April 5, 2011

ATTN: Document-Control Desk

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

Subject: Submittal of Responses to Requests for Additional Information (RAI)

TAC L32739.

To Whom it May Concern,

The following document is provided as a response to the US Nuclear Regulatory Commission

RAIs pertaining to the International Isotopes Fluorine Products Inc. December 30, 2009

application to license a depleted uranium hexafluoride de-conversion and fluorine extraction

process facility.

(1) Official Responses Environmental Report RAIs

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

questions regarding this letter or require additional information.

Sincerely,

John J. Miller, CHP

Radiation Safety Officer

JJM-2011-25

Enclosure as Stated

cc: Dr. Matthew Bartlett

U.S. Nuclear Regulatory Commission

Mail Stop E2C40M

6003 Executive Blvd.

Rockville, MD 20852

4137 Commerce Circle, Idaho Falls, Idaho 83401

Phone: 208-524-5300, 800-699-3108 Fax: 208-424-1411

Website: www.intisoid.com
International Isotopes Fluorine Products

International Isotopes Fluorine Products, Inc.

(IIFP)

A Wholly Owned Subsidiary of

International Isotopes, Inc.

Fluorine Extraction Process &

Depleted Uranium De-conversion

Plant (FEP/DUP)

Official Responses to

Environmental Report RAls

Revision A

March 31, 2011
Official Responses to Environmental Report RAls

TABLE OF CONTENTS

RAI Nuim.ber . . .. Nat.ure, of RAI< . , , ..Pag N. ibe.

RAI I Provide description of preconstruction and construction activities and their associated impacts.

1-a Provide definite preconstruction activities. I

1-b Separate preconstruction from construction activities. 7

1-c Provide schedule for preconstruction activities. 11

RAI 2 Provide Phase I and Phase 2 activitieS and impacts separately. -________..._

2-a Confirm Proposed Action consists only of Phase 1. 13

2-b I Provide Phase 1, Phase 2, and cumulative impacts. 18

2-c Describe Phase 2 construction activities. 25

RAI-3 Provide additionalinf6roi h4ý rcgarding d taxes during' construction and operation of 6fhIIIT

3-a Provide descriptions of agreements, abatements, fees-in-lieu-of taxes. 27

3-b Provide more details of incentive package. 28

3-c Provide estimated property tax payments during construction. 29

3-d Identify taxing entities and percentage of payments to entities. 30

3-e Provide estimated property tax payments during operations. 32

RAI 4 Provide clarifications and additional data for the cost-benefit analysis.

4-a Clarify whether replacement capital costs are construction or 33 operations costs.

4-b Provide estimate of distribution of replacement expenditures 34 4-b___ _ over/between Phase 1 and Phase 2 increment.

4-c Provide the cost of raw materials. 35

4-d Provide the utilities cost for Phase 1 and for Phase 2 increment. 36

4-e Provide sufficient data to quantify sales and distribution annual costs 37

for Phase 1 and Phase 2 increment.

4-f Provide breakdown of operations and maintenance costs for Phase 1 38

and Phase 2 increment.

4-g Clarify Phase 1 and Phase 2 increment costs for waste disposal. 39

4-h Provide 2010 market value per pound of each FEP product. 40

RAI 5 Provide clarificat i6onsif d'additional information regarding U0 2 shipments.

5-a Clarify packaging and number of packages per shipment for U02 41

byproduct material.

5-b Provide radionuclide inventory of each package and dose rate. 42

5-c Clarify number of U0 2 shipments. 44

5-d Clarify if each of the 450 shipments contains 20-25 drums of U0 2 per 46 shipment.

5-e Describe the shipment of "miscellaneous LLW" in terms of packages, 47

numbers, and curie content.

RAI 6 Provide the radionuclide inventory of an empty DUF6 cylinder _ _ _

6 1 Provide the activity after emptying cylinder and prior to shipment. I 50

RAI 7 Provide information regarding hydrogengeneration to support the description of the proposed

action.

7-a Describe how hydrogen would be generated. 52

7-b Provide the production capacity of hydrogen plant and the demand 53 _ _ _ for hydrogen. 53

7-c State the hydrogen storage capacity. 54

7-d State if provided natural gas demand includes the H2 generation. 55

Environmental Report Request for Additional Information Page ii
Official Responses to Environmental Report RAIs

RAI Numb I ~)<; Nature ofRAtI~ Vii wae Number

Provide the natural as required for hdrogen generation if necessar

RAI 8 Provide additfonal intformation regarding aire.;5ssions durinh construtiion.:

8-a Provide site-specific assumptions for estimated emissions from off- 56

road construction equipment.

8-b Describe on-site fueling of gasoline and diesel vehicles. 70

8-c Provide air impact analysis for the fuel storage and dispensing 71 activities.

RAI 9 Provide additional information regarding air emissions during operations,

9-a Describe representative capacity of gas-fired boilers and source of 72 data used for boiler emissions.

9-b Describe generators, estimate hours usage, and provide source to 73 estimate emissions.

9-c Describe method to estimate annual emissions by pollutant including 74

model and modeling assumptions.

9-d Provide stack parameter assumptions. 76

9-e Provide the 5-years of hourly data from Midland-Odessa station. 79

RAI 10 Provide additional information reg~arding accident analyses.

10 Describe the release rates required to exceed consequence levels. 84

RAI 11 Provide additional information regarding groundwater.

I11-a Provide information about existing groundwater monitoring well 86

network and indicate establishment of baseline quality assessment.

I l-b Describe proposed site groundwater monitoring well network. 90

11-c Describe proposed groundwater production wells. 96

-RAI 12 Provide copies of IIFP Site land surveys. , ....

12 Information is necessary to provide a centroid for demography, 97

environmental justice, air impacts, etc.

RAI 13 PProvide additional information regardiný :mployment.

13-a Provide employment curve so peak employees/dates can be 98 determined.

13-b Provide annualized wage (gross payments to employee not to include 103

benefits) for Phase 1 construction.

13-c Include employment curve for Phase I operations overlapping with 104 Phase 1 construction.

13-d Estimate peak workforce (no range) for Phase 2 construction with 105

start date, duration - employment curve.

13-e Provide annualize wage (no benefits) for average Phase 2 106 construction employee.

13-f Provide date line and workforce numbers for Phase 2 operations 107

employment curve overlapping with Phase 2 construction.

RAI 14 Provide reports of ecological field sttidies .

14 Provide reports from surveys or quarterly summaries. 108

RAI 15 Provide rationale that jurisdictional wetlands are/are not present within 40-acre facility.

15 IIFP may submit determination. 113

RAI 16 Provide additional information regarding ambient noise level monitoring results.

16 IIFP is conducting noise level reading at the corners of the site. 120

RAI 17 ClarifQstatus and/or schedule of variou state permits.

17 Required permits and schedule in Table 1-4 is to be updated. 121

Environmental Report Request for Additional Information Page iii
Official Responses to Environmental Report RAIs

RIu g Natuure of RAI .... Pa e Nmbe•r n 

RAI 18 Provide status of radiological moniioring plan

18 Provide updates to Section 6.1 of ER. 132

RAI 19 Provide full citations of references listed in Section 3.5 not listed in reference chapter.

19 Provide either reference or the complete citation. 134

RAI 20 Provide additional informationon construction wastes and operations wastes.

20-a Provide estimated quantities for Phase 1 and Phase 2 construction. 137

20-b Clarify total Phase 1 and Phase 2 RCRA operations waste. 141

RAI 21 Provide additional inf0foratioiirnegarding'past land use of projectiarea.

21-a Provide information collected on non-developmental human use such 142

as cattle grazing.

21-b Provide available information concerning previous oil/gas wells, right 148 of way, etc.

RAI 22 Provide Support for ERclaim of bett•erthan indu'stry average for occupational safety statistics.

22 Provide last 5 years of OSHA reports for IIFP Facility doing 151

comparable work.

RAI 23 Provide clarifications fonmitigation measures.

23 Separate mitigation measures into construction and operations phases. 153

RAI 24 Verify the distance to the nearest residence from IIFP property.

24 Nearest residence is approximately 1 mi from NW corner. 157

Non-Radiological Emissions and Impacts for Phase I and Phase 2 16

Attachment I .Construction Activities

Environmental Report Request for Additional Information Page iv
Official Responses to Environmental Report RAIs

RAI I

Provide a description ofpreconstruction and construction activities and their associated impacts.

a. Provide definite preconstruction activities within each pertinent section of the Environmental

Report (ER). The ER mentions only potential preconstruction activities (e.g., Section 2.1.2, "Site

Construction "provides a list of potential preconstruction activities).

This information is needed to assess the effects of construction and to develop the cumulative effects

analysis within the Environmental Impact Statement (EIS). Cumulative effects include past, present, and

reasonably foreseeable future actions. Impacts from preconstruction activities will be evaluated in the

cumulative effects analysis along with those of the proposed action and any other past, present, and

reasonably foreseeable future actions. Therefore, it is necessary that these preconstruction activities and

their impacts be clearly distinguished throughout the ER from the construction activities that are

considered part of the proposed action.

RESPONSE:

The listing of the potential preconstruction activities in Section 2.1.2 has been deleted with descriptions of

the preconstruction activities added in Sections 2.1.2.1 through 2.1.2.16. In the environmental assessment,

the preconstruction activities were assessed collectively unless specifically mentioned within the pertinent

environmental resource sections. See the Environmental Report Documentation Impact for RAI 2.b

Environmental Report Documentation Impact: The listing of potential preconstruction activities will

be deleted in the 2nd paragraph of Section 2.1.2. The 3 d paragraph will be revised to reflect the collective

assessment of all the preconstruction activities in each pertinent environmental resource. The 4 th and 5th

paragraphs will be revised to reflect the various construction stages. Descriptions of preconstruction

activities will be added to the Environmental Report Section 2.1.2 after the I Ith paragraph. Section 2.1.2

will be revised to read as follows:

2.1.2 Site Construction

The Proposed License Action construction and startup schedules are provided in the ER Chapter 1.

Construction of the Phase I facility is expected to begin in 2012 and startup of operations in 2013. IIFP is

proposing to request an exemption from NRC to conduct some pre-license preparatory type construction

(preconstruction) activities that are planned to start in 2011. The pre li-eensing construction proposeds

activities only affect the timing of work and will not increase the scope or environmental impact of

facility construction. Potential pre licensing.ostr....tion activities may inlde; the f.llewing:

Clearing land,

Site gr-adiing and ei-osion contýrol

finstalling mail enti-ance roeadbed and drainage to highwayl

histalling enutiuction trailer-.

Prfeparing pr-eliminar~y site roadways and grfavel parking ar~ea.

potenitial Irilling fwater wells.

Gonstruefing pewi substation-,

stbibbing in gas. line to the mewter-,

Begiinning a Imifnitiration building construction,

Environmental Report Request for Additional Information (RAI 1) Page 1
Official Responses to Environmental Report RAIs

Beginning wvarvehuse building constiuction,

In1stalling geather-mal haigcoiglos n

installing fir-ewater tanks.

Throughout this ER, where applicable, pre-lieeese construction is considered collectively in evaluating

the environmental impacts for each pertinent section. In each environmental resource. preconstruction

activities aind isare determined to have a "SMALL" impact in each of the impact areas evaluated excep

for Ecological Resource where the impact to wildlife will be MODERATE during preconstruction

activities.

Construction will occur in thfee-four-phasesstaes. The first stage will involve certain pre-licensing

construction tasks allowed under 10 CFR 40.32(e). The first-second phase-stage will involve certain pre-

.ieen. ng- construction tasks based on NRC approval of the exemption request. The activities will be

preparatory in nature and will not involve any process or safety related equipment or systems. Required

permits will be obtained prior to the start of preconstruction, and pre-operational baseline environmental

samples will be collected. In addition, geotechnical investigations will be conducted prior to construction

of roadways, buildings, and water retention systems. Specifically, Aa NPDES Spill Prevention Control

Countermeasures Plan and an NPDES Constr-uctiOn St0F'4water Permit with thle COe'al ConBti'uction

Permit will be completed prior to the implementation of pre -44ense-construction activities.

The third construction stage will begin Aafter NRC approval of the license._. gener'al c-ns;truction will

begin and This stage will complete any unfinished pre -ieen;ing construction activities, including

buildings, completion of roads and pads, and installation of systems and equipment, will ,be 6..T.Pe!e.

and will involve the remaining construction through completion f4oa-of the Phase I WFacility. The hif4

fourth construction phase-sage is expected to begin in 2015 and will complete the Phase 2 Ffacility to add

additional DUF 6 de-conversion capacity.

The Hobbs, New Mexico site characteristics are such that it will not likely need major earth grading or

movement. Excavation is required for sewer systems, roads, pads, building foundations and floors, etc.

