precision
Site
(Inches)
(mg/kg*)
(pCilg)
Plus/Minus
(pCi/g)
Plus/Minus
(pCi/g)
Plus/Minus
JD-I
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
1.16
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.4
0.4
0.6
0.2
0.2
0.2
0.8
0.8
0.3
0.3
0.6
0.1
0.7
0.2
1.06
1.0
0.1
1.39
1.0
0.1
0.7
0.2
1.25
0.7
0.1
0.9
0.3
1.04
1.2
0.1
0.5
0.2
2.17
1.2
0.1
0.7
0.2
0.88
1.2
0.1
0.6
0.2
1.16
0.8
0.1
0.06
0.06
0.05
0.04
0.04
0.07
0.06
0.06
0.06
0.06
0.06
0.07
0.04
0.05
0.06
0.06
0.05
0.05
0.06
0.05
0.04
0.06
0.07
0.06
0.06
0.05
0.06
0.05
0.04
0.05
0.05
0.05
0.09
0.03
0.05
0.08
0.06
0.04
0.05
0.05
0.05
0.06
0.06
0.06
0.06
0.05
0.06
0.04
0.04
0.5
0.6
0.6
1.40
0.8
0.7
0.7
0.4
0.4
1.1
0.9
0.9
1.0
0.9
1.0
1.0
0.4
0.6
0.9
0.9
0.6
0.6
0.8
0.7
0.4
0.9
1.1
0.9
0.8
0.6
0.8
0.7
0.5
0.6
0.8
0.8
2.4
0.3
0.5
1.5
0.9
0.6
0.8
0.6
0.7
0.8
0.9
0.7
0.9
0.6
0.8
0.4
0.5
0.2
0.2
1.80
0.69
0.75
2.42
2.32
1.80
1.0
0.6
0.7
0.4
0.3
0.5
1.3
0.6
JD-2
JD-3
JD-4
JD-5
JD-6
JD-7
LAS-1
LAS-2
LAS-3
LAS-4
LAS-5
LAS-6
LAS-7
LAS-8
LAS-9
LAS-10
LAS- Il
LAS-12
LAS- 13
LAS-14
SS-1
SS-2
SS-3
SS-4
SS-5
SS-6
SS-7
SS-8
SS-9
SS-10
SS-11
SS-12
SS-13
SS-14
SS-15
SS-16
SS-17
SS-18
SS-19
SS-20
SS-21
SS-22
SS-23
SS-24
SS-25
SS-26
SS-27
SS-28
April 2014
1.14
ER-120
0.2
Jane Dough Unit
UranerzEnergy Corporation
Table ER6-2 (Cont. )
Sample
Site
SS-29
SS-30
SS-31
SS-32
SS-33
SS-34
SS-35
SS-36
SS-37
SS-38
SS-39
SS-40
SS-41
SB-I**
SB-2**
SB-3**
SB-4**
SB-5**
SB-6**
SB-7**
SB-8**
SB-9**
April 2014
Depth
(Inches)
0-6
0-6
0-6
Uranium
(mg/kg*)
Pb-210
(pCi/g)
Precision
Plus/Minus
1.65
0.5
0.1
1.17
1.2
0.1
1.18
0.96
0.78
0.65
0.3
0.2
0.1
0.1
0.1
0.1
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
1.34
1.30
1.28
1.13
1.09
1.17
1.29
2.15
0.2
0.2
1.0
0.4
0.4
0.5
0.5
0.6
0.8
0.8
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
ER- 121
Ra-226
(pCi/g)
0.9
0.6
0.8
1.1
0.7
0.6
0.6
1.0
0.6
0.8
0.7
0.7
0.7
0.6
0.5
0.4
0.4
0.6
0.6
0.6
0.6
0.7
0.6
0.6
0.7
0.6
1.1
0.6
0.6
0.8
0.9
0.9
1.0
0.8
0.9
0.8
0.8
0.7
0.5
0.6
0.6
0.6
0.8
0.3
0.3
0.6
0.5
0.5
0.6
Precision
Plus/Minus
0.07
0.05
0.06
0.09
0.05
0.05
0.06
0.06
0.05
0.05
0.05
0.05
0.05
0.05
0.04
0.04
0.04
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.07
0.05
0.04
0.05
0.06
0.06
0.06
0.06
0.06
0.05
0.06
0.05
0.05
0.06
0.05
0.05
0.06
0.03
0.03
0.05
0.05
0.05
0.05
Th-230
(pCi/g)
Precision
Plus/Minus
0.5
0.2
0.4
0.2
0.8
0.4
0.3
0.3
0.3
0.5
0.5
0.3
0.5
0.7
0.8
0.6
0.9
0.2
0.2
0.1
0.2
0.2
0.1
0.2
0.2
0.3
0.2
0.3
Uranerz Energy Corporation
Jane Dough Unit
Table ER6-2 (Cont.)
Sample
Site
SB-10**
Uranium
(mg/kg*)
1.20
1.40
1.63
2.18
Pb-210
(pCi/g)
0.4
0.3
0.4
0.5
Precision
Plus/Minus
0.1
0.1
0.1
0.1
1.35
1.65
2.19
4.01
0.6
0.5
0.5
0.9
0.1
0.1
0.1
0.1
Surface Soil:
Minimum
Maximum
Average
Standard Deviation
0.69
2.42
1.37
0.46
0.3
1.3
0.8
0.3
0.3
2.4
0.8
0.3
0.4
0.9
0.6
0.1
Subsurface Soil:
Minimum
Maximum
Average 6-12
Average 12-24
Average 24-36
0.65
4.01
1.30
1.43
2.02
0.2
0.9
0.4
0.5
0.6
0.2
1.1
0.7
0.6
0.6
0.3
0.9
0.5
0.5
0.6
SB-1 1**
SB-12**
SB-13**
Depth
(Inches)
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
Ra-226
(pCi/g)
0.7
0.5
0.2
0.3
0.8
0.8
0.7
0.7
0.8
0.8
0.7
0.7
0.8
0.7
0.7
0.9
Precision
Plus/Minus
0.05
0.05
0.03
0.04
0.06
0.06
0.05
0.06
0.05
0.05
0.05
0.05
0.06
0.05
0.05
0.06
Th-230
(pCi/g)
0.5
0.3
0.4
0.3
Precision
Plus/Minus
0.2
0.2
0.2
0.2
0.6
0.6
0.8
0.7
0.2
0.2
0.2
0.2
*Reporting Limit: 0.02 mg/kg-dry.
**SB- I-SB- 13 are the 0-6 inch surface soil portions collected at the subsurface soil sample sites.
+/-: Plus/Minus Precision.
See Exhibit JD-D 11-2 in Appendix JD-DI I for sample site locations.
Table ER6-3
Average Radiological Background Values.
Radiological Background: Average Values
Mine
Unit
Jane Dough Unit
Hank Unit
Nichols Ranch Unit
Uranium
(mg/kg)
1.37
1.73
1.69
Pb-210
(pCi/g)
0.8
0.4
0.7
ApIl-2014
ERI 22
,4pri12014
ER- 1222
Ra-226
(pCi/g)
0.8
1.0
0.9
Th-230
(pCi/g)
0.6
0.6
0.6
Uranerz Energy Corporation
O
Jane Dough Unit
values previously
thesurface
Nicholssoil
Ranch
and Hank
Units.collected
The averages
presented
in the
summary
table arereported
based onfor156
samples
that were
throughout
the project
area.
Because the averages in all three unit areas are consistent, and because they compare
favorably with averages reported in the literature for surface soils, it can be concluded that the
soils are representative of natural background conditions.
Subsurface soil was sampled at 13 different locations. Two samples were collected from each of
the smaller wellfield areas but the sample number was increased to five for the much larger,
sinuously shaped wellfield in the west-central part of the Jane Dough Unit. Samples were collected
from subsurface intervals of 6-12 inches, 12-24 inches and 24-36 inches.
All samples were
analyzed for Ra-226 and, although Regulatory Guide 4.14 recommends analyzing a single set for
U, Pb-210 and Th-230, five sets (SB-1, SB-4, SB-5, SB-10 and SB-13) were analyzed for the
additional constituents. The sampling approach was designed to obtain Ra-226 values throughout
all of the wellfields and a full set of analyses from each of the five wellfield areas.
S
The results of the sampling effort are summarized in Table ER6-4, and Table ER6-5 provides a
comparison of the values by depth and site location. The subsurface average uranium values of
1.30 mg/kg and 1.43 mg/kg in the 6-12 and 12-24 inch intervals, respectively, are consistent with
the 1.37 mg/kg average reported for the 0-6 inch average in surface soil at the site. However, the
24 to 36 inch interval has an average value of 2.02 mg/kg. This elevated average can be traced to
the contribution of a single high value of 4.01 mg/kg at sample site SB-13. As can be seen from
Table ER6-3, and Table ER6-4, all other values are much lower and in line with the numerous
other values reported across the site. Although it is possible that the 4.01 value is real, it is more
likely an outlier. Assuming it is an outlier, it should not be counted in the average. If it is not used
in calculating the average, the new average would be 1.53 mg/kg for the subsurface interval of
24-36 inches, and this is more consistent with the averages from the other intervals.
With respect to the other radionuclides, all of the averages are tightly grouped and consistent with
typical background. As shown in Table ER6-5, the average values (pCi/g) have the following
ranges: Pb-210 (0.4 to 0.6); Ra-226 (0.6 to 0.7); and Th-230 (0.5 to 0.5). In summary, with the
exception of what appears to be an outlier discussed above, all of the values are consistent and
if
within the range of background expected in U.S. soils.
April 2014
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Uranerz Energy Corporation
Table ER6-4
Sample
Site
SB-l*
S13-2*
S13-3*
S13-4*
S13-5*
SB-6**
SB-7*
SB-8*
S13-9*
SB-10*
SB- 11*
S13-12*
S13-13*
Jane Dough Unit
Subsurface Soils: Radiological Baseline, Jane Dough Unit.