During construction-phases of the IIFP Site, conventional earthmoving and grading equipment will be

used. The removal of very dense soil (caliche) may require the use of heavy equipment with ripping tools.

Soil removal work for foundations will be controlled to minimize excavation. In addition, loose soil

and/or damaged caliche will be removed prior to installation of foundations for seismically designed

structures. Less than 10% of the total 640-Section area will be disturbed.

The IIFP F14acility will require the installation of water, natural gas, and electrical utility lines. It is

expected that some of these utilities will be installed during the pre licensing construction period.

On-site wells will be utilized to supply potable water, process makeup water, and fire water. The site is

over the Ogallala Aquifer. There are several existing monitoring and production wells for the surrounding

utility companies on the site th.at will be investigated for- .se in lieu of installing new wells.

The natural gas line feeding the site will connect to an existing, nearby line. This will minimize impacts

of short-term disturbances related to the placement of the tie-in line.

A new electrical transmission line is proposed for providing electrical service to the IIFP Ffacility. There

are currently 115 and 230 kV transmission lines along U.S. Highway 62/180 (U.S. 62/180) and New

Environmental Report Request for Additional Information (RAI 1) Page 2
Official Responses to Environmental Report RAIs

Mexico Highway 483 (NM 483). in conjunction with the new electrical lines serving the site, the local

electrical utility company will install an independent substation to ensure service.

Descriptions of the preconstruction activities are provided in Sections 2.1.2.1 through 2.1.2.16.

2.1.2.1 Site Clearing 16.2 Hectares (40 Acres)

The area of clearing will include locations of buildings, process structures, storage pads and roads.

Clearing encompasses an area approximately 244 in x 305 m (800 ft x 1.000 ft) inside the 16.2 ha (40-ac)

facility site. The work will include the removal of any brush, small vegetation and some topsoil.

2.1.2.2 Pre-construction Erosion and Stormwater Run-off Control

Temporary silt fencing and sediment straw bales will be installed around the areas of construction to

entrap silt and to prevent its migration off site. Drainage trenches and ditch checks will be installed alonh

the entrance road to prevent run-off and silt from the site onto NM 483 right-of-wvay. Site sloping, earth

berms, underground drainage pipe, and wet sediment retention basins will be installed to entrap storm

water run-off from construction areas.

2.1.2.3 Installation of Truck Washing Station

A truck wash-off station or portable unit will be installed prior to the intersection of the entrance road with NM 483

to minimize silt carryover onto the public right-of-way.

2.1.2.4 Site Grading and Erosion Control/Sedimentation Retention for Buildings, Process

Structures, Storage Pads and Roads

Conventional earthmoving and grading equipment will be used to remove most soil for site leveling and

for digghing foundations and footings for buildings, process structures and storage pads. Very dense soil

(caliche) removal may require the use of heavy equipment with ripping tools. Excavation for foundations

will be minimized. In addition, loose soil and/or damaged caliche will be removed prior to installation of

foundations for seismically designed structures. Less than 10% of the total 259-ha (640-ac) area will be

disturbed. Silt fences and straw bales will be used to control erosion and to protect undisturbed areas.

Temporary sedimentation basins will also be installed to control stormwater runoff.

2.1.2.5 Main Entrance Roadbed with Drainage to 16.2-ha (40-ac) Site

The entrance to the facility is from the west via a paved road [approximately 899 m (2,950 fi)] that

intersects with NM 483. The road connects with the facility road system at the main gate and guard

station. Adiacent to the main gate area and to the north is the paved and striped employee and visitor

parking lot.

The main entrance roadbed, with compacted gravel base course and drainage, will be constructed from

NM 483 to the 16.2-ha (40-ac) facility site main gate location. The roadbed. approximately 6.1 m x 899 m

(20 ft wide x 2.950 ft long), will remain through construction without a wearing coat (asphalt). Before

facility start-up, the asphalt wearing coat will be installed to provide a finished main entrance road.

Environmental Report Request for Additional Information (RAI 1) Page 3
Official Responses to Environmental Report RAIs

2.1.2.6 Construction/Office Trailer Installation

A construction/office trailer containing offices for engineers and construction supervisory personnel will

be installed at a strategic location inside the 16.2-ha (40-ac) facility site. Since no sanitary waste disposal

equipment will be in place during construction, the construction trailer will not maintain any functional

toilet facilities. Portable sanitary facilities will be stationed in locations convenient to construction areas.

The construction trailer will require temporary 115/230 volt. single phase power.

2.1.2.7 Electrical Substation Installation

A new electrical substation will be installed by the utility company to provide electrical service to the

IIFP Facility. It is expected that this substation will be installed on the IIFP facility site and will be

enclosed inside a secure chain link fence. It is also expected that new poles and hiph-voltage lines will be

installed firom existing high-voltage transmission lines along NM 483 to the substation.

2.1.2.8 Gas Main Installation to 16.2 ha (40 ac) Site

A new natural gas service line will be installed by the utility company to the 16.2-ha (40-ac) IRFP site.

The service line will be connected to a metering loop containing valves, regulators. safety valves,

isolation valves, check valves and fiacility-wide main meter. Gas piping from the metering loop will not

be installed until NRC license approval is granted.

2.1.2.9 Administrative Building Shell Construction

The Administrative Building, houses the offices of personnel not directly involved in the production and

maintenance functions of the facility. This building is accessed directly through the front door friom the

parking lot. The rear portion of this building is the Change/Locker Area with toilet facilities, showers and

lockers. The main employee entrance and boundary control area are located on the west side of the

Change/Locker Area. A turn-style and access controls are located at the security fence permitting

employee entrance into the controlled area.

Upon completion of Architectural and Engineering design drawings, and upon approval of same by all

authorities having iurisdiction. construction of the Administrative Building (shell only) will commence.

The building foundations, footings, floor slab and under-slab utilities will be installed first. Foundation

and footing design will be based upon the results of the soil analysis evaluation.

The Administrative Building shell will be a pre-engineered steel building with approximate dimensions of

24.4 in x 15.3 ni (80 ft lonp, x 50 ft wide) with eave height of 4.6 in (15 ft). The preconstruction building

will include the following: insulated exterior walls, insulated sloped standing seam metal roof. reinforced

concrete floor slab on grade, temporary lighting for construction, guttering. downspouts. interior metal

studs for partition walls, door frames, windows, anchor bolts. thsteners, etc.

The building shell will be constructed to provide for future interior finishes of tile and/or carpet flooring,

painted sheetrock. wall covering, 0.6 in x 1.2 in (2 ft x 4 ft) acoustical suspended ceiling tile system with

lay-in type lighting fixtures and geo-thernial heat pump heating and cooling systems.

Environmental Report Request for Additional Information (RAI 1) Page 4
Official Responses to Environmental Report RAIs

2.1.2.10 Maintenance and Stores Building Shell Construction

The Maintenance and Stores Building is located southeast of the Fluoride Products Trailer Loading

Building,. This building contains small tools, machines, repair equipment. and maintenance supplies such

as pipe and fittings, hardware, electrical parts and other small items required for maintenance of the

facility. No raw, licensed, or in-process materials or finished products are stored in this building. An

office area is provided for maintenance supervision and stores personnel.

Upon completion of Architectural and Engineering design drawings, and upon approval of same by all

authorities having iurisdiction. construction of the Maintenance and Stores Building (shell only) will

commence. The building foundations, footings floor slab and under-slab utilities will be installed first.

Foundation and footing, design will be based upon the results of tile soil analysis evaluation.

The Maintenance and Stores Building shell will be a pre-engineered steel building with approximate

dimensions of 18.3 ni x 15.3 m (60 ft long x 50 ft wide) with eave height of 4.6 m (15 fi). The

preconstruction building will include the following: insulated exterior walls, insulated sloped standing

seam metal root. reinforced concrete slab floor, temporary lighting for construction. guttering,

downspouts, interior metal studs for office and toilet partition walls, door firames, windows, anchor bolts,

fasteners, etc.

The building shell will be constructed to provide for future interior finishes in office and toilet areas of

tile flooring, painted sheetrock wall covering, 0.6 in x 1.2 mi (2 ft x 4 ft) acoustical suspended ceiling tile

system with lay-in type lighting fixtures.

2.1.2.11 Material Warehouse Building Shell Construction

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

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

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

oils, and cleaning agents are stored in the warehouse, but the quantities are limited to meet New Mexico

Commercial Building Code (NMCBC) and National Fire Protection Association (NFPA) requirements.

No licensed, raw, or in-process materials or finished products are stored in this building.

Upon completion of Architectural and Engineering design drawings, and upon approval of same by all

authorities having iurisdiction, construction of the Material Warehouse (shell only) will commence. The

building foundations, footings. floor slab and under-slab utilities will be installed first. Foundation and

footing design will be based upon the results of the soil analysis evaluation.

The Material Warehouse Building shell will be a pre-engineered steel building with approximate

dimensions of 30.5 m x 15.3 in (100 ft long4 x 50 ft) wide with eave height of 5.5 m (18 ft). The

preconstruction building will include the following: insulated exterior walls, insulated sloped standing

seam metal roof. reinforced concrete slab floor, temporary lighting for construction, guttering.

downspouts, interior metal studs for office and toilet partition walls, door friames, windows, anchor bolts,

fasteners, etc.

The building shell will be constructed to provide for future interior finishes in office and toilet areas of

tile flooring, painted sheetrock wall covering, 0.6 in x 1.2 in (2 ft x 4 ft) acoustical suspended ceiling tile

system with lay-in type lighting fixtures.

Environmental Report Request for Additional Information (RAI 1) Page 5
Official Responses to Environmental Report RAIs

2.1.2.12 Temporary Fencinit

Temporary chain-link fencing with locking gates will be installed around the Construction/Office Trailer

and around each building shell for protection from vandalism.

2.1.2.13 Facility Site Roadbeds and Gravel Parkingi, Areas for Construction

The inside-facility road begins at the main security gate and continues in an easterly direction where it

divides into an intersection with two access roads, one heading north and the other heading south. These

roads sunround the process areas of the facility and eventually meet to form a loop, thereby allowing

access around the facility in either direction. The loop formed by the road is approximately 213 m x 122

m F700 ft lon~g (north to south) x 400 ft wide (east to west)]. For descriptive purposes, the four sections of

the road loop are called the North, South, East and West Roads, so named by their proximities to the

North, South, East and West boundaries of the 16.2-ha (40-ac) facility site. Just north of the main gate

location is the employee and visitor parking lot.

The roadbed and base course will be installed for the North, South, East and West Roads and for the

parking lot. No asphalt wearing course will be installed on facilit, roads or the parking lot until

construction of the IIFP Facility is essentially complete.

2.1.2.14 Water Well Drilling

On-site wells will be utilized to supply potable water. process makeup water, and fire water. The site is

over the Ogallala Aquifer. Two wells will be required to satisfy facility water requirements. These wells

will be installed and capped at the wellheads for connections to the facility water distribution systems

after NR.C License approval. Lea County intends to drill a 350 gallon per minute well on the 640 acre site

prior to transferring titlevof the land over to UIFP.

2.1.2.15 Geothermal Heat Pump Loop Installation

Administrative, stores, process offices, laboratory, guard station and other high occupancy areas are

heated and cooled by ground water source (geothermal) heat pump systems. The current concept is to

design, select and install two horizontal, ground water source loop systems close to consumers.

A total capacity of 60 tons 1720.000 British Thermal Units/Hour (BTUH)] is estimated for the buildings

identified and currently sized in the facility concept. Actual sizing, selection and engineering of the

system will be performed during detailed design.

The installation of only the ground water source heat pump loops is requested under this Exemption.

Loops will be installed in trenches below grade and will be brought above grade and capped for

connection to heating and cooling equipment after NRC .icense approval.

2.1.2.16 Firewater Tank Installation

Just east of the East Road are located two above-ground Fire Water Tanks 1379 m1 (100,000 gal

and the Fire Pump [louse. The Fire Pump Hlouse contains the main fire water pump, the back-up diesel

fire water pump, Jockey pump, piping and controls. The HIFP facility fire protection system is described in

Chapter 7. "Fire Safety," of the License Application, including the classification of individual buildings

as per the NMCBC and NFPA 13 (NFPA, latest edition).

Environmental Report Request for Additional Information (RAI 1) Page 6
Official Responses to Environmental Report RAIs

The installation of the two Fire Water Tanks will be requested under an Exemption. After tank structure

and footings and IbUndations are designed, based Upon soil core sample analysis, and approvals are

obtained from all authorities having iurisdiction, the installation of the tank footings and foundations will

begin, The footings, foundations and tank design and construction will meet all codes governing the

installation of fire water tanks in the State of New Mexico.

Environmental Report Request for Additional Information (RAI 1) Page 7
Official Responses to Environmental Report RAls

RAI I

Provide a description ofpreconstruction and construction activities and their associated impacts.

b. Separate preconstruction from construction activities in the ER. For example, in Section 4.10. ],

"Facility Construction, "separate the preconstruction from the construction workforce. Another

example, in Section 4.6.1, "Air Quality Impacts from Construction, "including Tables 4-11 and 4-

12, separate respectively the "air quality impacts and emission rates" and "predicted propertyboundary air concentrations" into preconstruction and construction). Topics that need revision

include, but may not be limited to: waste streams, employment information, activity durations, air

emissions, economic information, transportation information, and water/usage/discharge

information.

This information is needed to assess the effects of construction and to develop the cumulative effects

analysis within the Environmental Impact Statement (EIS). Cumulative effects include past, present, and

reasonably foreseeable future actions. Impacts from preconstruction activities will be evaluated in the

cumulative effects analysis along with those of the proposed action and any other past, present, and

reasonably foreseeable future actions. Therefore, it is necessary that these preconstruction activities and

their impacts be clearly distinguished throughout the ER from the construction activities that are

considered part of the proposed action.

RESPONSE: Impact analyses of construction activities have been conducted for both the

preconstruction and the construction stages of the IIFP Facility. In addition to the examples provided

above, impact analyses have been performed for each of the resources described in Chapter 3. These

analyses and the predicted impacts are described for land use (Section 4.1); transportation (Section 4.2);

geology and soils (Section 4.3); water resources (Section 4.4); ecology (Section 4.5); meteorology,

climatology, and air quality (Section 4.6); noise (Section 4.7); historical and cultural resources (Section

4.8); visual/scenic resources (Section 4.9); socioeconomic (Section 4.10); public and occupational health

(Section 4.12); and waste management (Section 4.13). Analyses and predicted impacts regarding

environmental justice also are presented (Section 4.11). Revisions to these sections are provided in the

Environmental Report Documentation Impact for RAI 2.b.

Section 2.6 will be revised to summarize these environmental impacts mainly through a new table to be

added to show the environmental impact for preconstruction, Phase I Facility construction, Phase 2

Facility construction, Phase 1 Facility operation, Phase 2 Facility operation, decommissioning, and

cumulative effects. Descriptions of these environment impacts are provided in Chapter 4, with the

revisions to each environmental resource shown in the Environmental Report Documentation Impact to

RAI 2.b.

Environmental Report Documentation Impact: Section 2.6, "Cumulative Effects," will be revised to

include a summary of environmental impacts. The new Section 2.6 will be re-titled, "Environmental

Impacts and Cumulative Effects of the Proposed License Action and the Phase 2 Facility." Section 2.6

will be revised to add two new paragraphs before the initial (old Ist) paragraph to introduce the impact

analysis for all the phases of the IIFP Facility to include preconstruction, Phase I Facility and Phase 2

Facility construction; Phase I Facility and Phase 2 Facility (Phase I plus a future expansion) operation;

and decommissioning as well as cumulative impacts. The old 3 d paragraph will be revised to show the

extent of impacts considering all lifecycle phases from the IIFP Facility. A new paragraph after the old 3 rd

paragraph will be added to introduce a new Table 2-7 which summarizes the environmental impacts for

each of various phases of the IIFP Facility (preconstruction, Phase I and Phase 2 construction; Phase I

and Phase 2 operation; and decommissioning). Section 2.6 will be revised to read as follows:

Environmental Report Request for Additional Information (RAI 1) Page 8
Official Responses to Environmental Report RAIs

2.6 Environmental Impacts and Cumulative Effects of the Proposed IAcense Action and the

Phase 2 Facility

Impact analyses have been performed for each of the resources described in Chapter 3, "Description of

the Affected Environment." These analyses and the predicted impacts are described for land use (Section

4.1 ): transportation (Section 4.2); geology and soils (Section 4.3); water resources (Section 4.4): ecology

(Section 4.5): meteorology, climatology, and air quality (Section 4.6): noise (Section 4.7); historical and

cultural resources (Section 4.8): visual/scenic resources (Section 4.9); socioeconomic (Section 4.10):

public and occupational health (Section 4.12): and waste management (Section 4.13). Analyses and

predicted impacts regarding environmental iustice also are presented (Section 4.11).

As presented in Chapter 4, these impact analyses have been performed for the various stages of the

construction and operation of the IIFP Facility (preconstruction, Phase I Facility and Phase 2 Facility

construction. Phase I Facility and Phase 2 Facility operation and decommissioning). Additionally, the

impacts were also assessed for the Alternative Actions. A discussion of cumulative impacts also is

presented for each of the thirteen ( 13) chapter sections. Direct and indirect impacts for the Phase 1/Phase

2 Facility were assessed for normal operational events. Accident analyses were performed for potential

on-site accidents as part of the Integrated Safety Analysis (ISA) and documented in the ISA Summary for

the Proposed License Action (IIFP. 2009). As part of these analyses, off-site consequences from nonradiological and radiological hazards were evaluated, and items-relied-on-for-safety (IROFS) were

imposed to prevent or mitigate those accidents exceeding the criteria in 10 CFR 70.61.

Cumulative effects are those impacts that result from the incremental impact of an action added to other

past, present, and reasonably foreseeable actions in the future. IIFP considered past, current and potential

facilities and activities that could have some potential or cumulative impacts. The future expansion that

results in the Phase 2 ýFacility projected for the 2015-2016 timeframe and the potential approval by NRC

to exempt some pre-l-i-ese construction activities for the Proposed License Action has already been

included in this ER as reasonably foreseeable actions.

The anticipated impacts of the proposed-construction and operation of the IIFP EFfacility are expected to

be minimal; thus any incremental accumulative impacts caused by IIFP should be inconsequential. The

development and implementation of this Proposed License Action and its technology potentially avoid

impacts to other more environmentally sensitive sites.

The standard of significance (i.e., SMALL, MODERATE. LARGE) established by the NRC in NUREG1748 [Environmental Review Guidance for Licensing Actions Associated with NMSS (Nuclear Material

Safetv and Safeguards) Programs] was used to define the extent of impacts from the Proposed License

Action. The extent of impacts considering all lifecvcle phases from the Proposed License Action

combined with the Phase 2 Facility (Phase I plus expansion) is briefly summarized below by the

environmental resource that could be impacted. Potential environmental impacts are assessed to be

SMALL, except during construction periods (Phase I and Phase 2) when MODERATE impacts for

transportation on local highways may occur and SMALL to MODERATE impacts on transportation

during both operation stages and during decommissioning. and4 Cfemporary disruptions may occur in

some wildlife travel corridors during preconstruction and Phase I construction resulting in a

MODERATE impact for ecological resources. O-ve al-. Tthe cumulative potential impacts for these two

resources are SMALL.

Table 2-7 summarizes the environmental impacts for each of various stages of the Proposed License

Action and a future expansion that results in the Phase 2 Facility (preconstruction, Phase I and Phase 2

construction. Phase I and Phase 2 operation and decommissioning) for each of the resources described in

Environmental Report Request for Additional Information (RAI 1) Page 9
Official Responses to Environmental Report RAls

Chapter 3. Overall. adverse impacts from the Proposed License Action and the Phase 2 Facility are

anticipated to be SMALL. Implementation of mitigation measures will further reduce the severity of these

impacts.

The cumulative collective radiological exposure to the off-site population will be well below the

maximum dose limit of 100 mrem per year to the off-site Maximum Exposed Individual (MEI) and

below the limit of 25 mrem/yr specified in 40 CFR 190 for uranium fuel cycle facilities. Annual

individual doses to involved workers will be monitored and controlled to maintain exposure well below

the regulatory limit of 5_rem per year.

The sum total of all local and non-local cumulative impacts and effects are expected to be insignificant

when compared to the established federal, State and local regulatory limits. Positive cumulative effects

include the expansion of job opportunities and local business and tax base revenues plus the Gross

Revenue Tax and corporate income tax revenues to the State and regional communities.

Environmental Report Request for Additional Information (RAI 1) Page 10
Official Responses to Environmental Report RAIs

Table 2- 7 Environmental Impacts for the IIFP Facility

Land Use SMALL SMALL SMALL SMALL SMALL SMALL SMALL

SMALL to SMALL to SMALL to

Transportation SMALL MODERATE MODERATE MODERATE MODERATE MODERATE SMALL

Soils SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Water SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Ecological MODERATE MODERATE SMALL SMALL SMALL SMALL SMALL

Air Quality SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Noise SMALL SMALL SMALL SMALL SMALL SMALL SMALL

-istorical/Cultural SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Resources

Visual/Scenic SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Resources

Socioeconomic

Population SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Economic SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Community SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Environmental SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Justice

Public & Occupational Health

Non-radiological SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Radiological SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Accidents SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Waste Management SMALL SMALL. SMALL SMALL.. SMALL SMALL SMALL

Environmental Report Request for Additional Information (RAI 1) Page 10
Official Responses to Environmental Report RAIs

RAI I

Provide a description ofpreconstruction and construction activities and their associated impacts.

c. Provide estimated milestones (including durations) of all preconstruction and construction

activities relative to the anticipated issuance of the license.

This information is needed to assess the effects of construction and to develop the cumulative effects

analysis within the Environmental Impact Statement (EIS). Cumulative effects include past, present, and'

reasonably foreseeable future actions. Impacts from preconstruction activities will be evaluated in the

cumulative effects analysis along with those of the proposed action and any other past, present, and

reasonably foreseeable future actions. Therefore, it is necessary that these preconstruction activities and

their impacts be clearly distinguished throughout the ER from the construction activities that are

considered part of the proposed action.

RESPONSE:

A proposed schedule for the preconstruction activities and for the construction of the Phase I and Phase 2

Facilities was developed prior to the assessment of the impacts. Impacts from preconstruction activities

were considered separately from general construction activities in the assessment of the environmental

resources.

Environmental Report Documentation Impact: The Environmental Report will be revised to add a

schedule of the preconstruction activities (Table 2-1) with the schedule for the Phase 1 and Phase 2

construction. Section 2.1.2.17 will be added to the Environmental Report and will read as follows:

2.1.2.17 Schedule of Preconstruction and Construction Activities

The schedule for the preconstruction and Phase I and Phase 2 construction is presented in Table 2-1. The

schedule shows both preconstruction/activities that do not require an NRC exemption or NRC approval

and those construction activities requiring an NRC exemption. The schedule assumes each of the

activities is approved by the NRC and other agencies having jurisdiction. General facility construction of

the Phase 1 and Phase 2 Facilities, other than the exempted and approved preconstruction will start only

after N RC license approval.

Table 2-1_Proposed Schedule for Construction

Construction Activity :•::'•"Estimated T Schedule Start Projeczt

Completion

Construction/Activity Not Re uiring NRC Exemption

Wildlife Baseline Study' 3d Quarter 2010 3 d Quarter 2011

Location and Staking of Under-ground and Above- 2'd Quarter 2011 3d' Quarter 2011

ground Utilities

Survey and Staking of 40 Acre Facility Site within 2n' Quarter 2011 2

.. Quarter 2011

640-acre Section ,

Testing of Existing Well Water to Determine 3• Quarter 2011 4" Quarter 2011

Treatment Requirements

Environmental Report Request for Additional Information (RAI 1) Page 11
Official Responses to Environmental Report RAIs

Tt

.. , Construction Activity 'Schedule Start -I Co"Ipletion

Soil Borings for Founidations for Buildings, Process ,rd ,1Q 21

Structures. Storage Pads and Roads Quarter j uaiu 201_1

.Preconstruction Requii g NRC Exemption

Site Clearing 40 Acres 3r, Quarter 2011 1l Quarter 2012

Pre-construction Erosion and Storm Water Run-off 3"d Quarter 2011 Ist Quarter 2012

Control

Installation of Truck Wash-off Station 41t Quarter 2011 1i• Quarter 2012

Site Grading and Erosion Control/Sedimentation

Retention for Buildings, Process Structures, Storage 4"' Quarter 2011 1 Quarter 2012

Pads and Roads

Main Entrance Roadbed with Drainage to 40-acre site 4 th Quarter 2011 1 ,' Quarter 2012

Construction/Office Trailer Installation 4 1h Quarter 2011 1 Quarter 2012

Electrical Substation Installation 4 "h Quarter 2011 1 S Quarter 2012

Gas Main Installation to 40-acre Site 4"' Quarter 2011 1' Quarter 2012

Administrative Building Shell Construction 4' Quarter 2011 11 Quarter 2012

Maintenance/Stores Building Shell Construction 4"' Quarter 2011 1s Quarter 2012

Warehouse Building Shell Construction 4"' Quarter 2011 11 Quarter 2012

Temporary Fencing 4"' Quarter 201 1 1 Quarter 2012

Facility Site Roadbeds and Gravel Parking Areas for I 't Quarter 2012 1 Quarter 2012 Construction

Water Well Drilling 4 d' Quarter 2011 st Quarter 2012

Geothermal Heat Pump Loop Installation 4"h Quarter 2011 1,I Quarter 2012

Firewater Tank Installation 4"h Quarter 2011 1 Quarter 2012

Construction after NRC License

Phase I Construction 2"' Quarter 2012 2"1 Quarter 2013

Phase 2 Construction 2"'_•' Quarter 2015 2__ Quarter 2016

Environmental Report Request for Additional Information (RAI 1) Page 12
Official Responses to Environmental Report RAls

RAI 2

Provide Phase I and Phase 2 activities and impacts separately.

a. Clarify and confirm that the proposed action consists only of Phase 1

This information is needed to describe the proposed action and to develop cumulative effects analyses

within the EIS. Cumulative effects include past, present, and reasonably foreseeable future actions. Phase

2 construction and operation will be considered reasonably foreseeable future actions relative to the

proposed action, and their impacts will be evaluated in the cumulative effects analysis along with those of

the proposed action and any other past, present, and reasonably foreseeable future actions. Therefore, it

is necessary that these Phase 2 activities and their impacts be clearly distinguished throughout the ER

from activities that are part of the proposed action.