Depth
(Inches)
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
0-6
6-12
12-24
24-36
Uranium
(mg/kg*)
1.18
0.96
0.78
0.65
Pb-2 10
(pCi/g)
0.3
0.2
0.2
0.2
Precision
Plus/Minus
0.1
0.1
0.1
0.1
1.34
1.30
1.28
1.13
1.09
1.17
1.29
2.15
1.0
0.4
0.4
0.5
0.5
0.6
0.8
0.8
0.1
0.1
0.1
0.1
0.I
0.1
0.I
0.1
1.20
1.40
1.63
2.18
0.4
0.3
0.4
0.5
0.1
0.1
0.1
0.1
1.35
1.65
2.19
4.01
0.6
0.5
0.5
0.9
0.1
0.1
0.1
0.1
Ra-226
(pCi/g)
0.6
0.5
0.4
0.4
0.6
0.6
0.6
0.6
0.7
0.6
0.6
0.7
0.6
1.1
0.6
0.6
0.8
0.9
0.9
1.0
0.8
0.9
0.8
0.8
0.7
0.5
0.6
0.6
0.6
0.8
0.3
0.3
0.6
0.5
0.5
0.6
0.7
0.5
0.2
0.3
0.8
0.8
0.7
0.7
0.8
0.8
0.7
0
0.8
0.7
0.7
0.9
Precision
Plus/Minus
0.05
0.04
0.04
0.04
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.07
0.05
0.04
0.05
0.06
0.06
0.06
0.06
0.06
0.05
0.06
0.05
0.05
0.06
0.05
0.05
0.06
0.03
0.03
0.05
0.05
0.05
0.05
0.05
0.05
0.03
0.04
0.06
0.06
0.05
0.06
0.05
0.05
0.05
0.05
0.06
0.05
0.05
0.06
Th-230
(pCi/g)
0.8
0.4
0.3
0.3
Precision
Plus/Minus
0.3
0.2
0.1
0.2
0.5
0.5
0.3
0.5
0.7
0.8
0.6
0.9
0.2
0.2
0.1
0.2
0.2
0.3
0.2
0.3
0.5
0.3
0.4
0.3
0.2
0.2
0.2
0.2
0.6
0.6
0.8
0.7
0.2
0.2
0.2
0.2
*Reporting Limit: 0.02 mg/kg dry.
+/- Precision
See Exhibit JD-DI 1-2 in Appendix JD-DI I in Appendix JD-DI I of the NRC Technical Report for sample site locations.
April
A4pril 2Q14
2014
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Jane Dough Unit
Uranerz Energy Corporation
Table ER6-5
Subsurface Soil Radiological Baseline Comparison by Depth and Sample Site
Jane Dough Unit.
Sample
Site
SB-I
SB-4
SB-5
SB-10
SB-13
Avg.
Uranium
6 to 12"
(mg/kg)
0.96
1.30
1.17
1.40
1.62
1.30
Uranium
12 to 24"
(mg/kg)
0.78
1.28
1.29
1.63
2.19
1.43
Uranium
24 to 36"
(mg/kg)
0.65
1.13
2.15
2.18
4.01
2.02
Pb-210
6 to 12"
(pCi/g)
0.2
0.4
0.6
0.3
0.5
0.4
Pb-210
12 to 24"
(pCi/g)
0.2
0.4
0.8
0.4
0.5
0.5
Pb-210
24 to 36"
(pCi/g)
0.2
0.5
0.8
0.5
0.9
0.6
Sample
Ra-226
6 to 12"
Ra-226
12 to 24"
Ra-226
24 to 36"
Th-230
6 to 12"
Th-230
12 to 24"
Th-230
24 to 36"
Site
(pCi/g)
(pCi/g)
(pCi/g)
(pCi/g)
(pCi/g)
(pCi/g)
0.5
0.6
0.6
1.1
0.9
0.9
0.5
0.8,
0.5
0.5
0.8
0.8
0.7
0.7
0.4
0.6
0.6
0.6
0.9
0.8
0.6
0.3
0.5
0.2
0.7
0.7
0.7
0.6
0.4
0.6
0.7
0.6
1.0
0.8
0.6
0.3
0.6
0.3
0.7
0.7
0.9
0.6
0.4
0.5
0.8
0.3
0.6
0.3
0.3
0.6
0.4
0.8
0.3
0.5
0.9
0.3
0.7
0.5
0.5
0.5
SB-1
SB-2
SB-3
SB-4
SB-5
SB-6
SB-7
SB-8
SB-9
SB-10
SB-I 1
SB-12
SB-13
Avg.
See Exhibit JD-DI 1-2 in Appendix JD-DI I of the NRC Technical Report for sample site locations.
Baseline radionuclides in sediments at the Jane Dough Unit are generally similar to those measured
at the Nichols Ranch and Hank Units. A comparison of the averages at the three sites is provided
in Table ER6-6. With regard to uranium, the averages are closely matched but the slightly higher
average at Jane Dough was influenced by two anomalous values recorded at sample sites SD- 1I
and SD- 16. As shown on Table ER6-7, these two sites have values of 8.93 mg/kg and 9.21 mg/kg,
respectively. Although the Hank Unit did not have any values approaching 9 mg/kg, it had four
values greater than 3 mg/kg, compared to the single 3+ value at Jane Dough. Because of this, the
two averages are not far apart. Similarly, although the Nichols Ranch Unit did not have any values
approaching 9 mg/kg, it had a value over 4 mg/kg and a 2.73 mg/kg value. Also because there are
A4pril 27014
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Uranerz Energy Corporation
Table ER6-6
Jane Dough Unit
Average Sediment Background Radiological Values.
Average Values In Sediments
Sample Location
Jane Dough Unit
Hank Unit
Nichols Ranch
Uranium
Pb-210
Ra-226
Th-230
(mg/kg)
2.60
2.38
2.34
(pCi/g)
1.6
1.0
1.3
(pCi/g)
0.8
1.2
9.6
(pCi/g)
0.6
0.6
0.6
many fewer sample points at the Nichols Unit compared to the Jane Dough Unit (10 vs. 19), the
average at the Nichols Ranch Unit is more strongly influenced by higher values.
With respect to Pb-2 10, the background average exceeds the averages at the Hank and Nichols
Units. The reason for this can be attributed to the number of samples (5 in total) that have values
greater than 2 mg/kg. By comparison, the Hank and Nichols sites each had only one value greater
than 2 mg/kg. It is difficult to say why the frequency of Pb-210 above 2 mg/kg is greater at the
Jane Dough than the Hank and Nichols Units. All three sites share a common history of land use,
which includes exploration and development of shallow coal bed methane and the exploration of
uranium.
April 2014
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Jane Dough Unit
Uranerz Energy Corporation
Table ER6-7 Radiological Baseline in Sediments: Jane Dough Unit.
Sample
Site
SD-I
SD-2
SD-3
SD-4
SD-5
SD-6
SD-7
SD-8
SD-9
SD-10
SD-I I
SD-12
SD-13
SD-14
SD-15
SD-16
SD-17
SD-18
SD-19
Minimum
Maximum
Average
Stdev
Hank Unit
Nichols Ranch
Uranium
(mg/kg)
1.37
1.84
1.57
2.15
1.94
1.51
1.62
1.92
2.77
3.40
8.93
1.20
1.76
1.38
2.10
9.21
1.58
1.49
1.69
Pb-210
(pCi/g)
1.4 +/-0.1
0.8 +/-0.1
1.7 +/-0.1
2.4 +/-0.2
2.1 +/-0.2
1.5 +/-0.1
2.4 +/-0.2
0.7 +/-0.1
1.3 +/-0.1
1.1 +/-0.2
2.0 +/-0.2
0.7 +/-0.I
1.3 +/-0.1
1.6 +/-0.1
0.8 +/-0.1
1.8 +/-0.2
2.8 +/-0.2
1.3 +/-0.1
2.4 +/-0.I
Ra-226
(pCi/g)
0.9 +/-0.06
0.7 +/-0.05
0.8 +/-0.06
0.9 +/-0.06
1.0 +/-0.06
0.7 +/-0.05
0.8 +/-0.05
0.6 +/-0.05
0.6 +/-0.04
0.7 +/-0.05
0.7 +/-0.05
0.5 +/-0.04
0.9 +/-0.06
1.0 +/-0.07
1.1 +/-0.07
0.8 +/-0.05
0.7 +/-0.05
0.7 +/-0.05
1.0 +/-0.07
Th-230
(pCi/g)
0.4 +/-0.2
0.7 +/-0.2
0.5 +/-0.2
0.7 +/-0.2
0.6 +/-0.2
0.6 +/-0.2
0.9 +/-0.3
0.5 +/-0.2
0.7 +/-0.2
0.6 +/-0.2
0.4 +/-0.2
0.7 +/-0.2
0.4 +/-0.2
0.5 +/-0.2
0.6 +/-0.2
0.5 +/-0.2
0.5 +/-0.2
0.5 +/-0.2
0.8 +/-0.3
1.20
9.21
2.60
2.34
2.38
2.34
0.7
2.8
1.6
0.6
1.0
1.3
0.5
1.1
0.8
0.2
1.2
9.6
0.4
0.9
0.6
0.1
0.6
0.6
*Reporting Limit: 0.02 mg/kg-dry.
See Exhibit JD-D 11-2 for sample site locations.
Referring again to Table ER6-2, it can be seen that Ra-226 values at the Jane Dough Unit are very
much in line with values typically reported in the Nichols Ranch and Hank Unit. The values are
for the most part at or below I pCi/g. The average of 0.8 pCi/g for the Jane Dough Unit is just
below the 1.2 pCi/g value measured at the Hank Unit.
As reported in the original license
application, approximately 40% of the Ra-226 values at the Nichols Ranch Unit were in excess of
typical background and therefore a comparison cannot be made with the Jane Dough. Lastly, there
is little to say with regard to the values for Th-230 other than they are normal baseline values for
Jane Dough, Nichols Ranch and Hank Units are all the same (0.6 pCi/g).
April 20/4
ER- 127
Jane Dough Unit
Uranerz Energy Corporation
6.1.2 Baseline Gamma Survey
6.1.2.1 Purpose and Procedure
Baselines serve as a backdrop against which operational impacts can be measured. Baselines also
serve as targets for reclamation goals, which in turn are eventually used for license termination
and site release to unrestricted use. The procedure for establishing gamma background at the
Jane Dough Unit followed the procedure used in the gammas surveys at the Nichols Ranch and
Hank Units.