RESPONSE:

The ER will be revised to be clear that the "Proposed License Action" is for Phase 1 Facility construction

and operation. The "Proposed Action" term that was used in the Revision A of the Environmental Report"

has been renamed "Proposed License Action."

This Environmental Report (ER) addresses cumulative effects from of the Phase 1 Facility, the

incremental effects of a future expansion that results in the Phase 2 Facility and the cumulative effect of

the Phase 2 Facility (Phase 1 Facility plus expansion, i.e. integrated IIFP Facility) in order for NRC to

prepare an Environmental Impact Statement (EIS) for the Phase 1 and Phase 2 IIFP Facility.

The 2 nd paragraph of the Environmental Report, Revision A, Section 1.2, "Purpose and Need for Proposed

License Action," reads as follows:

IIFP is currently requesting an NRC license for a possession limit of 750,000 kilograms of depleted

uranium (kg U) during Phase 1. Prior to the Phase 2 expansion, IIFP will prepare and submit an amended

license application for the Phase 2 facility, including a possession of up to 2,200,000 kilograms of

depleted uranium. The environmental impact evaluation conducted by this ER has been prepared for the

Phase 1 and Phase 2 integrated facility. The average on-site inventories of uranium materials and major

chemicals for both phases of the facility are presented in Table 1-1. IIFP has a written agreement with the

New Mexico Environment Department (NMED) on maximum limits of total uranium and chemical

inventories. (Revised-See RAI ER-2b).

In addition, each environmental resource addressed in Chapter 4 will be revised to clarify that the

assessed impact includes both Phase I and Phase 2 Facilities even though the Proposed License Action is

the Phase I Facility. Chapter 4 will be restructured to address construction and operations for Phase 1,

incremental impacts from the construction and operations for Phase 2, and combined impacts for the

construction and operations of the integrated IIFP Facility (includes Phase I and Phase 2). The revised

Chapter 4 that will be provided in a separate document as part of the official RAI ER response package.

In addition, Figure 4-1 "Integrated Facility" a redacted figure will be submitted as an updated Site Plan

electronic drawing (number I00-C-000I Revision E) that can be viewed and printed as a legible 24" x

36" engineering drawing of the ER Figure 4-1.

Environmental Report Request for Additional Information (RAI 2) Page 13
Official Responses to Environmental Report RAIs

Environmental Report Documentation Impact: The 8 th paragraph of Section 1.1, "General Description

of the IIFP Facility and Proposed License Action," (renamed title) of the Environmental Report, Revision

A, will be revised and will read as follows:

1.1 General Description of the IIFP Facility and Proposed License Action

PrecConstruction of the Phase I pl4-*Facility is expected to begin in late 2011 and startup of operations is

expected to begin in the-4atemid-20134. The expafi+,en construction for aexpanding the Phase I Facility

that results in a Phase 2-p*4a Facility is expected to begin in 2015 and operations start up in late 2016.

The "Proposed Action" term that was used in the Revision A of the Environmental Report has been

renamed "Proposed License Action." The ER does however include the Environmental Impacts and

Cumulative Effects for both the Proposed License Action (which is the Phase 1 Facility) and the Phase 2

Facility (Phase 1 Facility plus expansion). as well as the incremental effects of the expansion, where

applicable, in order for NRC to prepare an Environmental Impact Statement (EIS) for the Phase 2 IIFP

Facility. Prior to the Phase I expansion resulting in the Phase 2 Facility, IIFP will prepare and submit an

amended license application for the Phase 2 Facility. At the end of its useful life, the -4a•t4IFP Facility

woul4dwill be decommissioned consistent with the decommissioning plan that is developed and submitted

in the IIFP License Application, Chapter 10, "Decommissioning".

Environmental Report Documentation Impact: The 5th and 6th paragraphs of Section 2.1, "Proposed

Action," (renamed "Proposed License Action") of the Environmental Report, Revision A, will be revised

and a new 7 th paragraph will be added as clarification and will read as follows:

2.1 Proposed License Action_(renamed)

Phase 1, with a projected startup date of latemid-20132, consists mainly of two processes:

* DUF6 de-conversion to depleted uranium tetrafluoride (DUF4), i.e. the DUF6 to DUF 4 plant.

* The Fluorine Extraction Process for producing SiF 4 and BF 3 by reacting the DUF 4 produced

in the de-conversion step with the oxides of silicon (Si0 2) and boron (B20 3), respectively.

The Pphase 2 pant-4Fcility, scheduled for startup in n+i4late-2016 will have an additional process for

direct de-conversion of DUF6 to uranium oxide. The Proposed License Action addresses only the

construction and operation of the Phase I IIFP Facility. Prior to a future expansion that results in the

Phase 2 Facility. IIFP will prepare and submit an amended license application for the Phase 2 Facility.

This Environmental Report (ER) addresses cumulative effects from of the Phase I Facility, the

incremental effects of a future expansion that results in the Phase 2 Facility and the cumulative effect of

the Phase 2 Facility (Phase I Facility plus expansion, i.e. integrated JIFP Facility).

Environmental Report Documentation Impact: Chapter 4 of the Environmental Report, Revision A

will be restructured to provide separate sections addressing construction and operations for Phase 1,

incremental impacts from the construction and operations for Phase 2, and combined impacts for the

construction and operations of the integrated IIFP Facility (includes Phase 1 and Phase 2). Remove

Chapter 4 of the Environmental Report, Revision A in its entirety and replace with the revised Chapter 4

that will be provided in a separate document as part of the official RAI ER response package. The outline

for Chapter 4 is shown below:

Environmental Report Request for Additional Information (RAI 2) Page 14
Official Responses to Environmental Report RAIs

4. ENVIRONMENTAL IMPACTS

4.1 Land Use Impacts

4.1.1 Phase 1 Facility

4.1.2 Incremental Impacts from the Phase 2 Facility

4.1.3 Combined Impacts from the Integrated Facility

4.1.4 Decommissioning

4.1.5 Cumulative Impacts

4.1.6 Control of Impacts

4.1.7 Comparative Land Use Impacts of Alternative Actions

4.2 Transportation Impacts

4.2.1 Transportation Mode

4.2.2 Transportation Route

4.2.3 Traffic Pattern

4.2.4 Phase 1 Facility Impacts

4.2.5 Incremental Impacts from the Phase 2 Facility

4.2.6 Combined Impacts from the Integrated Facility

4.2.7 Other Construction Transportation Impacts

4.2.8 Radioactive Material Transportation

4.2.9 Decommissioning

4.2.10 Cumulative Impacts

4.2.11 Impact Controls

4.2.12 Comparative Transportation Impacts of Alternative Actions

4.3 Geology and Soil Impacts

4.3.1 Geology Impacts

4.3.2 Soils Impacts

4.3.3 Phase 1 Facility

4.3.4 Incremental Impacts from the Phase 2 Facility

4.3.5 Combined Impacts from the Phase 2 Facility

4.3.6 Decommissioning

4.3.7 Cumulative Impacts to Site Soils

4.3.8 Impact Controls

4.3.9 Comparative Geology and Soil Impacts of Alternative Actions

4.4 Water Resources Impacts

4.4.1 Surface Waters

4.4.2 Receiving Waters

4.4.3 Impacts on Surface Water and Groundwater Quality

4.4.4 Hydrological System Alterations

4.4.5 Hydrological System Impacts

4.4.6 Ground and Surface Water Use

4.4.7 Identification of Impacted Ground and Surface Water Users

4.4.8 Decommissioning

4.4.9 Identification of Predicted Cumulative Effects on Water Resources

4.4.10 Control of Impacts to Water Quality

4.4.11 Comparative Water Resources Impacts of Alternative Actions

4.5 Ecological Resources Impacts

4.5.1 Maps

4.5.2 Proposed Schedule of Activities

4.5.3 Phase 1 Facility

4.5.4 Incremental Impacts from the Phase 2 Facility

Environmental Report Request for Additional Information (RAI 2) Page 15
Official Responses to Environmental Report RAIs

4.5.5 Combined Impacts for the Phase 2 Facility

4.5.6 Area of Disturbance by Habitat Type

4.5.7 Maintenance Practices

4.5.8 Short-Term Use Areas and Plans for Restoration

4.5.9 Activities Expected to Impact Sensitive Communities or Habitats

4.5.10 Impacts of Elevated Construction Equipment or Structures

4.5.11 Tolerances and Susceptibilities of Important Biota to Pollutants

4.5.12 Special Maintenance Practices

4.5.13 Wildlife Management Practices

4.5.14 Decommissioning

4.5.15 Cumulative Impacts

4.5.16 Practices and Procedures to Minimize Adverse Impacts

4.5.17 Comparative Ecological Resource Impacts of Alternative Actions

4.6 Air Quality Impacts

4.6.1 Phase I Facility

4.6.2 Incremental Impacts from the Phase 2 Facility

4.6.3 Combined Impacts for the Phase 2 Facility

4.6.4 Description of Gaseous Effluents

4.6.5 Visibility Impacts

4.6.6 Decommissioning

4.6.7 Cumulative Impacts

4.6.8 Control of Impacts

4.6.9 Comparative Air Quality Impacts of No-Action Alternative Scenarios

4.7 Noise Impacts

4.7.1 Phase I Facility

4.7.2 Incremental Impacts from the Phase 2 Facility

4.7.3 Combined Impacts for the Phase 2 Facility

4.7.4 Noise Sources

4.7.5 Sound Level Standards

4.7.6 Potential Impacts to Sensitive Receptors

4.7.7 Facility Decommissioning

4.7.8 Cumulative Effects

4.7.9 Control of Noise Impacts to Community

4.7.10 Comparative Noise Impacts of Alternative Actions

4.8 Historic and Cultural Resource Impacts

4.8.1 Proposed License Action

4.8.2 Agency Consultation

4.8.3 Historic Preservation

4.8.4 Potential for Human Remains

4.8.5 Minimizing Adverse Impacts

4.8.6 Cumulative Impacts

4.8.7 Comparative Historical and Cultural Resource Impacts of Alternative Scenarios

4.9 Visual/Scenic Resources Impacts

4.9.1 Photos

4.9.2 Proposed License Action

4.9.3 Phase 1 Facility Impacts

4.9.4 Incremental Impacts from the Phase 2 Facility

4.9.5 Combined Impacts for the Phase 2 Facility

4.9.6 Decommissioning

Environmental Report Request for Additional Information (RAI 2) Page 16
Official Responses to Environmental Report RAIs

4.9.7 Aesthetic and Scenic Quality Rating

4.9.8 Significant Visual Impacts

4.9.9 Visual Compatibility and Compliance

4.9.10 Cumulative Impacts to Visual/Scenic Quality

4.9.11 Comparative Visual/Scenic Resources Impacts of No-Action Alternative

4.10 Socioeconomic Impacts

4.10.1 Facility Construction

4.10.2 Facility Operation

4.10.3 Decommissioning

4.10.4 Cumulative Socioeconomic Impacts

4.10.5 Comparative Socioeconomic Impacts of No-Action Alternative Scenarios

4.11 Environmental Justice

4.11.1 Procedure and Evaluation Criteria

4.11.2 Results of Census Block Group Data

4.11.3 NRC Review of NEF Environmental Justice

4.11.4 Proposed License Action

4.11.5 Comparative Environmental Justice Impact of Alternative Actions

4.12 Public and Occupational Health Impacts

4.12.1 Nonradiological Impacts

4.12.2 Radiological Impacts

4.12.3 Environmental Effects of Accidents

4.12.4 Decommissioning

4.12.5 Cumulative Effects

4.12.6 Control of Impacts

4.12.7 Comparative Public and Occupational Exposure Impacts of No-Action

Alternative Scenarios

4.13 Waste Management Impacts

4.13.1 Waste Descriptions

4.13.2 Site Preparation and Construction of the IIPF Facility

4.13.3 Waste Disposal from the Operation of the IIFP Facility

4.13.4 Waste Minimization

4.13.5 Decommissioning Impacts

4.13.6 Cumulative Impacts

4.13.7 Control of Impacts

4.13.8 Comparative Waste Management Impacts of No-Action Alternative Scenarios

Environmental Report Request for Additional Information (RAI 2) Page 17
Official Responses to Environmental Report RAts

RAI 2

Provide Phase 1 and Phase 2 activities and impacts separately.

b. Provide separate quantitative Phase 1, Phase 2 (incremental), and cumulative (Phase 1 plus

Phase 2) values for the following information described in Chapters 2 and 4 of the ER (IIFP,

2009a):

* all materials that serve as inputs and outputs to the deconversion process (a mass balance),

including emissions and waste streams;

* workforce; and

* impacts.

For example, separate the air quality impacts described in Section 4.6.2, "Air Quality Impacts

from Operations" into impacts that will result from Phase 1 operations and impacts that will

result from Phase 2 operations. Also, state that the cumulative impacts will be Phase 1 plus

Phase 2, or describe the cumulative impacts, if they are not additive.

This information is needed to describe the proposed action and to develop cumulative effects analyses

within the EIS. Cumulative effects include past, present, and reasonably foreseeable future actions. Phase

2 construction and operation will be considered reasonably foreseeable future actions relative to the

proposed action, and their impacts will be evaluated in the cumulative effects analysis along with those of

the proposed action and any other past, present, and reasonably foreseeable future actions. Therefore, it

is necessary that these Phase 2 activities and their impacts be clearly distinguished throughout the ER

from activities that are part of the proposed action.

RESPONSE:

Revision A of the Environmental Report was reviewed to ensure that each environmental resource was

assessed for Phase 1, Phase 2, and cumulative impacts. Where each environmental resource was

inadequately assessed, revisions were made to address those impacts for the construction and operation of

each stage of the Facility. In addition, Chapter 4 was restructured for the most part to have separate

sections addressing construction and operations for Phase 1, incremental impacts from the construction

and operations for Phase 2, and combined impacts for the construction and operations of the integrated

IIFP Facility (includes Phase 1 and Phase 2). This necessitated a rewrite of Chapter 4. The revised

Chapter 4 will be provided in a separate document as part of the official RAI ER response package.

ER Figure 1-2 "Projected IIFP Facility Estimated Annual Capacity" will be removed and replaced to

incorporate new calculations for an additional production line for BF3 during the Phase 2 operations.

Section 1.1 will be reviewed and revised accordingly. See also RAI 13a.

Table 1-1 will be replaced and named "Phase 1 and Phase 2 Facility Inventories of Major Chemical

Materials") with the new table depicting the typical range of inventory for Phase 1 and integrated Phase 2,

(see also RAI GI-7A). The range of inventory amounts does not necessarily represent

minimum/maximum values. The range is derived from estimates of production through-put rates, plant

process capabilities and additional contingencies. The contingencies included in the estimate are

operational and material delivery situations that may cause variations in the facility raw material, workEnvironmental Report Request for Additional Information (RAI 2) Page 18
Official Responses to Environmental Report RAIs

in-progress and product inventories but will be controlled such as not to cause licensed material

possession limits to be exceeded.

Environmental Report Documentation Impact: For each environmental resource with quantifiable

data, each section addressed Phase 1 impacts, incremental impacts, and impacts for Phase 2 (Phase I plus

the expansion). See Environmental Report Documentation Impact RAI ER-2a addressing the Chapter 4

rewrite.

Environmental Report Documentation Impact: Former paragraph 3 of the Chapter 1, introduction will

be revised for clarification (bullets excluded).

This Environmental Report (ER) addresses cunmlative effects from of the Phase I Facility, the

incremental effects of a future expansion that results in the Phase 2 Facility and the cumulative effect of

the Phase 2 Facility (Phase I Facility plus expansion, i.e. integrated IIFP Facility). This ER evalu'ates the

environmental impa.ts of the Proposed JH"P faciiity. Accordingly, this document discusses the Proposed

License Action, the need for and purposes of the Proposed I...icense Action, applicable regulatory

requirements, impacts, consequences, etc. as included in the following chapters:

Environmental Report Documentation Impact: (1) ER Section 1.1 (renamed) will be revised beginning

with former paragraph seven. Figure 1-2 will be removed and replaced with updated data. See also RAI

ER-13a.) (1) Remove Table 1-1 and replace with renamed Table 1-1 "Phase 1 and Phase 2 Facility

Inventories of Major Chemical Materials" in ER Section 1.2, renamed "Purpose and Need for Proposed

License Action." Section 1.2 will also include minor revisions to clarify Phase 1 and Phase 2, and to

identify the values in Table 1-1; the section will read as follows:

1.1 General Description of the IIFP Facility and Proposed License Action

The future Phase 2 fFacility is the result of-wil-lbe an expansion of the Phase I 4Facility, which provides

additional de-conversion capability using a chemical process for direct de-conversion of DUF6 to uranium

oxide and provides an additional line of production for BF3 . The Phase 2 Facility is not the expansion but

it is the result of the Phase 1 Facility plus the expansion. The Phase 2 plant-Facility (Phase I plus

expansion) is scheduled to be built and operational by mid-2016. In the Phase 2 process, DUF6 is received

from the toll-service de-conversion customer, vaporized in containment-type autoclaves and fed to a firststage reaction vessel where the DUF6 reacts with a steam-HF vapor mix to produce depleted uranyl

oxyfluoride (DUO2F2) and concentrated HF vapor. The DUO2F2 is withdrawn as a powder and fed to a

second-stage reaction vessel and heated with steam to form uranium oxide powder and HF vapor. The HF

vapors from both of the reaction vessel stages are condensed and fed to a fractional distillation column

where AHF is withdrawn from the top of the column and aqueous HF is taken from the bottom and

recycled as feed reactant to the first-stage reaction vessel. The AHF is packaged into approved tank

trailers; the product is sold and shipped to customers for use in industrial chemical applications. Uranium

oxide from the second-stage reaction vessel is packaged and shipped to an off-site licensed disposal

facility.

PrecGonstruction of the Phase I pfA+4Facility is expected to begin in late 2011 and startup of operations is

expected to begin in +e4-atemid-20132. The expansien construction for aexpanding the Phase I Facility

that results in a Phase 2-plant Facility is expected to begin in 2015 and operations start up in late 2016.

The "Proposed Action" term that was used in the Revision A of the Environmental Report has been

renamed "Proposed I.Jcense Action." The ER does however include the Environmental Impacts and

Cumulative Effects for both the Proposed License Action (which is the Phase 1 Facility) and the Phase 2

Environmental Report Request for Additional Information (RAI 2) Page 19
Official Responses to Environmental Report RAIs

Facility (Phase I Facility plus expansion), as well as the incremental effects of the expansion, where

applicable, in order for NRC to prepare an Environmental Impact Statement (EIS) for the Phase 2 IIFP

Facility. Prior to the Phase I expansion resulting in the Phase 2 Facility, IIFP will prepare and submit an

amended license application for the Phase 2 Facility. At the end of its useful life, the plantllFP Facility

will would-be decommissioned consistent with the decommissioning plan that is developed and submitted

in the IJFP License Application, Chapter 10, "Decommissioning".

IIFP is designing the company's Phase 1 ftanl-Facility annual capacity for de-converting approximately

300 DUF 6 cylinders per year; equivalent to about 7-.-.'_8 million pounds of DUF6 per year (lb/yr) or j-.43.6

million kilograms per year (kg/yr). The Phase 1 plan-t-Facility_also has a designed production capacity of

.I. .R..... "ey-nearly 2 million lb/yr (0.9 million kg/yr) of specialty fluoride products, and 1 million lb/yr

(0.45 million kg/yr) AHF.

Upon completion of the expansion that results in the Phase 2 Facility, the integrated facility will have an

overall total de-conversion capacity of .ea.y-,..approxinmately 928 DUF 6 cylinders; about 2a4-.725.5

million lb/yr ("-l 1.6 million kg/yr) DUF6. Ne•ay-Approximately_ 34 L.2 million lb/yr (2-42.8 million

kg/yr) of AHF product is projected to be produced and sold and the specialty fluoride products will reach

a capacity of 2.8 million lbs/yr (1.3 million kg/vr. A schematic of the process flows and designed

operational capacity for the plant is presented as Figure 1-2. A more detailed description of the IJFP

Facility processes and the Facility site plan illustrating buildings and layout are provided in Chapter 2 of

the ER.

1.2 Purpose and Need for Proposed License Action

The Proposed License Action is the issuance of an NRC license under Title 10 Code of Federal

Regulations Part 40, "Domestic Licensing of Source Material" for the IIFP plantFacilitv. The license

application and supporting documentation addresses pre-license construction (hereafter called

preconstruction), construction after license approval and operation of a facility to utilize depleted uranium

hexafluoride (DUF6) to produce high-purity inorganic fluorides, uranium oxides, and anhydrous

hydrofluoric acid. There is no known existing or planned private commercial de-conversion capacity in

the U.S. or in this hemisphere. This ER is prepared and submitted for both the Phase 1 and Phase 2

Facilities.

IIFP is currently requesting an NRC license for a possession limit of 750,000 kilograms of depleted

uranium (kg U) during Phase 1. Prior to the Phase 2 expansion, IIFP will prepare and submit an amended

license application for the Phase 2 WFacility, including a possession of up to 2,200,000 kilograms of

depleted uranium. The environmental impact evaluation conducted by this ER has been prepared for the

Phase 1 and Phase 2 integrated facility. The average-estimated typical range of on-site inventories of

Environmental Report Request for Additional Information (RAI 2) Page 20
Official Responses to Environmental Report RAls

33-6 brDL-- .DLF- to DLTs

j -L2S Cvlindeis. ' ýon-vrslen &n4Y1-1

Ib 4"O b viO

ARTI

--------------------------------------- -1 1 ----------- -------- ---

5 J:

)7i2it-,viDýTz k d-I

lbJ1&f -ýf Plant l y UO

L onIý

vrEI -7~Ilv

Ill

All uranium in the above flowchart is "depleted".

Figure 1-2 Projected IIFP Facility Estimated Annual Capacity

I

Environmental Report Request for Additional Information (RAI 2) Page 21
Official Responses to Environmental Report RAls

uraniurn materials and major chemicals- materials for both phases of the facility are-is presented in Table

1-1. IlFP has a written agreement with the New Mexico Environment Department (NMED) on maximum I imit", n! rteml iiran!nim nnd chemicau! in-vent~riezinventories of denleted uranium oxides and total denletedi

uranium that can be maintained on site.

Table 1- 1 Phase 1 and Phase 2 Facility Inventories of Major Chemical Materials

Physical Typical Range of

Form: Typical Range of Inventory BaSed on

Maximum Limit Liquid(i). Inventory Based on ProjectedoPrydUction

Material Agreement with Solid or Projected Production . aiectdnPr ( :: io

New Mexico'> Po•der(s), l Capacity and Capaciy a nd

S Vapor or Requirements Phase I (Phase I + exi~aisionB)

lotal Depleted 4.851,000 lb 678,200-1.653.750 lb 678,200-4,851,000 lb

Uranium as "U" (2,200,000 kg) (307,575-750,000 kg) (307.600-2.200.000 kg)

219,700-1,105,000 lb 219.700-1,875,000 lb DUE! Not Applicable (NA) • (100U.000-50 1A100 kg) (100.000-850.300 kg)

PN363.500-5 15,000 lb 363,500-1.268.000 lb

DU___4 NA (164,900-233,600 kg) (164,900-575,000 kg)

Uranium Oxides as 2.205.000 lb 350,000-525,000 lb 350.000-1.564,000 lb

DUO 2 (1.000.000 ke) (158,700-238,100 kg) (158,700-709,300 kg)

Hydrofluoric Acid 31,000-80,000 lb 31.000-150.000 lb

(Iydrogen Fluoride) N A. (14,100-36L300 kg) (14.100-68000 kg)

S__, (Packaged + in 8,000-14,400 lb 8,000-14,400 lb

process) (3.,600-6,.500 kg) (3.600-6500 kg)

BFPac e NA. 7,200-54.800 lb 7,200-284,000 lb

(3,300-24,900 kg) (3,300-129.000 kg)

14,000-54,000 lb 14,000-54,000 11) KOH N.A 1 (6.300-24,600 kg) (6.300-24.600 kg)

2,400-80.500 lb 2.400-80.500 lb CaF2 NA (1,100-36,500 kg) (1,100-36.500 kg)

25.000-100.000 lb 25.000-100.000 lb

a 2 NA (11.300-45,300 kg) (11.300-45,300 kg)

l'•lq l I\l'll ll lJ [l ll-llI 1 I~ ~ Il l~ ll n II (II"~• inf- I.r/ - In 1•II•n /r i n i-llii-n |-ll I~ll]i/1• n fi~ la

22. 2009.