The survey that was performed for the project site differs in pattern from the survey described in
Regulatory Guide 4.14. The layout of the pattern given in the guide is based on a conventional
mine and mill, which have significant particulate source terms. Because of the vast difference
between ISR and conventional mining and milling, a modified procedure was used to measure
baseline gamma levels in the areas where operational activities will occur. Additionally, the
survey design took into account the fact that the Jane Dough Unit will not have a central or satellite
processing facility and fact that the processing facility at the Nichols Ranch Unit will be limited
to resin loading.
Referring back to the discussion in the soils section, it was noted that potential impacts on soils
and sediments from ISR operations are attributed to accidental spills from pipeline breaks or leaks.
This aspect of potential impact served as a major guide in the baseline sampling pattern for soils,
sediments and gamma. In addition to the large number of gamma readings taken throughout the
proposed wellfield areas at the Jane Dough Unit, readings were also taken at the sediment sampling
locations in the drainages passing through the proposed license area; the air monitoring sites; the
nearest residences; and the vegetation sampling sites. Exhibit JD-D11-2 in Appendix JD-D I1of
the NRC Technical Report shows the gamma sample sites.
6.1.2.2 Survey Methodology
A Ludlum Model 12S RR Survey Meter was the instrument used to collect data during the gamma
survey. The calibration date on the meter for the September 2011 survey was September 2, 2011.
April 201/4
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Uranerz Energy Corporation
dane Dough Unit
As described in the soils section of the application, a sample site map was developed prior to
conducting the survey. Using GPS and the previously-developed sample site map, the survey team
traveled to each sample point. Gamma measurements were recorded by holding the meter at waist
level and slowly passing it over each sample point and over the area proximate to the sample
location. Readings at each site were taken for 2 minutes.
6.1.2.3 Jane Dough Unit Results
Table ER6-8 provides a summary of the gamma measurements. A review of the table shows a
range of 4 jtR/hr (13 to 17 1tR/hr) for the surface soil locations and the same 4 fiR/hr range (14 to
18 !.R/hr) for the sediment sample sites. The high end range for the surface soil locations is
represented only a single reading of 17 jtRihr at LAS-13. Similarly, only two sediment sample
locations support the 18 jiR/hr top range value. Most of the values are within 14 to 16 jtR/hr, and
the averages for the surface soil sites and the sediment locations are 15 and 16 tR/hr, respectively.
The averages at the Jane Dough Unit are a little higher but similar to the 13 ptR/hr average
measured at the Nichols Ranch and Hank Units. The highest values of 16, 17 and 18 ptR/hr at
the Jane Dough Unit were compared to the soil sample sites with the highest uranium, Pb-2 10,
Ra-226 and Th-230 values reported in the soils at those locations to see if a positive correlation
could be established. Not surprising, there was no consistent positive correlation between the
slightly elevated gamma readings and the slightly elevated radionuclides in the soils.
In the previous baseline analysis for the Nichols Ranch Unit, a positive correlation for a few sites
could be made but in those few examples, the level of Ra-226 was much more elevated than the
levels at the Jane Dough Unit.
Gamma measurements taken with a general survey meter cannot establish a high degree of
correspondence with the actual presence of Ra-226 in soil. An instrument of much higher resolving
power (such as a 2x2 sodium iodide Ludlum Model 44-10) would be needed for this purpose.
However, a standard survey meter such as a Ludlum Model 12S can be used in baseline surveys
and as a first-level screening device to detect areas of elevated gamma levels (usually 2.5 to 3 times
background).
April 20/4
ER- 129
Jane Dough Unit
Uranerz Energy Corporation
Table ER6-8
Sample
Site
Random 1*
Random 2*
JD-1
JD-2
JD-3
JD-4
JD-5
JD-6**
JD-7**
LAS-I
LAS-2
LAS-3
LAS-4
LAS-5
LAS-6
LAS-7
SB-I
SB-2
SB-3
SB-4
SB-5
SB-6
SB-7
SB-8
SB-9
SB-10
SB-l1
SB-12
SB-13
Gamma Survey Results: Jane Dough Unit.
Gamma
(pR/hr)
14
16
14
14
16
13
13
I5
15
I5
16
16
14
15
14
14
Sample
Site
LAS-8
LAS-9
LAS-10
LAS-I 1
LAS- 12
LAS- 13
LAS- 14
SS-1
SS-2
SS-3
SS-4
SS-5
SS-6
SS-7
SS-8
SS-9
Gamma
(fiR/hr)
15
15
13
16
14
17
14
14
14
15
15
15
16
15
14
14
Sample
Site
SS-10
SS-11
SS-12
SS-13
SS-14
SS-15
SS-16
SS-17
SS-18
SS-19
SS-20
SS-21
SS-22
SS-23
SS-24
SS-25
Gamma
(ttR/hr)
16
15
16
14
15
15
16
14
14
14
13
14
15
14
15
15
15
15
15
15
15
15
14
15
16
14
15
16
16
SD-I
SD-2
SD-3
SD-4
SD-5
SD-6
SD-7
SD-8
SD-9
SD-10
SD-I 1
SD-12
SD-13
15
14
15
17
15
16
18
15
17
17
16
15
17
SD-14
SD-15
SD-16
SD-17
SD-18
SD-19
....
....
....
....
....
....
....
16
14
14
18
15
16
Average
Minimum
Maximum
Notes:
Sample
Site
SS-26
SS-27
SS-28
SS-29
SS-30
SS-31
SS-32
SS-33
SS-34
SS-35
SS-36
SS-37
SS-38
SS-39
SS-40
SS-41
15
13
17
Gamma
(pR/hr)
15
16
14
13
15
13
14
15
15
16
16
14
15
16
15
15
16
14
18
*Random I and 2 are additional vegetation sample sites.
"*Nearestresidences.
JD-I through 7: gamma exposure rate/air/vegetation sample sites.
SS: Surface Soil Site
SB: Subsurface Soil Site
SD: Sediment Sample Site
LAS: License Area Sample Site
See Exhibit JD-DI 1-2 in Appendix JD-DI I in the NRC Technical Report for sample site locations.
April 2014
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Jane Dough Unit
Uranerz Energy Corporation
In summary, the density of the survey and its consistent values provide reasonable assurance that
a representative baseline was established. Additional evidence supporting the representativeness
of survey are the values from the Nichols Ranch and Hank Units.
6.1.3 Baseline Radon-222 and Direct Gamma Exposure Rates
6.1.3.1 Purpose and Procedure
As described in previous discussions on soil, sediment and gamma baselines, although ISR
operations do not generate significant levels of particulates, they do have Rn-222 emissions, which
include radon daughter products with varying half-lives. For this reason, ambient baseline Rn-222
levels should be established. In establishing the baseline, the monitoring procedure outlined in
Regulatory Guide 4.14 was followed, and it involved deploying Rn-222 detectors and gamma
dosimeters at suggested locations.
6.1.3.2 Survey Methodology
Landauer Extra Sensitive Outdoor Rn-222 Detectors and X-9 Gamma Dosimeters were deployed
at seven monitoring sites (JD-1 through JD-7). Detectors were placed at the two nearest residence
locations (JD-6NR-2 and JD-7NR-1) and the remaining five were located as shown on
Exhibit JD-D1 1-2. The five detectors were located at or near the following locations: (1) the
proposed license boundary; (2) a control site (upwind and removed from operational activities);
and (3) in the prevailing downwind direction.
6.1.3.3 Results for Jane Dough Unit
Monitoring extended over a full year beginning with the third quarter of 2010 and ending in the
second quarter of 2011. The results of the baseline year are summarized in Table ER6-9. A review
of the table shows that the third quarter had the highest average (0.9 pCi/1) and the first quarter had
the lowest average (0.3 pCi/1). It is also interesting to note that five of the seven sites had readings
greater than 1.0 pCi/l during the third quarter while all of the sites had values well below 1.0 pCi/I
April 2014
ER-131
Uranerz Energy Corporation
Table ER6-9
Jane Dough Unit
Baseline Radon-222 at the Jane Dough Unit Air Monitoring Stations.
Third
Quarter
2010
(pCi/l)
Fourth Quarter
2010
(pCi/I)
First
Quarter
2010
(pCi/I)
JD-I
1.0 +/- 0.09
0.6+/-0.05
0.3 +/-0.04
JD-2
JD-3
JD-4
JD-5
JD-6/NR-2*
JD-7/NR- I*
1.2
0.7
0.6
1.0
1.1
1.1
0.5+/-0.05
0.6+/-0.06
0.7+/-0.06
0.6+/-0.05
0.6+/-0.06
0.8+/-0.07
0.3
0.3
0.5
0.4
0.3
0.3
Average
+/-0.10
+/-0.07
+/-0.07
+/-0.09
+/-0.09
+-/0.10
1.0
0.6
+/-0.04
+/-0.04
+/-0.05
+/-0.04
+/-0.04
+/-0.04
Second
Quarter
2010
(pCi/I)
0.6
0.7
0.6
0.4
0.6
0.7
0.5
0.3
+/-0.05
+/-0.06
+/-0.05
+/-0.04
+/-0.05
+/-0.06
+/-0.05
Average
by Site
(pCi/I)
0.6
0.7
0.6
0.6
0.7
0.7
0.7
0.6
Notes: *Nearest residence upwind and downwind.
U.S. average outdoor Rn-222 level: 0.4 pCi/I (U.S. EPA).
See Exhibit JD-D 11-2 in Appendix JD-D] I in the NRC Technical Report for sample site location.
throughout the remaining three quarters. A similar result was recorded at the Nichols Ranch and
Hank Units when baseline surveys were conducted. To illustrate that point, the third quarter
average for all five monitoring locations at the Hank Unit was 1.9 pCi/i and the first quarter average
was 0.6 pCi/l. The profile was repeated again at the Nichols Ranch Unit. The third quarter average
was 1.4 pCi/I and the first quarter had the lowest average of 0.8 pCi/l.