Environmental Report Documentation Impact: Remove and replace Table 7-4 from Chapter 7 of the

ER. Table 7-4 has been revised to provide separate Phase 1 and incremental Phase 2 values for workforce

labor costs.

Environmental Report Request for Additional Information (RAI 2) Page 22
Official Responses to Environmental Report RAIs

Table 7- 1 Estimated Construction Labor Costs

Phase I Incremental Incremental

P 3 Years Expansion 3.5 Years

: Phase I • Average Resulting in a '

Cost Category in Millions Cost Phase 2 Facility Average •Annual Annual

MOM9S) in Millions (St in Millions CostsA

(2009S) .(2 09$ Mi ioliýn•'$)

Construction & Installation 36-40 12-13.3 14-19 4-5.4

Engineering, Procurement

& Construction 7-11 2.3-3.7 7-9 2-2.6

Management

Project Management 2-3 0.7-1 1-1.5 0.3-0.4

Total 45-54 15-18 22-29.5 6.3-8.4

Environmental Report Documentation Impact: Revise Section 7.1.2 (renamed )of the ER, paragraphs

one, two and three to incorporate the increased capacity in Figure 1-2 and milestone schedule Table 1-2

(see RAI ER-2b and ER 13a).

7.1.2 Basis of Construction and Operating Costs-Benefit Estimates for the Proposcd Action

The project construction and operation cost estimates assume that project detailed engineering begins in

mid 201, and some pre liensigconstuctioprenststruction activities may start by early-late

2011. Upon approval of the NRC license application, the full construction is expected to begin by the end

of 2nd quarter 2014-2 with startup of the Phase I operation for functional testing byen4-the 2 'd quarter of

2013_2. It is assumed that the facility would not reach significant production operating levels and receipt

of revenue streams until mid- to-late 2013, after operational checkout and test production runs are

completed and operations are well underway.

Beginning in late 2013, the production of the two fluorine extraction process (FEP) products (SiF 4 and

BF 3) and the anhydrous hydrogen fluoride (AHF) by-product is assumed to ramp up over the following

six months to approach the operational design capacity in 2014 of about 2 million lb/yr (0.9 million kgivr)

of specialty fluoride (FEP) products0.68 million kg/y' (1.5 million lb/yr) of SiF 4, 0.23 million kg/yr (0.5

milli;n lb/yr)' of BF,, and about I million lb/yr (0.45 million .- /yr,. milli.n ky .3...illi.n l/)

of AHF. The Phase I plant design capacity for de-conversion is approximately 8 million lb/yr (3.6 million

kg/yr) DUFI- 3.3 million . k.g..yr. (7.3 millien ub.yr, or about 2--0-300 DUF 6 cylinders per year.

Costs and benefits estimates are also included for the Phase 2 fFacility that would be constructed in the

2014-2015 timeframe. Phase 2 fFacility startup is planned for mid-2016 resulting in an additional DUF6

de-conversion design capacity of nearly 17.5 million lb/yr (7.9 million kg/yr) 6.5 +mii kg/yr (about

14.4 million lk/yr). This will result in a total integrated plant de-conversion capacity of approximately

25.5 million lb/yr (11.6 million kjg/yr) of DUF69.8 million lgi,/yr, (21.7 million lb/yir), or nearly 7--928

DUF 6 cylinders per year. The Phase 2 capacity provides for production of an additional 2.22 million kg/yr

(-9 , ml444 .,/yi-j3• 5 million lb/yr (2.4 million ktg/yr) of AHF; increasing the total facility production

c t fn r). 2.6 million kg/yr, (5.7 million l/year). capacity for AHF to about 6.2 million Ib/vr (2.8 million kLir..,••,m Vgy: .<..' ,,.,,,, I...,.•u;' ya)

Environmental Report Request for Additional Information (RAI 2) Page 23
Official Responses to Environmental Report RAls

The FEP capacity increases by 0.76 million lb/yr (0.34 million kg/yr) to reach a total capacity of nearlv

2.8 million lb/yr ( 1.25 million kg/yr).

Environmental Report Request for Additional Information (RAI 2) Page 24
Official Responses to Environmental Report RAls

RAI 2

Provide Phase I and Phase 2 activities and impacts separately.

c. Describe Phase 2 construction activities. For example describe additional land disturbing

activities and construction of buildings.

This information is needed to describe the proposed action and to develop cumulative effects analyses

within the EIS. Cumulative effects include past, present, and reasonably foreseeable future actions. Phase

2 construction and operation will be considered reasonably foreseeable future actions relative to the

proposed action, and their impacts will be evaluated in the cumulative effects analysis along with those of

the proposed action and any other past, present, and reasonably foreseeable future actions. Therefore, it

is necessary that these Phase 2 activities and their impacts be clearly distinguished throughout the ER

from activities that are part of the proposed action.

RESPONSE:

A description of the Phase 2 construction activities will be added to the Environmental Report.

Environmental Report Documentation Impact: A new section will be added to the Environmental

Report, Revision A to describe the Phase 2 construction activities. Section 2.1.2.18 will be added and will

read as follows:

2.1.2.18 Phase 2 Construction

The fourth construction stage is expected to begin in 2015 and will complete the Phase 2 Facility

increasimn DUF de-conversion capacity. During this construction stage, additions are planned for the

DUF6 Autoclave Building, the Oxide Process Building. Direct Oxide Staging Building and the HF

Distillation Annex.

The entire site clearing will occur during preconstruction and Phase I construction. No roads will need to

be added. Minor revisions during Phase 2 construction to paved or concrete areas may be required.

Hence. no major earth grading or movement will be necessary, but excavation will be required for sewer

and building foundations and floors and for tie-ins for water, natural gas, and electrical utility lines.

Excavation for foundations will be minimized. Loose soil and/or damaged caliche will be removed prior

to installation of foundations for seismically designed structures. Approximately 20% more building

space will be added to the existing Phase I Facility. Considering the total 640-Section area, minimal soil

disturbance will occur. Silt fences and straw bales will be used to control erosion and to protect

undisturbed areas.

A construction/office trailer containing offices for construction supervisory personnel will be installed at

a strategic location near the Phase I production areas. The construction trailer will not maintain any

functional toilet facilities, so portable sanitary facilities will be stationed in locations convenient to Phase

2 construction areas. The construction trailer will require temporary 1 15/230 volt, single phase power.

Temporary chain-link fencing with locking gates will be installed around the construction/office trailer

and around each building shell for construction personnel entry and egress.

Environmental Report Request for Additional Information (RAI 2) Page 25
Official Responses to Environmental Report RAts

The Oxide Process Building and the Direct Oxide Sta ging Building are of structural steel beam and

column construction with metal wall panels and with Class 1 metal roofs as approved by Factory Mutual

(FM)-4450 (FM, latest edition) or as classified by Underwriters Laboratory (LII!,) standard 1256 (UI.

latest edition). The first floor of each building is constructed of reinforced concrete with curbing to

function as a containment-type barrier. The Oxide Process Building is 15.3 in x 15.3 n_ x 21.3 n (50 t

long x 50 ft wide x 70 ft) eve height, while the Direct Oxide Staging Building is 15.3 in x 6.2 in x 9.1 in

(50 ft x 20 ftx 30 ft)]. The existing Phase 1 DUF Autoclave Building [27.4 m x 18.3 in x 12.2 m (90 ft x

60 ft x 40 fl)] will be expanded an additional [27.4 m x 18.3 in x 12.2 m (90 ft x 60 ft x 40 ft)] to add

three more autoclaves with support piping, valves, and control instrumentation.

The 1IF Distillation Annex is constructed of reinforced concrete floor slabs turned up to form

containment-type barriers. The upper sections of these buildings are of concrete block construction with

Class I metal roofs meeting FM and UL requireinents as stated above. The HF Distillation Annex is 7.6

m x 6.1 m x 18.3 in (25 ft x 20 ftx 60 fIT).

The process buildings are multi-story buildings where necessary to provide requirements for equipment

space and to provide elevations for permitting gravity flow of particulate solids. The uipper floors are

configured such as to provide adequate room for equipment function and maintenance. The upper floor

areas below equipment and piping containing, powdered materials are constructed of reinforced concrete

with curbincg and seal coatings on floor and wall surfaces. Other upper floor areas of the buildings are

constructed of metal grating or metal flooring.

See Section 2.1.4.1, "Process Buildings and Process Areas," for additional information on the process

control rooms for the maior processes, including appropriate mnonitoring, recording, alarm notification

and control instrumentation.

Environmental Report Request for Additional Information (RAI 2) Page 26
Official Responses to Environmental Report RAIs

RAI 3

Provide additional information regarding taxes during construction and operation of the International

Isotopes Fluorine Products, Inc. (JIFP) facility.

a. Provide a description of any agreements, abatements, fees-in-lieu-of taxes, or any other

arrangements (routine or special) that IIFP may have with property taxing entities for the

facility.

The above tax payment information will be needed to quantitatively evaluate the impacts of construction

and operations property tax payments for the EIS socioeconomics analysis. This is important to clarify

because payments made to local taxing entities can be considered large in comparison to other local

municipality tax revenues, and can therefore be a significant factor in the socioeconomic impact analysis.

RESPONSE:

In New Mexico, Industrial Revenue Bonds (IRB) may be issued to finance privately-operated developed

projects by a municipality, county or the New Mexico Finance Authority. The private party initiates the

process by requesting that the government unit issue the bonds. IRBs offer some property and gross

receipts tax relief to a company.

International Isotopes, Inc. as the parent corporation of IIFP has arranged through a Lease and Purchase

Agreement a $72 million Industrial Revenue Bond with Lea County, New Mexico. The Issuer (Lea

County) at the request of the Company (IIFP), or the Company as an agent for the Issuer will apply to the

New Mexico Taxation and Revenue Department (TRD) for nontaxable transaction certificates to be

issued by the Company to vendors in order to permit vendors to IIFP to claim deductions available under

the New Mexico Gross Receipts and Compensating Tax Act. The receipts of vendors from the sale of

tangible property to the Issuer (effectively IIFP) are deductible from the gross receipts (taxation). The use

of such property is exempt from compensating tax (or property tax) to the fullest extent permitted under

New Mexico Administrative Code.

Effectively, through the IRB agreement, IIFP is essentially exempt from the annual property tax.

However, IIFP must pay to the Hobbs Municipal School District and to the New Mexico Junior College,

an amount in lieu of property tax that IIFP would have been required to be paid as property tax if the IRB

had not been issued and the IIFP property had, consequently, been subject to property tax. Property value

in Lea County is assessed on one-third of book value. The property tax rate for school entities used to

determine the amount of payment that IIFP would make in lieu of property school tax and the amount of

annual property tax estimated for the Phase I Facility and the cumulative Phase 2 Facility are provided in

responses to RAI 3.c and RAI 3.e.

Environmental Report Documentation Impact: None.

Environmental Report Request for Additional Information (RAI 3) Page 27
Official Responses to Environmental Report RAIs

RAI 3

Provide additional information regarding taxes during construction and operation of the International

Isotopes Fluorine Products, Inc. (IIFP) facility.

b. Sections 2.2, "Alternatives for Site Selection, " 7.1.2, "Basis of Construction and Operating

Costs-Benefit Estimates for the Proposed Action, " and 7.1.5. 7, "Insurance and Taxes" of the ER

(IIFP, 2009a) state that the State of New Mexico and Lea County both have an incentive package

that would exempt this facility from property and local taxes. Provide more details about this

package, including whether it is final and what, if any, taxes are owed to the State and County.

The above tax payment information will be needed to quantitatively evaluate the impacts of construction

and operations property tax payments for the EIS socioeconomics analysis. This is important to clarify

because payments made to local taxing entities can be considered large in comparison to other local

municipality tax revenues, and can therefore be a significant factor in the socioeconomic impact analysis.

RESPONSE: The discussion of tax incentive agreements that are in place and property tax estimates are

provided in response to RAls 3.a, 3.c and 3.e. Other potential tax credit incentives may be available after

the IIFP Facility is built and operational, but for purposes of the Environment Report, these are not final

and not used in calculating tax exemptions in the cost-benefit analysis impact.

Environmental Report Documentation Impact: Paragraph 2 of Section 7.1.5.7 of the IIFP

Environmental Report Revision A has been revised to explain applicable property tax exemptions and to

show the taxes by Phase 1 and Phase 2 Facility operations. This change is shown in the Environmental

Report Documentation Impact response to RAI 3.e.

Environmental Report Request for Additional Information (RAI 3) Page 28
Official Responses to Environmental Report RAIs

RAI 3

Provide additional information regarding taxes during construction and operation of the International

Isotopes Fluorine Products, Inc. (IIFP) facility.

c. Provide estimated property tax payments including those paid on land and everything attached to

the land and property taxes on company equipment and material during preconstruction and

construction.

The above tax payment information will be needed to quantitatively evaluate the impacts of construction

and operations property tax payments for the EIS socioeconomics analysis. This is important to clarify

because payments made to local taxing entities can be considered large in comparison to other local

municipality tax revenues, and can therefore be a significant factor in the socioeconomic impact analysis.

RESPONSE:

Property taxes are generally exempt as part of the Lea County, New Mexico incentive package and the

issued Industrial Revenue Bond (IRB) agreement that IIFP has with Lea County as previously discussed

in response to RAI 3.a. Two school districts are not exempt by the IRB; the Hobbs Municipal School

District and the New Mexico Junior College. For this "non-exempt" property tax, the IRB provides that

IIFP pay in lieu of the property tax an amount equal to the amount of property taxes that IIFP would have

been required to pay if the IRB had not be issued and the project property had, consequently, been subject

to property taxation. Property taxes in Lea County are assessed on one-third of the book value of tangible

property and the tax rate for the two non-exempt school district property taxes. The annual payment to the

Hobbs Municipal School District is based on $7.60 tax rate per $1000 of assessed property value. The

annual payment to the New Mexico Junior College is based on a tax rate of $4.30 per $1000 of assessed

property value. Based on the estimated assessed value of the IIFP land and attachments to the land and on

the equipment and materials and the estimated tax rate, the estimated property taxes during

preconstruction and construction of the IIFP Facility are provided below.

Table RAI 3-c Estimated Property Taxes for the IIFP Facility During Phase 1

Year Activity Tax on Land & Attachments Property Tax on Equipment and

Materials

2011 Preconstruction $ 15,900 $ 22,700

2012 Phase I Construction $ 87,800 $ 173,200

2013 Continued Phase 1 $ 46,500 $ 246,900

Construction

Future Future construction

Years (such as the expansion

to Phase 2) would occur

in the years of

operations and is

included in the annual

property taxes of the

operating facility

Environmental Report Documentation Impact: None.

Environmental Report Request for Additional Information (RAI 3) Page 29
Official Responses to Environmental Report RAls

RAI 3

Provide additional information regarding taxes during construction and operation of the International

Isotopes Fluorine Products, Inc. (IIFP) facility.

d. Identify the taxing entities including the two educational entities, as stated in Section 7.1.5. 7,

"Insurance and Taxes, " of the ER (IIFP, 2009a), that would tax the plant and what percentage of

the payments would be sent to each entity. (Examples of taxing entities include state, county,

municipality, local schools/colleges, and independent irrigation districts.)

The above tax payment information will be needed to quantitatively evaluate the impacts of construction

and operations property tax payments for the EIS socioeconomics analysis. This is important to clarify

because payments made to local taxing entities can be considered large in comparison to other local

municipality tax revenues, and can therefore be a significant factor in the socioeconomic impact analysis.

RESPONSE:

The entities that require tax payments are the Federal government, State of New Mexico, and Lea County

New Mexico. Additionally, in lieu of exempt property taxes as discussed in to response to RAI 3.a above,

IIFP will make annual payments to the Hobbs Municipal School District and the New Mexico Junior

College.

The IIFP employer's part of social security and Medicare employment taxes will be paid at the Federal

rate; currently 6.2 per cent of the first $106,800 of earnings per employee for social security and 2.9% of

each employee's total annual earnings for the Medicare tax. Also, IIFP will pay New Mexico

unemployment tax at a rate of 5.4% on the first $21,900 of each employee's earnings. The Federal

unemployment tax rate will be 0.8% on the first $7,000 of each employee's earnings. The cost for these

payroll related taxes are included in the estimated overhead rates of the annual labor cost estimates.

Property taxes are generally exempt as part of the Lea County and State of New Mexico site incentive

package as discussed in response to RAI 3.a. Two educational local school taxes are not part of the

exemption. As shown in the revised Table 7-11 below, the payments in lieu of property taxes are about

4.2% of the total tax revenues estimated to benefit the State and Lea County. Of that payment amount,

about 64% will be distributed to the Hobbs Municipal School District and the remaining 36% will be

distributed to the New Mexico Junior College. The annual estimate of those taxes is based on a formula

and information provided by Lea County. Those annual property taxes are explained in response to RAI

3.e and discussed in the revision being made to the Paragraph 2 of Section 7.1.5.7 of the IIFR

Environmental Report as shown in the RAI 3.e response. Table 7-11 provides the estimated tax revenues

to Lea County and the State of New Mexico for Phase 1, increment of expansion to a Phase 2 Facility and

the cumulative facility taxes totaled for the 40-year life of the IIFP Facility.

Corporate income taxes for the IIFP Facility operations are calculated on an average federal rate of 35%

of taxable income plus the State of New Mexico income tax of 7.5% of taxable income. The State income

taxes are credited as being an offsetting expense on federal taxes. Approximately, 47.5% of the State and

Lea County total tax revenue (shown in Table 7-11) from the IIFP Facility is corporate income tax to the

State.

Environmental Report Request for Additional Information (RAI 3) Page 30
Official Responses to Environmental Report RAIs

The Gross Revenue Tax represents about 48.35% of the total tax from IIFP and is distributed 93% to the

State of New Mexico and the remaining 7% to Lea County, as shown in Table 7-11 below.

Environmental Report Documentation Impact: The original Table 7-11 of the IIFP Environmental

Report Revision A is being deleted and replaced with the new Table 7-11 below to show tax revenues to

the State and Local Community by type and IUFP Facility operational phases.

Table 7-11 Estimated Tax Revenues to State and Local Community for Total 40-Year Period

(Expressed in Thousands of Dollars in Year 2009S)

New_______ Mexico _ LeaNew Mexico Lea County Cumulative

Type ofNew Mexico Lea County Phase 2 Phase 2 Phase I and 2

Increment Increment Total

Gross Receipts Tax

High Estimate t118.100 8.800 165.400 I 12400 304,700

Low Estimate 87.100 6.500 121.900 9100 224,600

NM Corp. Income Taxb

High Estimate 77.200 N/Ae 222.400 N/Ac 299,600

Low Estimate 57,100 N/A' 164.300 N/AC ý221400

Property Tax

High Estimate Note "d" _I Note "d" 12_700 2_4(0

Low Estimate Note "d" 8,700 Note "d" 8,100 16.800

TOTALTAX 144.200- 15.200- 286,200- 17.200- 462.800-

ESTIMATE 195.300 22,00 387.800 25,100 0700

RANGE .....

"Based on Average Earnings over the 40-Yr Analysis Period for the Proposed ll[If Facility

'Allocaiion would be made to the State of New Mexico

Pay m, e s in lieum 01' r~rorfelv Ins is di strihi ted to school lax lifr Hobbmhs Mi incmiii District and1New Mexico .h mmmioir (Ci olee

" Pavinents in lieu ofnroneitv tax is distributed to school tax lor I lobbs Municipal Distrio andNew 1VlCXjC0 JUJuOr COllefe

Environmental Report Request for Additional Information (RAI 3) Page 31
Official Responses to Environmental Report RAIs

RAI 3

Provide additional information regarding taxes during construction and operation of the International

Isotopes Fluorine Products, Inc. (IIFP) facility.

e. Provide estimated property tax payments including those paid on land and everything attached to

the land and property taxes on company equipment and material during operations.

The above tax payment information will be needed to quantitatively evaluate the impacts of construction

and operations property tax payments for the EIS socioeconomics analysis. This is important to clarify

because payments made to local taxing entities can be considered large in comparison to other local

municipality tax revenues, and can therefore be a significantfactor in the socioeconomic impact analysis.

RESPONSE:

Property taxes are generally exempt as part of the Lea County, New Mexico incentive package and the

issued Industrial Revenue Bond (IRB) agreement that IIFP has with Lea County as previously discussed

in response to RAI 3.a. Two school districts are not exempt by the IRB; the Hobbs Municipal School

District and the New Mexico Junior College. For this "non-exempt" property tax, the IRB provides that

IIFP pay in lieu of the property tax an amount equal to the amount of property taxes that IIFP would have

been required to pay if the IRB had not be issued and the project property had, consequently, been subject

to property taxation. Property taxes in Lea County are assessed on one-third of the book value of tangible

property and the tax rate for the two non-exempt school district property taxes. The payment to the Hobbs

Municipal School District is based on a tax rate of $4.30 per $1000 of assessed property value. The

annual payment paid to the New Mexico Junior College is based on a tax rate of $7.60 per $1000 of

assesses property value. Based on the estimated assessed value of the IIFP land and attachments to the

land and on the equipment and materials and the estimated tax rate, the estimated property taxes during

the operating periods of the IIFP Facility are provided below:

The estimated annual property taxes for the IIFP Facility during the operations period are discussed in

paragraph 7.1.5.7 of the IIFP Environmental Report. This paragraph is being updated as explained below.

Environmental Report Documentation Impact: Paragraph 2 of Section 7.1.5.7 of the IIFP

Environmental Report Revision A has been revised to update estimates of property taxes and to show a

break out of the taxes by Phase 1 and Phase 2 Facility operations.

Property and local taxes are generally exempt as part of the Lea County and State of New Mexico site

incentive package and the Industrial Revenue Bond ORB) issuance that IlFP has with Lea County New

Mexico. Ther-e a..e two educational local school taxes that a.. not prt of !he exemption.- Two school

districts are not exempt by the IRB: the Hobbs Municipal School District and the New Mexico Junior

College. For this "non-exempt" property tax. the IRB provides that IIFP pay in lieu of the property tax an

amount equal to the amount of property taxes that IIFP would have been required to pay if the [RB had

not be issued and the project property had. consequently, been subject to property taxation. The annual

estimate of those property taxes is based on a formula and information provided by Lea County. The

property taxes (payments in lieu of) are estimated at an average of$217,500-$342,500 annually during

the Phase 1 Facility operations period and $420.000-$660.000 annually for the Phase 2 Facility operations

(the combined integrated Phase I and Phase 2 Facilitv.y$350,000 annually for the total Phase I and Phas.e

2 f:edlit.

Environmental Report Request for Additional Information (RAI 3) Page 32
Official Responses to Environmental Report RAIs

RAI 4

Provide clarifications and additional data for the cost-benefit analysis.

a. Clarify whether replacement capital costs are construction or operations costs. Although

replacement capital covers activities that are similar to construction, these activities occur after

2017, and thus would occur during the operations phase of the project. Chapter 7, "Cost-Benefit

Analysis" of the ER (IIFP, 2009a) presents replacement capital as construction.

The information in Chapter 7, "Cost-Benefit Analysis, " of the ER (IIFP, 2009a) either needs clarification

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the

EIS.

RESPONSE:

Replacement costs are capital costs that occur during the facility operations period in order to replace

equipment, materials and infrastructure as needed to maintain the IIFP in a safe and reliable condition. As

such, those replacement costs are considered as operation capital costs rather than facility construction

costs. Replacement capital is estimated and expended as a cash flow in the year(s) in which equipment or

infrastructure is being replaced.

In addition to replacement capital, annual expenses for maintenance material are required for repair and

normal maintenance of equipment and infrastructure. These annual maintenance material costs are

estimated at about 3% to 5% of the facility direct capital cost. Operating supplies are also included in this

category. Operating supplies, for example, include items such as gloves, personnel safety items, office

supplies, lab chemicals, lubricating oils, custodial supplies, etc. Annual operating supplies are estimated

at about 0.75% to 1.2% of the direct capital costs.