Although the second quarter average at the Nichols site was slightly higher than the third quarter
(1.6 pCi/I vs.l1.4 pCi/I), a sample location in the second quarter had a single high value of 2.3 pCi/I
which raised the average. Because the 2.3 pCi/i number was the only value that exceeded all others
at the time, it may likely have been an outlier. If the value had been more consistent with the
values of 0.6 pCi/I and 1.4 pCi/l that were measured at that location during other quarters, the third
quarter average would have been the highest as it was at the Hank and Jane Dough Units. The
apparent trend of higher values occurring in the third quarter and the lowest values in the first
quarter could likely be the result of weather conditions. The first quarter is quite cold with snow
cover and the third quarter is much warmer and dry. The colder winter months with snow cover
tends to suppress radon exhalation rates while the warmer and drier conditions of summer would
increase the exhalation rate. This explanation is further supported by the fact that highest and
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lowest values are not found at a single site; instead, the highest and lowest values vary with the
time of year.
Table ER6-9 also shows the annualized average for all locations combined as being 0.6 pCi/l. This
average is lower than the averages of 1.0 pCi/l and 1.2 pCi/l recorded at the Hank and Nichols
Ranch Units, respectively. The range of the averages at all three units are consistent with values
found in the U.S. Background radon varies considerable in the U.S. due to factors such as soil and
rock types and the presence of naturally occurring uranium. The 0.6 pCi/l average measured at
the Jane Dough Unit is consistent with but slightly above the U.S. average outdoor Rn-222 level
of 0.4 pCi/I (U.S. EPA).
6.1.3.4 Background Gamma Exoosure Rate
Background gamma exposure rates from the one year monitoring program are summarized in
Table ER6-10. The quarterly averages comprising all seven sites range from 11.3 mrem to
45.8 mrem. When compared to previous baseline surveys at the Ranch Nichols Ranch and Hank
units, the quarterly range average was 34.4 mrem to 55.0 mrem (Hank) and 35.0 mrem to
47.9 mrem (Nichols Ranch). An additional comparison can be made to values from an even earlier
baseline that was developed for the nearby North Butte project. The quarterly averages from North
Butte ranged from 32.3 mrem to 39.7 mrem.
Table ER6-10
Baseline Gamma Exposure Rate at the Jane Dough Unit Air Monitoring Stations.
Third
Quarter
Fourth Quarter
2010
2010
(mrems)
(toreros)
JD-1
34.7
45.0
JD-2
JD-3
38.8
33.9
45.1
46.9
JD-4
JD-5
JD-6/NR-2*
JD-7/N R- I *
30.8
35.0
37.4
36.2
42.7
45.9
49.4
45.7
Average
Nichols
Hank
35.3
39.6
41.5
45.8
35.0
34.4
First
Quarter
2011
(mrems)
44.5
38.0
34.0
34.7
33.0
38.4
38.0
37.2
47.5
55.0
Second
Quarter
2011
(mrems)
11.0
11.3
10.9
11.8
11.5
10.9
11.5
11.3
47.9
50.5
Average
by Site
(rnrems)
33.8
33.0
31.4
30.0
31.4
34.0
32.9
32.4
42.5
45.4
Notes: *Nearest residence upwind and downwind.
Minimum detectable dose equivalent: 0.10 mrem, See Exhibit JD-DI 1-2 in Appendix DI I of the NRC
Technical Report for sample site locations.
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Although there is a good level of consistency between the 3rd, 4th, and 1 st quarters of data from
the Jane Dough Unit, the 2nd quarter is significantly below (approximately 72% lower) the
39.4 mrem average of the other three quarters combined. Also, the spread between the 11.3 mrem
recorded during the second quarter at Jane Dough compared to the values from Hank and Nichols
(50.5 mrem and 47.9 mrem, respectively) exceeds 35 mrems. Because the second quarter values
at Jane Dough appear to be exceeding low, the averages shown on Table ER6- 10 are approximately
7 mrems too low. The -7 mrem estimate was derived by comparing the average for all of the
Jane Dough values from three quarters (39.7 mrem) and comparing this value to the 32.4 mrem
average that includes the second quarter data. The 39.7 mrem value is much more consistent with
the 42.5 to 45.4 mrem average recorded for Nichols Ranch and the Hank Units.
Apart from the comparisons just noted, the average values recorded the three project sites of
approximately 40 to 45 mrem can be put into a better perspective when compared to the following:
•
Average dose to the U.S. Public from natural sources: 300 mrem.
*
Background radiation (total) in the Colorado Plateau: 75 to 140 mrem.
*
Terrestrial background (Rock Mountains): 40 mrem.
•
Average dose to the public from all sources: 360 mrem
As the comparison shows, the average background at the project site is very similar to terrestrial
background (Rock Mountains) of 40 mrem.
6.1.4 Flora and Fauna
6.1.4.1 Purpose and Procedure
According to Section 2.1.4 in Regulatory Guide 4.14, vegetation, food and fish samples should be
collected if, in individual licensing cases, a significant pathway to man is identified. As discussed
previously in this report, pathways for significant radiological contaminants to enter the
environment from current-day ISR operations have been nearly eliminated.
ISR operations do
not have fluid discharges nor do they generate significant particulate emissions. The main avenue
for radiological constituents to enter the environment is limited to the emission of Rn-222.
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Because emissions are restricted to nearly-particulate-free Rn-222, significant buildup of
radionuclides in soil, vegetation and other media is not likely to occur. The minimal accumulation
of radionuclides is supported by MILDOS modeling results, and is borne out in operational
monitoring data that had been collected at various ISR facilities over the past 30 years.
The baseline sampling program for the Jane Dough Unit closely followed the approach used in the
license application for the Nichols Ranch and Hank Units. It will be recalled that the program was
modified from the guidance given in Regulatory Guide 4.14. Departure from the guide is discussed
in the Methods Section below. While developing the pre-operational baseline studies, it was
understood through experience and the evolution of ISR, that pathways to flora and fauna are not
significant.
Even though potential impacts from ISR operations on flora, fauna and the food chain have been
shown to be insignificant, good baseline characterizations continue to be an important and
necessary part of a license application. Baseline values can be compared to values during actual
operations to validate the minimal to no-impact of the project.
Baselines also provide an important background against which post-operational closeout surveys
can be compared for demonstrating that release criteria have been met. Lastly, baseline values are
used when corrective actions are initiated to address an accidental spill.
Following is a description of the baseline sampling program that was performed at the Jane Dough
Unit.
6.1.4.2 Methods
According to the field reconnaissance, no permanent surface water exists at or immediately
adjacent to the site. Given the absence of water, fish are absent. The site was surveyed for the
presence a crop-growing areas and none were found. Agricultural activities appear to be limited
to cattle grazing.
Although the guide suggests sacrificing livestock to obtain samples, it is
Uranerz's opinion that this is not necessary for modem ISR operations. Lacking a pathway for a
source term of sufficient strength, grazing animals are not exposed in a meaningful way. In
addition, since operational monitoring will include routine sampling of vegetation, food crops
(if they are grown in the area) and grazing/forage foods, a mechanism will be in place to monitor
this pathway to local fauna.
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Based on the existing land use, samples were collected from wildlife browsing/grazing areas
(Random-1 and Random-2 sites); the nearest residences (JD-6 and JD-7); and at the
Rn-222/gamma/air monitoring sites (JD-1 through JD-5). Exhibit JD-D 11-2 in Appendix JD- 11
of the NRC Technical Report shows the sample site locations. Samples were collected on
September 29, 2011 and delivered to the laboratory on September 30, 2011. While collecting the
samples, care was taken to clip the vegetation approximately one inch above the ground to avoid
mixing with surface soil. All samples were analyzed for Uranium, Ra-226, Pb-210 and Th-230.
6.1.4.3 Results for the Jane Dough Unit
Table ER6-11 provides a summary of the laboratory analyses.
Although there is the usual
variation, the values are within normal background ranges. To illustrate the consistency in the
background values, a comparison was made with the baseline previously established for the
Nichols Ranch and Hank Units. As can be seen from the Table ER6-12, the averages for all three
sites are in close agreement. A single, somewhat higher Ra-226 value of 3.7E-04 ýICi/kg, which
was collected at sample site R-1 Dry Fork Ranch while developing the Nichols Ranch Unit
baseline explains the higher average Ra-226 level in the table.
Table ER6-11
Sample Site
Radiological Baseline Values in Vegetation: Jane Dough Unit.
Ra-226
Pb-210
Th-230
([tCi/kg)
(pCi/kg)
2.1E-04 +/- 4.7E-06
(pCi/kg)
Uranium
(PCi/kg)
2.7E-05 +/- 3.7E-07*
5.5E-05 +/- 2.OE-07*
JD-2
4.3E-06 +/- 8.9E-07
1.1E-05 +1- I.6E-06
5.8E-04 +/- 8.7E-06
2.1E-06 +/- 3.OE-06
7.4E-06 +/- 4.7E-06
JD-3
JD-4
JD-5
2.4E-05 +/- 2.5E-06
8.4E-06 +/- 1.6E-06
1.OE-05 +1- I.6E-06
7.4E-04 +/- 1.OE-05
4.1 E-04 +/- 8.4E-06
2.1 E-04 +/- 6.7E-06
2.5E-05 +/- 8.9E-06
5.5E-06** +/- 4.7E-06
6.6E-06 +/- 4.5E-06
5.8E-05 +/- 2.OE-07*
5.9E-05 +/- 2.OE-07*
3.4E-05 +/- 2.OE-07*
JD-6
JD-7
6.9E-06 +/- I.4E-06
5.5E-06 +1- I.5E-06
2.4E-04 +/- 7.4E-06
1.9E-04 +/- 8.3E-06
9.4E-06 +/- 6.OE-06
9.1 E-06 +/- 6.8E-06
1.2E-05 +/- 2.OE-07*
5.5E-05 +/- 2.OE-07"
Random-I
Random-2
1.2E-05 +/- 2.OE-06
1.9E-05 +/- 2.3 E-06
9.5E-04 +1- 1.3E-05
6.1 E-04 +/- 1.OE-05
3.8E-05 +/- 8.8E-06
2.4E-05 +/- 6.6E-06
Average
1.0
0.6
0.3
8.2E-05 +/- 2.OE-07*9.7E-05 +/- 2.OE-07*
0.6
JD-1
*Reporting limit.
See Exhibit JD-DI 1-2 of Appendix JD-I I of the NRC Technical Report for sample site locations.
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Table ER6-12 Comparison of Average Baseline Values: Jane Dough, Nichols Ranch and
Hank Units.
Ra-226
Sample Location
Jane Dough Unit
Nichols Ranch
Hank Unit
(pCi/kg)
I. 1E-05
1.9E-04
7.OE-05
Average Values In Sediments
Th-230
Pb-210
(pCi/kg)
4.6E-04
5.4E-04
3.9E-04
(pCi/kg)
1.5E-05
4.I E-05
1.6E-05
Uranium
(pCi/kg)
5.3E-05
1.2E-04
3.2E-05
6.1.5 Radon Flux
Regulatory Guide 4.14 indicates that radon flux measurements should be conducted at eight
locations within 1.5 km of the site. Because there will be no tailings impoundments or evaporation
ponds at the Jane Dough Unit, radon flux is not an applicable radiological parameter for baseline
characterization.
6.1.6 Oualitv Assurance
The quality of data generated for the baseline radiological measurements and monitoring was
managed throughout the effort.
In general, each collection and analysis were controlled and
monitored.
6.1.6.1 Collection
Representativeness was assured by sampling as planned based on applicable regulatory guidance
and expectations, review of prior local and/or regional sampling efforts, expected radiological
patterns or conditions, and adherence to written instruction for sampling or monitoring.
The instrument used to measure exposure rate had a current annual calibration.
6.1.6.2 Analysis
There were no problems with the analyses and all associated quality control data satisfied
laboratory requirements.
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6.1.6.3 Results
The completeness of a data set was evaluated by comparison of valid data to the amount of data
expected to be obtained. The completeness criteria included use of proper analytical methods,
review of quality control data, and approval of laboratory reports. Review of chain's-of-custody
and final laboratory reports confirmed that the proper analytical methods were used during analysis
of samples. Any case of unaccepted or uncertain data is otherwise described previously with
presentation of the results. Each data set was approved by the laboratory.
The comparability of the data sets was also evaluated. Several conditions allow that subsequent
data sets can be compared to the data collected during baseline radiological measurements and
monitoring. These are:
*
The plans for measurements and monitoring provided for collection of representative
samples;
" Sample constituents measured in each sample were reported in the correct units;
" Data quality was confirmed by the laboratory; and
" Results are consistent with results of previous comparable efforts and expected
conditions.
6.2 PHYSIOCHEMICAL GROUNDWATER MONITORING
This section describes the results of baseline regional groundwater quality monitoring conducted
in support of the Jane Dough Unit. The section also addresses the groundwater monitoring
program that would be developed based on information obtained from pre-mining baseline
geologic and hydrologic information, wellfield testing, and wellfield groundwater baseline
sampling.
6.2.1 Groundwater Monitoring
6.2.1.1 Regional Groundwater Monitoring
Regional baseline water quality sampling for the Jane Dough Unit was conducted for a one year
time period with regional water wells sampled once a quarter and analyzed for parameters found
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in Table ER6-13. These parameters are those that are required by the WDEQ in determining
baseline groundwater quality. The results of the regional baseline water quality sampling are
detailed in Addendum D6B of the attached Appendix JD-D6 of the NRC Technical Report.
Additionally, Section 2.7 of the NRC Technical Report summarizes the groundwater quality
information obtained during baseline groundwater sampling.
6.2.1.2 Pre-Operational Wellfield Assessment
The groundwater monitoring program for the Jane Dough Unit would begin with pre-operation
wellfield testing.
These tests are conducted utilizing the baseline geologic and hydrologic
information that was collected and assembled for Jane Dough Unit. Appendix JD-D5 and JD-D6
this application contains the baseline geologic and hydrologic information.
By using the detailed geologic and hydrologic information, monitoring zones can be defined,
geologic and hydrologic parameters quantified, wellfields planned, hydrologic monitoring
programs developed, and baseline water quality sufficiently determined. This information would
then be utilized for prevention and/or detecting excursions of lixiviant outside of the wellfield or
into the underlying or overlying aquifers.
6.2.1.3 Monitor Well Spacing
The density and spacing of monitor wells for the Nichols Ranch Unit and the Hank Unit is
determined during the geologic and hydrologic assessment of a proposed wellfield. Monitor wells
would be installed in the ore zone at a density of one monitoring well per four acres in the proposed
wellfield. These wells would be used to obtain baseline water quality data for the proposed
wellfield to determine groundwater Restoration Target Values (RTV's).
Horizontal monitor wells would also be installed on the edge of the wellfield in the same zone as
the ore zone. This "ring" of wells would be used to obtain baseline water quality data in the area
were determined using a groundwater flow model and estimated hydrologic properties for the
proposed wellfield. This distance also takes into consideration that if an excursion were to occur,
processing fluids could be controlled within 60 days as required by the WDEQ.
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outside of the wellfield and to ensure that recovery solutions do not migrate outside of the ore
zones. UCL's would be determined for these wells from the baseline water quality data that are
collected. The distance between these wells and the wellfield is approximately 500 ft. The
distance from horizontal monitor well to horizontal monitor well is also 500 ft. These distances
Vertical monitor wells would also be installed in the overlying and underlying aquifers at a density
of one underlying and one overlying well per every four acres of wellfield. These wells would be
used to collect baseline water data that would be used to determine UCL's for the overlying and
underlying aquifers. If the immediate overlying or underlying aquifers in the wellfield are nonexistent, or the confining unit (aquitard) is thin (less than five feet in thickness) within the proposed
wellfield or section of the wellfield, then monitor well spacing and density would be determined
in consultation with the regulatory agencies. In the case of the wellfield
2Q14
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Table ER6-13 Groundwater Baseline Water Quality Parameters and Analytical Methods.
Analytical Method
EPA 310.1/310.2
Parameter*
Alkalinity
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
Aluminum
Ammonia Nitrogen as N
Nitrate + Nitrite as N
Barium
Bicarbonate
Boron
Carbonate
Fluoride
EPA 375.1/375.2
EPA 160.1/SM2540C
Sulfate
Total Dissolved Solids (TDS)@ 180°F
EPA 206.3/200.9/200.8
EPA 200.9/200.7/200.8
EPA 200.7/215.1/215.2
Dissolved Arsenic
Dissolved Cadmium
Dissolved Calcium
EPA
EPA
EPA
EPA
Dissolved Chloride
Dissolved Chromium
Total and Dissolved Iron
Dissolved Magnesium
300.0
200.9/200.7/200.8
236.1/200.9/200.7/200.8
200.7/242.1
EPA 200.9/200.7/200.8/243.1/243.2
EPA 200.7/200.8
Dissolved Manganese
Dissolved Molybdenum
EPA 200.7/258.1
EPA 270.3/200.9/200.8
Dissolved Potassium
Dissolved Selenium
Dissolved Sodium
EPA 200.7/273.1
EPA 200.9/200.7/200.8
DOE RP450/EPA 903.1/SM7500-R-AD
SM7500-R-AD
Dissolved Zinc
Radium-226 (pCi/L)
Radium-228 (pCi/L)
DOE RP710/CHEM-TA-GP B I/EPA 900
DOE RP710/CHEM-TA-GP BI/EPA 900
DOE MM 800/EPA 200.8
EPA 286.1/286.2/200.7/200.8
Gross Alpha (pCi/L)
Gross Beta (pCi/L)
Uranium
Vanadium
Zinc
EPA 200.7
EPA 900.0
EPA 900.0
Gross alpha
Gross Beta
* All parameters measured in mg/L unless otherwise denoted.
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200.7
350.1
353.2
200.7
310.1/310.2
212.3/200.7
310.1/310.2
340.1/340.2/340.3
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6.2.1.4 Production Area Pump Test
When a proposed wellfield has been found to be feasible to be mined using the ISR method, the
wellfield becomes a production area. A Production Area Pump Test is then developed to determine
information about the hydrologic characteristics of the production area and the underlying and
overlying aquifers within the production area. The information to be determined during the
Production Area Pump Test includes:
hydrologic characteristics of the ore zone aquifer,
determination of any hydrologic communication between the ore zone aquifer and the overlying
and underlying aquifers, the presence or absence of any hydrologic boundaries in the ore zone
aquifer, determination of the degree of hydrologic communication between the ore zone and the
monitor well ring, and the vertical permeability of the overlying and underlying confining units
that have not already been tested.
Before conducting the Production Area Pump Test, the test plan would be submitted to the Safety
and Environmental Review Panel (SERP) and WDEQ for review and comment.
Standard
Operating Procedures (SOP's) would also be developed that would detail the procedures of the
Production Area Pump Test.
6.2.1.5 Production Area Pump Test Document
After the completion of the Production Area Pump Test field data collection, a Production Area
Pump Test Document would be assembled and submitted to the WDEQ for review. Additionally
the document would be reviewed by the SERP to verify that the results of the production area
hydrologic testing and the planned production area activities are in compliance with NRC technical
requirements. A written evaluation by the SERP would evaluate any safety and environmental
concerns. The evaluation would also address compliance with applicable NRC requirements. The
written evaluation would be located at the Uranerz offices.
Details to be contained in the Production Area Pump Test document are as follows:
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1. A description of the location, extent, etc. of the production area.
2. Map(s) showing the proposed production area (production patterns) and location of all
monitoring wells. This includes the monitor well ring, underlying, overlying, and ore
zone wells.
3. Geologic cross-sections maps.
4. Isopach maps of the ore zone, underlying, and overlying confining units.
5. Discussion on pump test methods including well completion reports.
6. Discussion of the results and conclusions of the production area pump test including
pumping data, drawdown match curves, potentiometric surface maps, water level graphs,
drawdown map, and directional transmissivity data and graphs.
7. Data showing that the monitor well ring and the ore zone are in communication with the
production patterns.
8. Any other information that is pertinent to the production area being tested.
6.2.1.6 Baseline Water Quality Determination
The importance of properly defining the baseline groundwater quality for individual production
areas cannot be overemphasized as the data collected would be used to establish the UCL's and
the restoration target values that would be used in groundwater restoration.
SOP would be
developed that would detail acceptable water quality sampling and handling procedures, as well
as the statistical assessment of the groundwater data.
6.2.1.6.1 Data Collection
Water quality samples would be collected and analyzed from all monitor wells to establish baseline
groundwater quality for the ore zone, ore zone aquifer, underlying aquifer, and the overlying
aquifer. The sampling of the monitor wells would be in accordance to all sampling, preservation,
and analysis procedures. The number of samples collected and the parameters that the samples
would be tested for are as follows:
1. Ore Zone (Production Pattern) Wells (MP Wells) - All ore zone monitoring wells in a
production area would be sampled four times, with a minimum of two weeks between
sampling, during baseline groundwater quality determination. The first and second sampling
events shall be analyzed for all parameters found in WDEQ Guideline No. 8 including uranium
parameters. The third and fourth sample events can be analyzed for a reduced list of
parameters. The parameters that can be deleted from analysis are those that were not detected
during the first and second sampling events.
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2. Ore Zone Monitoring Ring Wells (MR Wells) - Monitoring ring wells would be sampled
four times, with at least two weeks between sampling, during the baseline characterization.
The first monitor well ring sampling would include the analyses for the parameters listed
in WDEQ Guideline No. 8 including uranium parameters. The remaining three samples
would be tested for the potential UCL's parameters chloride, total alkalinity, and
conductivity.
3. Overlying Aquifer Wells (MO Wells) and Underlying Aquifer Wells (MU Wells) - The
overlying and underlying aquifer monitoring wells would be sampled four times with at
least two weeks between sampling events. The first and second sampling events would be
analyzed for the parameters listed in Table ER6-14. The third and fourth sampling events
would be analyzed for the possible UCL parameters chloride, total alkalinity, and
conductivity.
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.
Restoration Target Values Parameters.
Table ER6-14
Parameter
Lower Detection Limit'
Alkalinity
Ammonia
Arsenic
5
0.05
.001
Barium
Bicarbonate
Boron
0.1
5
0.1
0.005
1
Cadmium
Calcium
Carbonate
5
1
Chloride
Chromium
Copper
Electrical [email protected] 25 degrees C
0.05
0.01
Iron
5 uohm
0.1
0.05
Lead
Magnesium
0.001
I
Manganese
0.01
Mercury
Molybdenum
Nickel
0.001
0.1
0.05
Fluoride
Nitrate
pH
Potassium
0.01
0-14 s.u.
1
Radium-226
Radium-228
0.2 pCi/L
I pCi/L
Selenium
0.001
I
Sodium
Sulfate
Total Dissolved Solids
2
10
Uranium
Vanadium
2
0.0003
0.1
Zinc
0.01
Gross Alpha
pCi/L
Gross Beta
pCi/L
mg/L unless specified otherwise
Minimum Detectable Concentrations detennined on a sample by sample basis
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6.2.1.7 Statistical Assessment of Baseline Water Quality Data
Baseline water quality for the overlying, underlying, ore zone, and monitoring ring wells would
be determined by averaging the data collected for each parameter analyzed.
In addition to
calculating the average of the data, the variability of the data would also be calculated. Outliers
would be determined by using the methods outlined in WDEQ Guideline No. 4 or other accepted
methods. Any value determined to be an outlier would not be used in baseline calculations.
Average data from wells that are not uniformly distributed would be calculated by weighting the
data according to the fraction of area, or water volume, represented by the data.
Baseline
conditions would be calculated as follows:
1. Ore Zone Wells (MP Wells) - Baseline water quality would be calculated by using the
average of each parameter that is analyzed. If the data collected shows that water
from the entire production area is that of waters of different underground water
classes, the data then would not be averaged together, but separated into sub-zones.
Data within the sub-zones would then be averaged. The boundaries of the sub-zones,
where required, would be delineated at half-way between the sets of sampled wells
that define the sub-zones.
2. Monitoring Ring Wells (MR Wells) - Baseline water quality would be calculated by
averaging each parameter that is analyzed. As with the ore zone wells, if sub-zones
are present that have different classes of water, data in the sub-zones would be
averaged separately.
3. Overlying and Underlying Aquifer Wells (MO and MU Wells) - The baseline water
quality would be calculated by using the average of each parameter that is analyzed.
6.2.1.8 Restoration Target Values
The RTV's are calculated from the baseline water quality data collected from the ore zone
monitoring wells.
The RTV's are used in determining and assessing the effectiveness of
groundwater restoration within a production area.
Baseline water quality averages for the
parameters sampled for the ore zone wells constitute the RTV's. If sub-zones exist in the ore zone,
the RTV's would be determined for each sub-zone. The Restoration Target Value parameters are
listed in Table ER6-14.
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6.2.1.9 Upper Control Limits
UCL's are used to define excursions at monitoring wells.
Through the installation of the
monitoring ring wells, and the overlying and underlying aquifer monitoring wells, tracking of the
lixiviant and processing fluids can be accomplished to ensure that the fluids are not leaving the
defined ore zone. The process bleed or wellfield purge in combination with the production area
pumping and injection rates assist in keeping all processing fluids within the ore zone.
An excursion occurs when the production area processing fluids reach a monitoring ring or
overlying/underlying monitor well. This would cause the UCL's to be exceeded. If an excursion
is determined to have occurred, operational changes would be implemented to reverse the flow of
the processing fluids so that they are retrieved back to the ore zone and the affected monitor well(s)
is no longer in a excursion status. UCL's for the monitor wells are determined from the collection
of the baseline water quality data. For the Nichols Ranch ISR Project, the parameters to be used
for UCL's would be chloride, conductivity, and total alkalinity.
6.2. 1. 10 Calculation of Upper Control Limits
The UCL's are based on the baseline water quality data and calculated as follows:
1. Chloride UCL - The chloride UCL would be calculated by taking the baseline mean plus
five standard deviations or by taking the baseline mean plus 15 mg/L, whichever is
greater. The chloride UCL would be expressed in mg/L.
2. Total Alkalinity UCL - The total alkalinity UCL would be calculated by taking the
baseline mean plus five standard deviations. The total alkalinity UCL would be
expressed in mg/L CaCO3.
3. Conductivity UCL - The conductivity UCL would be calculated by taking the baseline
mean plus five standard deviations. The conductivity UCL would be expressed in
umhos/cm at 25°C.
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6.2.1.11 Operational Groundwater Monitoring Program
The groundwater in a production area would be monitored during operation to detect and correct
for any condition that could lead to an excursion. Process variables such as flow rates and
operating pressures of each individual operating well would be monitored in addition to the flow
rates and operating pressures of the main pipelines going to and from the plants.
6.2.1.11.1 Monitoring Frequency and Reporting
The ore zone, overlying aquifer, and underlying aquifer monitor wells would be sampled twice per
month at intervals of approximately 2 weeks. The samples would be analyzed for and compared
against the UCL parameters of conductivity, chloride, and total alkalinity. Static water levels
would also be collected and recorded prior to the sampling event (but are not used as an excursion
indicator). All static water levels and analytical monitoring data for the monitoring wells would
be kept by Uranerz and submitted to the WDEQ on a quarterly basis. These data would also be
available to the NRC for review.
6.2.1.11.2 Water Quality Sampling and Analysis Procedures
Water quality samples would be obtained for the monitor wells through permanently installed
submersible pumps. Initially the monitor wells would have three casing volumes discharged
before sampling to ensure that the water in the well is formation water. As operations continue,
the monitor wells would be pumped for a determined amount of time, with a minimum of one
casing volume removed, based on the particular monitor well's performance. Each individual
monitor well would have its static water level recorded prior to pumping. Conductivity, pH, and
temperature would be measured in the field and recorded in periodic intervals prior to sampling.
This is done to demonstrate that the water quality conditions in the monitor wells have stabilized
and that formation water is being sampled. All collected water quality data for each monitor well
would be periodically reviewed to ensure that sampling and analytical procedures are adequate.
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All water quality samples from the monitor wells would be analyzed at the Nichols Ranch Unit
laboratory for chlorides, total alkalinity, and conductivity within 48 hours of the sample being
collected.
All samples would be analyzed in accordance with accepted methods.
Standard
Operating Procedures (SOP's) would be developed that would detail all water sampling and
laboratory analysis procedures.
6.2.1.11.3 Excursions
If any two of the three UCL excursion parameters (chloride, total alkalinity, or conductivity) are
exceeded, an excursion is suspected to have occurred. Within 24 hours of the first analysis, a
second verification sample would be taken and analyzed to determine that two of the three
excursion parameters have been exceeded. The verification sample is then split and analyzed in
duplicate to assess any analytical error. If two of the three UCL's are exceeded, an excursion is
then verified. If the second sample does not exceed the UCL's, then a third sample would be taken
within 48 hours. During an excursion event, all monitoring wells that are placed on excursion
status would be sampled at least every seven days for the UCL parameters.
If an excursion is verified by the second or third sample, the WDEQ and NRC Project Manager
would be notified by telephone or email within 24 hours. The WDEQ and NRC Project Manager
would also be notified in writing within seven days of a verified excursion. Corrective actions
such as changes in the injection and recovery flow rates in the affected area would be implemented
as soon as practical. The corrective actions would continue until the excursion is reversed. A
written report describing the excursion event, corrective actions, and the corrective action results
must also be submitted to the NRC Project Manager within 60 days of the excursion confirmation.
In the event that the concentration of the UCL parameters that were detected in the monitor well(s)
do not begin to decline within 60 days after the verification of an excursion, all injection into the
ore zone (production zone) adjacent to the excursion would be suspended to further increase the
amount of net water withdrawal from the excursion area. Injection would be suspended until such
time that a declining trend in the UCL parameters concentration is established. If a declining trend
is not established in a reasonable time period, additional measures would be implemented. When
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a significant declining trend is established, normal operations would resume with injection and/or
production rates monitored such that net water withdrawals for the excursion area would continue.
The declining trend would be maintained, until the concentrations of excursion parameters in the
affected monitor well(s) have returned to concentrations less than the established UCL's.
6.2.2 Quality Assurance
The quality of data generated for the baseline groundwater quality measurements and monitoring
was managed throughout the effort.
All groundwater sample collection and analysis were
controlled and monitored.
6.2.2.1 Sample Collection
Groundwater baseline sample collection was conducted based on guidance provided by the
Uranerz Groundwater Sampling Procedure and by the WDEQ Guideline No. 8-Hydrology (2014).
These documents detailed the methods to be used in collecting groundwater samples to ensure that
the samples are handled and obtained correctly so that the proper information can be obtained.
6.2.2.2 Sample Analysis
Analysis of the groundwater collected was preformed according to all associated quality control
measures implemented by the laboratory. No issues or problems with the analyses of the data
occurred.
6.2.2.3 Results
The completeness of the groundwater quality data set was evaluated by comparison of valid data
to the amount of data expected to be obtained. The completeness criteria included use of proper
collection and sampling methods, review of quality control data, and approval of laboratory
reports.
Review of chain's-of-custody and final laboratory reports confirmed that the proper
analytical methods were used during analysis of samples. Any case of unaccepted or uncertain
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data is otherwise described previously with presentation of the results. Each data set was approved
by the laboratory.
The comparability of the data sets was also evaluated. Several conditions allow that subsequent
data sets can be compared to the data collected during baseline groundwater quality measurements
and monitoring. These are:
" The plans for measurements and monitoring provided for collection of representative
samples;
* Sample constituents measured in each sample were reported in the correct units;
* Data quality was confirmed by the laboratory; and
* Results are consistent with results of previous comparable efforts and expected
conditions.
6.3 ECOLOGICAL MONITORING
6.3.1 Wildlife
Wildlife monitoring for the Jane Dough Unit would include annual raptor and sage grouse surveys
as required by the WDEQ. Raptor surveys would take place in late April or early May. Sage
grouse surveys would take place at the same time. The purpose of the surveys would be to observe
identified raptor nesting activity within the permit area, observe and count sage grouse activity on
known leks within one mile of the permit boundary, and to observe if any new nests or leks are in
the permit or surrounding one mile area.
Baseline field studies conducted for the Jane Dough Unit found that there is one greater sagegrouse leks within the permit area and three additional leks located within 2.0 mi of the permit
area. Seventy one raptor nests were found within the permit area and a one-half mile buffer of
which seven were determined to be active in 2012. All nests were located in areas that would not
be affected by welifield or associated activities with the Jane Dough Unit. All nests within
0.5 miles of the Jane Dough Unit boundary would be monitored annually for continued activity.
In the unlikely event that it becomes necessary to disturb a raptor nest, a mitigation plan would be
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developed including consultation with the WDEQ, Wyoming Game and Fish, and the U.S. Fish
and Wildlife Service. Any required permits would be obtained from the appropriate agencies.
Appendix JD-D9 attached to this license application provides further detailed discussions on the
sampling methods used in conducting the baseline wildlife surveys and the results of those studies
for the Jane Dough Unit. The locations and activity status of raptor nests in 2012 are provided in
Table JD-D9-4 and illustrated on Exhibit JD-D9-3 in Appendix JD-D9 of the NRC Technical
Report. The results of the baseline sage grouse surveys and historic lek activity data are presented
in Table JD-D9-3. Sage grouse lek locations are illustrated on Exhibit JD-D9-3. Also included in
Appendix JD-D9 is the documentation of contact with all applicable regulatory agencies.
6.4 NO ACTION ALTERNATIVE
No environmental measurements and monitoring programs would be needed if the No Action
Alternative were implemented since no mining would take place.
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7.0 COST BENEFIT ANALYSIS
7.1 GENERAL
Uranium that would be mined at the Jane Dough Unit would be used to replace the uranium
consumed in the production of power from nuclear power plants. The Jane Dough Unit would
also supply a domestic source of uranium that would help alleviate the need of nuclear power plant
operators in the United States to seek uranium supplies from foreign sources. Currently the United
States imports approximately 30 million pounds of uranium from foreign countries while only
producing approximately 5 million pounds per year. The Jane Dough Unit would have the
beneficial effect of helping the United States offset this deficit in domestic production.
In evaluating the benefits of energy produced during reactor licensing, the environmental costs of
the reactor are weighed against the energy produced by including a prorated share of the
environmental costs associated with recovering uranium for fuel. The incremental impacts of
mining uranium for the use in reactor fuel are justified in terms of benefits of energy generation to
society. With that, the benefits and costs of an in situ recovery facility are evaluated in terms of
benefits to the United States and society in general against local environmental costs for which
there may be no directly related compensation.
7.2 QUANTIFIABLE ECONOMIC IMPACTS
The major potential benefits of the Jane Dough Unit include the added income and revenues to
local communities in the area near the project area, the State of Wyoming, and the federal
government through employee income, royalty income, and tax revenues generated by the mining
operation. Some items that may go against these potential benefits involve the incremental costs
and strains on schools, fire and medical response, and other community services for the continued
operation of the Jane Dough Unit as part of the Nichols Ranch ISR Project, but these costs are
relatively small since most of the workforce that would be used for the Jane Dough Unit would
already be employed at the adjacent Nichols Ranch ISR Project. Because of uncertainties in the
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market place and other factors such as counties being able to alter various taxing rates, a numerical
balance between the benefits and costs of any one community, or for the project cannot be arrived.
7.3 ENVIRONMENTAL COSTS
The Jane Dough Unit would basically have three types of environmental costs: 1) radiological
impact, 2) disturbance of the land, and 3) groundwater impact. The radiological impacts of the
project during its operation are minimal since all potential radiological containing materials would
be confined in the process. During reclamation, any remaining solid radioactive wastes would be
disposed of at an NRC licensed facility. This results in no long-term impact at the site from the
radiological materials. The disturbance of the land is also a small environmental impact. All lands
that are disturbed during the life of the project would be reclaimed, and after the project is
decommissioned, would be returned back to the pre-mining use. Groundwater impacted by the
Jane Dough Unit would be restored back to pre-mining conditions such that pre-mining use
suitability of the groundwater is maintained.
7.4 SUMMARY
The overall economic benefits to local communities, the State of Wyoming and the federal
government along with the minimal radiological impacts, surface disturbance, and groundwater
impacts that result from the production of uranium to make nuclear power for the use of the general
public, make the benefit-cost balanced in favor of the development of the Jane Dough Unit.
Additionally, the domestic production of uranium for the use of producing nuclear power helps
the United States reduce its need to import uranium from foreign sources. With this, issuing a
source material license for the Jane Dough Unit is the desired regulatory action.
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8.0 SUMMARY OF ENVIRONMENTAL CONSEQUENCES
The Jane Dough Unit would use the ISR method of mining uranium. The project would be located
in Johnson and Campbell counties, Wyoming, in the Pumpkin Buttes Mining District of the
Powder River Basin. The location of the Jane Dough Unit is located immediately adjacent to
Uranerz Nichols Ranch ISR project. In addition, it is also located near the currently licensed and
operational uranium ISR facility, Uranium One Inc.'s Willow Creek (Christensen Ranch/Irigaray)
ISR project and one area that is licensed and under development (Cameco's North Butte ISR
project).
The ISR mining method environmental impacts are temporary and not significant (NRC 2008).
Information concerning specific resource impacts resulting from the Jane Dough Unit is presented
in Table ER2-1 and will not be repeated here. Impacts to groundwater resources, radiological
doses to workers and the surrounding area, soils, ecology, and land use are small and limited.
Groundwater affected by the recovery facilities would be returned to pre-mining conditions, or if
alternately approved, to its pre-mining class of use standard when completion of a production area
occurs. Radiological doses to workers and the surrounding area (general public) would be below
the regulatory limits in 10 CFR Part 20. Any radioactive (contaminated) waste generated by the
Jane Dough Unit operations would be disposed of in approved methods such as disposal at a
licensed NRC facility or in a deep disposal well.
Land use impacts would be small as only approximately 101 acres would be disturbed during the
life of the project. Measures would be taken to stockpile topsoil in areas where disturbances would
last the life of the project. In areas such as the wellfield, any disturbance to the soils would be
temporary as the soils would be reclaimed and reseeded immediately after any constructions
activities.
Construction activities include pipeline installation, wellfield construction, and
temporary wellfield roads. Final reclamation of the wellfield and site facilities would return the
land affected by the Jane Dough Unit to its pre-mining use of livestock grazing and wildlife habitat.
The total cumulative impacts of the proposed project would not result in a significant impact to
the general public and surrounding areas. Mitigation measures would be put in place to minimize
environmental impacts from the Jane Dough Unit so that upon completion of the project all
groundwater and lands affected by the operation would be returned to their pre-mining condition
or use.
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9.0 REFERENCES
Bureau of Land Management. 2006. BLM Clearinghouse GIS Database. Accessed January, 2006.
Campbell County Assessor.
2014.
Campbell County Mill Levies. 2011-2012.
<<http://www.ccgov.net/assessor/assets/LEVIES 12.pdf>> accessed 3/10/2014.
Campbell County Economic Development Corporation. 2005. Campbell County Housing Needs
Assessment. Gillette, Wyoming.
Campbell County. 2006. Land Use Plan. < http://ww3.ccgov.net/Land%2OUse%20Plan.pdf.>
Accessed January 2005
Cervoski, A.O.., Greinier, B. Oakleaf, L. Van Fleet, and S. Patla. 2004. Atlas of birds,
mammals, reptiles and amphibians in Wyoming. Wyoming Game and Fish Department
Nongame Program, Lander, Wyoming. 206 pp.
Curtis, Jan, and Kate Grimes. 2004. Wyoming Climate Atlas. Office of the Wyoming State
Climatologists, Laramie, Wyoming. <http://www.wrds.uwyo.edu/wrds/wsc/climate atlas
>. Accessed September 2007.
Equality State Almanac. 2006. Prepared by: Economic Analysis Division Department of
Administration and Information State of Wyoming. Cheyenne, Wyoming.
Hantush, M.S., 1960, Modification of the Theory of Leaky Aquifers. Journal of Geophysical
Research, Vol. 65, No. 11, PP. 3713-3725.
Hodson, W.G., R.H. Pearl and S.A. Druse, 1973. Water Resource of the Powder River Basin
and Adjacent Areas, Northeastern Wyoming. U.S.G.S. Hydrologic Atlas HA-465.
Johnson County Planning and Zoning Commission. 2005. Johnson County Comprehensive Land
Planner/Documents/JCLandUsePlanMar05.pdt>. Accessed November 13, 2013.
Knight, D. H. 1994. Mountains and Plains: The Ecology of Wyoming Landscapes.
University Press, New Haven, Connecticut. 338 pp.
Yale
Lowham, H.W., 1976. Techniques for Estimating Flow Characteristics of Wyoming Streams.
U.S.G.S. Water Resource Investigation 76-112.
Martner, Brooks E. 1986. Wyoming Climate Atlas. University of Nebraska Press, Lincoln,
Nebraska.
National Climatic Data Center (NCDS). Relative Frequency Distribution: Gillette, Wyoming,
1996-2005. Climate Services Branch. U.S. Department of Commerce. Asheville, North
Carolina.
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National Council on Radiation Protection and Measurement. 1975.
Background Radiationin the United States. Bethesda, MD.
Report No. 45: Natural
1984a. Report No. 78: Evaluation of Occupational and Environmental Exposures to
Radon and Radon Daughters in the United States. Bethesda, MD.
1984b. Report No. 77: Exposures from the Uranium Series with Emphasis on Radon
and its Daughters.Bethesda., MD.
_
Neuman, S.P. and P.A. Witherspoon, 1972. Field Determination of the Hydraulic Properties of
Leaky Multiple Aquifer Systems. Water Resource. Vol.8, No. 5.
Natrona County Assessor. 2014. Total Assessed Valuations for Natrona County 1990-2012.
<<http://www.natrona.net/index.aspx?NID=328>> accessed 3/10/2014.
Natural Resource Conservation Service. 1988. Technical guide to range sites and range
condition 10-14 inch, Northern Plains. Technical Guide Notice No. WY-99, Section LIB.
Nuclear Regulatory Commission. 1974. Regulatory Guide 1.86 "Termination of Operating
Licenses for Nuclear Reactors" http://pbadupws.nrc.gov/docs/ML0036/ML003676463.pdf
Accessed March 14, 2014.
1980. Regulatory Guide 4.14. Radiological Effluent and Environmental Monitoring at
Uranium Mills. Washington, D.C.
1992. NUREG CR-5849: Manualfor Conducting Radiological Surveys in Support of
License Termination. Oak Ridge Associated Universities. Oak
Ridge, TN.
_
2002. NURER-1569 "Standard Review Plan for In Situ Leach Uranium Extraction
License Applications, NRC, Washington D. C.
_
2003. NUREG-1 748: EnvironmentalReview Guidancefor Licensing Actions Associated
with Nuclear MaterialSafety and Safeguards Programs:Final
Report. Washington,
D.C.
_
. 2008. Generic Environmental Impact Statement for In Situ Leach Uranium Milling
Facilities-Draft Report for Comment (NUREG-1910, Vols. 1-2). www.nrc.gov/readingrm/doc-collections/nuregs/staff/sr 1910/. Accessed January 22, 2009.
Pathfinder Mines Corporation. North Butte ISL Project. Casper, Wyoming 1988.
State of Wyoming Department of Administration and Information, Economic Analysis Division.
2011. Wyoming Sales, Use and lodging Tax Revenue Report. October 2011. Prepared by
Wenlin Lui. Pages 17 and 50. Total Sales Tax Collections by County and Total Tax Use
tax Collections by County.
http://eadiv.state.wy.us/s&utax/ReportFYl 1.pdf.
Accessed 3/10/2014.
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State of Wyoming, Attorney General's Office. 2014. Crime in Wyoming. First, Second and Third
Quarter Reports. Uniform Crime Reporting. Division of Criminal Investigation.
<http://wyomingdci.wyo.giv/files> accessed 3/5/2014.
State of Wyoming Economic Analysis Division. 2010, Equality State Almanac. Prepared by:
Economic Analysis Division, Department of Administration and Information. 14th Edition.
http://eadiv.state.wy.us/almanac/ESA201 0.pdf>> accessed 3/14/2014. Pages 142, 156, and
162.
State of Wyoming, Department of Education. 2014a. 2011-12 Financial Summary by Fund Group
and District Profile for Campbell #1, Statistical Report Series No. 3, Page 78 of 121.
<<http://edu.wyoming.gov/sf-docs/data-information-and-reports/2012-financialsummary-by-fund-district-profile-for-state-of-wy.pdf>> accessed 3/4/2014.
2014b. 2011-12 Financial Summary by Fund Group and District Profile for Johnson #1,
Statistical Report Series No. 3, Page 94 of 121. <<<http://edu.wyoming.gov/sf-docs/datainformation-and-reports/2012-financial-summary-by-fund-district-profile-for-state-ofwy.pdf>>» accessed 3/4/2014.
_
2014c. 2011-12 Financial Summary by Fund Group and District Profile for Natrona #1,
Statistical Report Series No. 3, Page 99 of 121. << http://edu.wyoming.gov/sf-docs/datainformation-and-reports/2012-financial-summary-by-fund-district-profile-for-state-ofwy.pdf">> accessed 3/4/2014.
_
Tipler, P.A. 1991. Physics for scientists and engineers.
Tipler. 1,167 pp. + append.
Third edition.
Published by P.A.
U.S. Bureau of labor Statistics. 2014a. Wyoming Average Weekly Wage 2008-2012. QCEW State
and
County
Map.
<http://beta.bls.cov/maps/cew/WY?period=2013 -Q2&industry=
10&pos_color=blue&negco.>> accessed 3/6/2014.
2014b. Profile of General Population and Housing Characteristics. Campbell County.
factfinder2.census.gov/faces/tableservices/j sf/pages/productview.xhtml?src=
bkmk>>> accesses 3/5/2014.
_
2014c. Profile of General Population and Housing Characteristics. Johnson County.
factfinder2.census.gov/faces/tableservices/j sf/pages/productview.xhtml?src=bkmk>>>
accesses 3/3/2014.
_
2014d. Profile of General Population and Housing Characteristics. Natrona County.
factfinder2.census.gov/faces/tableservices/j sf/pages/productview.xhtml?src=bkmk>>>
accesses 3/5/2014.
_
U.S. Department of Agriculture. 1993. Soil Survey Manual, Handbook 18. U.S. Department of
Agriculture, Government Printing Office, Washington, D.C. 437 pp.
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U.S. Environmental Protection Agency.
1971.
Noise from construction equipment and
operations, building equipment, and home appliances.
Ntid 300.1.
Available at
<http://www.dot.ca.gov/dist 11/115 managed/I- 15/figures/chapter3/3 -23.pdf.>
Accessed
January 23, 2009.
Wyoming Department of Environmental Quality, and Land Quality Division. 1994. Guideline
No. 1; Topsoil and overburden including selenium update. Cheyenne, Wyoming. 43 pp.
1997. Guideline Number 2, Vegetation. Cheyenne, Wyoming. 46 pp.
• 2004. Guideline 2, Vegetation Noncoal. Cheyenne, Wyoming.
2006. Final Adoption of Noncoal Rules. Rule Package 1-V (revegetation performance
standards): Noncoal Rules, Chapter 3. Cheyenne, Wyoming.
2007. Guideline Number 12, Standardized Reclamation Performance Bond Format and
Cost Calculation Methods. Cheyenne, Wyoming.
_
_
2014. Guideline Number 8, Hydrology. Cheyenne, Wyoming. 79 pp.
Wyoming Natural Diversity Database. 2006. Database search and Wyoming Gap Analysis for
the permit area and a one township buffer. Wyoming Natural Diversity Database,
University of Wyoming, Laramie, Wyoming.
Wyle Laboratories. 1971. Community noise. U.S. Environmental Protection Agency Report
No. NTID300.3 203 pp.
Yuan, Y.C., J.H.C. Wang, and A. Zielen. "MILDOS-AREA: An Enhanced Version of MILDOS
for Large-Area Sources." Report ANL/ES-161. Argonne, Illinois: Argonne National
Laboratory, Energy and Environmental Systems Division. 1989. [Code version 2.20p3,
December 1998.]
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10.0 LIST OF PREPARERS
Chapter 10 lists those persons that were involved in the preparation of this NRC Environmental
Report for a source material license for the Jane Dough Unit.
10.1 URANERZ
Uranerz Energy Corporation
1701 East E Street
P.O. Box 50850
Casper, WY 82605-0850
Glenn Catchpole
Bruce Larson
Paul Goranson
Michael Thomas
Glenda Thomas
Doug Hirschman
Dalton Trimm
CEO
Vice President of Exploration and Geology
President and COO
Vice Predident of Regulatory Affairs
Vice President Operation
Vice President Land
Drafter
10.2 TRC ENVIRONMENTAL CORPORATION
TRC Environmental Corporation
605 Skyline Drive
Laramie, WY 82070
Scott Kamber
Jan Hart
Diane Thomas
Nathan Fleming
James Lowe
Rena Merritt
Jessica Robinson
Randall Blake
Betty Wills
Genial DeCastro
Project Manager
Biologist
Biologist
Cultural Program Manager
Associate Program Manager
Document Production Specialist
Technical Editor
GIS Specialist
AutoCAD Specialist
Document Production Supervisor
10.3 CRAIG HOLMES CONSULTING
Craig W. Holmes
8107 Pommel Drive
Austin, TX 78759
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10.4 OMEGA PROJECT SERVICES
Omega Project Services
P. O. Box 1290
Muskogee, OK 74402
Rob Miller
Craig Harlin
Principal and Project Manager
Principal
10.5 HYDRO-ENGINEERING, LLC
Hydro-Engineering, LLC
4685 East Magnolia
Casper, WY 82604
George Hoffman P.E.
Thomas Michaels Ph.D
Hydrologist
Hydrologist
10.6 WILDLIFE RESOURCES, LLC
Wildlife Resources, LLC
Box 247
Bighorn, WY 82833
Duffy Brown
Principal Biologist
10.7 BKS ENVIRONMENTAL ASSOCIATES, INC.
BKS Environmental Associates, Inc.
P.O. Box 3467
Gillette, WY 82718
Brenda Schladweiler Soil Scientist
Soil Scientist
Jamie Eberly
Soil Scientist
Beth McGee
10.8 STRATIGRAPHIC REX, LLC
Stratigraphic Rex, LLC
2210 E. 17th
Casper, WY 82609
Melissa Connely
2014
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10.9 IML AIR SERVICES
IML Air Services
555 Absaraka Street
Sheridan, WY 82801
Shane Hansen meteorologist
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