Environmental Report Documentation Impact: The first two paragraphs of Section 7.1.5.4 of the IIFP

Environmental Report Revision A is being updated as follows:

Material required for repair and normal replacement of equipment and infrastructure is estimated at 3% to

5% of the plant direct capital cost not including engineering procurement and construction management

costs or contingency. Additionally, replacement capital is estimated and expended as a cash flow in the

year in which the equipment or infrastructure would be replaced. Replacement costs are capital costs that

occur during the facility operations period in order to replace equipment, materials and infrastructure as

needed to maintain the IIFP in a safe and reliable condition. As such. those replacement costs are

considered as operation (capital) costs rather than facility construction costs.

Operating supplies are also included in this category. Operating supplies, for example, include items such

as gloves, personnel safety items, office supplies, lab chemicals, lubricating oils, custodial supplies, etc.

Operating supplies are estimated at 0.75% to 1.25% of the direct capital costs. These percentages are

based on published cost methodology data and experiences at similar facilities (Timmerhaus, Peters and

West, 2003b).

Environmental Report Request for Additional Information (RAI 4) Page 33
Official Responses to Environmental Report RAIs

RAI 4

Provide clarifications and additional data for the cost-benefit analysis.

b. Provide an estimate of the distribution of replacement expenditures over/between Phase 1 and the

Phase 2 increment.

The information in Chapter 7, "Cost-Benefit Analysis, " of the ER (IIFP, 2009a) either needs clarification

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the

EIS.

RESPONSE: Table 7-5 of the IIFP Environmental Report Revision A will be revised to show the refined

updated replacement capital cost estimate. All of the estimated replacement capital costs over the 40 year

analysis period occur after the expansion of the Phase 1 Facility to the Phase 2 Facility (the Phase I plus

the add on expansions that result in the combined facility, that is the Phase 2 Facility). All of the

replacement occurs during the time of the Phase 2 Facility operation because Phase 1 operates only about

3-4 years before the expansions are completed that result in the Phase 2 cumulative facility operation.

During the time frame between 2017 and 2050, approximately 51% of the replacement capital cost is

related to equipment and infrastructures that were installed in the Phase I construction. The remaining

49% of replacement costs are for the incremental equipment and infrastructures that were installed in the

expansion to a Phase 2 Facility. Thus, the average annual replacement cost distributed to the Phase I

initial equipment/infrastructure is about 1-1.2 million dollars and that for the incremental equipment and

infrastructure for expansion to the Phase 2 Facility is approximately 0.9-1.2 million dollars per year.

Environmental Report Documentation Impact: Table 7-5 of the IIFP Environmental Report Revision

A is revised to read as follows:

Table 7- 5 Estimated Replacement Capital

Time Period of Replacement Cost Projected to Range of Estimated Replacement Costsi•.

be Incurred~ (Millions of $)(xrsg ný ý'Dolas

Years 2010 through 2016 (Phase I Operation only No replacement capital; all is estimated initial capital

until late 2016)

2017-2027 (Phase I + Phase 2 Operation) 9-14 9-1 1

2028-2037 (Phase 1 + Phase 2 Operation) 2-8-6 35-43

2038-2050 (Phase 1 + Phase 2 Operation) 223- 3 2-39

Total 40 Year Analysis Period 60-8-5 76-93

Environmental Report Request for Additional Information (RAI 4) Page 34
Official Responses to Environmental Report RAIs

RAI 4

Provide clarifications and additional data for the cost-benefit analysis.

c. Provide the cost of raw materials. Section 7.1.5.1, "Raw Materials ", of the ER (IIFP, 2009a)

does not present the cost of raw materials, other than that they are "low. "

The information in Chapter 7, "Cost-Benefit Analysis, " of the ER (IIFP, 2009a) either needs clarification

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the

EIS.

RESPONSE: The FEP and De-conversion processes have a relatively low raw materials cost for a

chemical plant. The fluoride value in the FEP and AHF products comes from extracted fluorine of the

waste uranium enrichment customer tails material. The extracted fluoride from DUF6 is the major raw

material of the FEP process. As a raw material, it effectively has a negative cost because IIFP is paid a

service fee (revenue) for the de-conversion of DUF 6.

Raw material usages were determined from process flow sheets and mass balance calculations for each

respective process. Raw material and treating agent unit costs were obtained from vendors and supplier

budget-type quotes for purposes of the economic analyses. Some factors were applied in consideration of

the estimated efficiencies of utilization as opposed to theoretical stoichiometry. Annual costs were

derived for each production case by using the unit cost and production volumes.

Table 7-6, "Major Raw Materials and Treating Agents," will be revised to provide unit cost for the major

raw materials and treating agents. The raw material and treating agent costs for the Phase 1 Facility are

estimated to be $1.89 million (yr-2009$) per year. The Phase 2 Facility (cumulative of Phase I and

expansion to the Phase 2 Facility) raw material and treating agent costs are estimated to be $2.71 million

annually.

Environmental Report Documentation Impact: Table 7-6 from the Environmental Report Section

7.1.5.1, "Raw Materials," will be revised to add the unit costs for the raw materials. Table 7-6 will read as

follows:

Table 7- 6 Major Raw Materials and Treating Agents

Raw Material~or Un itI Cst(s I

. .. rr.. . A .g e n t 2 0 0 9 U S $; C om m en ts..

Silicon dioxide (Si02) $ pound Alternative to be evaluated in pilot test. Diatomaceous earth of much

less unit cost is an option contingent on the product purity tests.

Boric Oxide (BzO 3) $1 .501pound Used in production of BF3 product.

Calcium Hydroxide $0.06!pound Used in hydrated lime treatment of process water to regenerate KOH

[Ca(OH)2] and neutralize small amounts of aqueous HF wastes

Treating agent bought as a 45% solution and used in scrubbing

Potassium Hydroxide emissions from process off-gas vents. The agent is regenerated and

(KOH) $ precycled to avoid process water discharges and to minimize usage.

Small make-up is required.

Hydrogen-gaseous $1.751100 cubic feet Estimates for economic analysis obtained from vendor quotes

(H2) I assuming that supply would come from a on-site packaged system.

Environmental Report Request for Additional Information (RAI 4) Page 35
Official Responses to Environmental Report RAIs

RAI 4

Provide clarifications and additional data for the cost-benefit analysis.

d. Provide the utilities cost for Phase 1 and an incremental amount for Phase 2. Section 7.1.5.2,

"Utilities, " of the ER (IIFP, 2009a) presents costs for operations utilities. The text states that

Phase 2 operations add significantly to Phase ] utilities cost. The value of 2.5 to 3.5 million

dollars per year is provided, but it is not clear for which phase this value applies.

The information in Chapter 7, "Cost-Benefit Analysis, " of the ER (IIFP, 2009a) either needs clarification

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the

EIS.

RESPONSE: The last paragraph of Section 7.1.5.2 will be revised to provide separate estimated annual

cost of utilities for Phase 1 only and the Phase 2 (combined Phase 1 plus expansion to Phase 2) Facilities.

The type of utilities are the same for the Phase I and Phase 2 Facility, but there is a significant increase in

usage of utilities amounts beginning in about 2016, especially in steam and electricity, for the integrated

Phase 2 Facility after the Oxide plant add-on.

Environmental Report Documentation Impact: The Environmental Report, Section 7.1.5.2,

"Utilities," will be revised to show updated utility costs Phase I and Phase 2 operations and the last two

paragraphs of the Section will read as follows:

The type of utilities are the same for the Phase 1 and Phase 2 Facility, but there is a significant increase in

usage of utilities amounts beginning in about 2016, especially in steam and electricity, for the integrated

Phase 2 Facility after the Oxide plant add-on.

A.pp...iately 2.5 •ea to 3.3 million dollars per- 4.f utilities are estimated to be precured f..om tilit;

Iom .aioes ated in !he r~egion of State thereby benefiting the local and State economie

Approximately 1.5 million dollars (2009$) per year of utilities are estimated to be procured during the

Phase I Facility operations each year between 2013 and the beginningY of 2017. An additional 1.7 million

dollars (2009$) per year of utilities are estimated to be procured each year from 2017 through 2050 as a

result of the expansion to the Phase 2 Facility. After the expansion to Phase 2, the cumulative utilities

procured will cost about 3.2 million dollars (2009$) each year firom utility companies located in the

reclion or State thereby benefitine the local and State economies.

Environmental Report Request for Additional Information (RAI 4) Page 36
Official Responses to Environmental Report RAls

RAI 4

Provide clarifications and additional data for the cost-benefit analysis.

e. Provide sufficient data to quantify the sales and distribution annual costs for Phase 1 and Phase

2 increment. Section 7.1.5.3, "Selling and Distribution, " of the ER (IIFP, 2009a) states, "The

sales and distribution annual costs ... are estimated at 8% of the projected product cost. " It is

not clear what the value of the "projected product cost" is.

The information in Chapter 7, "Cost-Benefit Analysis, " of the ER (IIFP, 2009a) either needs clarification

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the

EIS.

RESPONSE: The subject sales and distribution annual costs apply only to the high purity SiF4 product.

There is no direct selling of the de-conversion services, other than agreements and contracts arranged

between IIFP and suppliers/customers. Likewise the BF 3 product and AHF by-product are sold in bulk

quantities by contract agreements to a relatively small number of customers, thus the sales and marketing

cost are minimal and absorbed in the product unit pricing. The added 8% sales and distribution is applied

to the SiF 4 because it is packaged and sold in smaller quantities to several customers thus requiring more

marketing effort and incurring more direct distribution costs.

The annual cost for the sales and distribution costs is estimated to be $200,000 to $250,000 based on

year-2009$. There is essentially no difference in selling and distribution costs of the Phase 1 and future

Phase 2 Facility cumulative costs because the amount of SiF 4 production does not increase by the

expansion to a Phase 2 Facility

Environmental Report Documentation Impact: None.

Environmental Report Request for Additional Information (RAI 4) Page 37
Official Responses to Environmental Report RAIs

RAI 4

Provide clarifications and additional data for the cost-benefit analysis.

f Provide a breakdown of operations and maintenance materials costs for Phase I and Phase 2

increment. Section 7.1.5.4, "Operational and Maintenance Materials, " of the ER (IIFP, 2009a)

states that the average cost of maintenance materials and operating supplies are 3 to 4 million

dollars annually, but the distinction between Phase 1 and Phase 2 is not clear.

The information in Chapter 7, "Cost-Benefit Analysis, "of the ER (JJFP, 2009a) either needs clarification

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the

ElS.

RESPONSE: The Phase I Facility annual maintenance material costs and operating supplies costs are

estimated at 2.1million dollars (in yr-2009$) and 0.63 million dollars (in yr-2009$), respectively. Those

annual costs increase for the incremental expansion to a Phase 2 Facility by $1.2 million per year for

maintenance materials and by $0.36 million per year for operating supplies. The cumulative Phase 1 and

Phase 2 Facility annual maintenance material costs are estimated to be $3.3 million and the annual

operating supplies costs are estimated to be $0.99 million. All these costs are expressed in year-2009$.

Environmental Report Documentation Impact: None.

Environmental Report Request for Additional Information (RAI 4) Page 38
Official Responses to Environmental Report RAIs

RAI 4

Provide clarifications and additional data for the cost-benefit analysis.

g. Clarify Phase 1 and Phase 2 incremental costs for waste disposal. Table 7-10, "Estimated Range

ofAnnual Waste Disposal Costs, " of the ER (IIFP, 2009a) presents the annual waste disposal

costs for Phase 1 and Phase 2, but from the values, it seems that the Phase 2 column is the

cumulative Phase 1 and 2 waste disposal costs. If the Phase 2 costs are cumulative of Phase 1

and 2, then so state.

The information in Chapter 7, "Cost-Benefit Analysis, "of the ER (IIFP, 2009a) either needs clarification

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the

EIS.

RESPONSE: Phase 2 costs are cumulative of Phase I and Phase 2 costs because the Phase 2 facility

results from an expansion of the Phase 1 Facility.

Environmental Report Documentation Impact: Table 7-10 and its introduction in Section 7.1.5.6 of

the IIFP Environmental Report Revision A will be changed to read as follows:

Table 7-10 provides a range of estimated waste disposal costs by type of waste. The Phase 2 costs are

cumulative of Phase I and Phase 2 costs because the Phase 2 Facility results fioom an expansion of the

Phase I Facility.

Table 7- 10 Estimated Range of Annual Waste Disposal Costs

Phase I and Phase 2 Facility

Type Waste Phase 1 Facility (cumulative)

(Thousand of $ Per Year in 2009$) (Thousands of $ Per Year in

2009$)

Depleted uranium oxide 2,600 -4-500 6.970 8,000-4-4-04 22.500

Other process LLW 4 -,A00 ,-T,0 250-400 4-,4- 1,,,,80 260-450

Misc. LLW 225-350 450-650

RCRA 9-22 9- 3) 5 14-45

Sanitary 42-____33 4-2-2-3

Environmental Report Request for Additional Information (RAI 4) Page 39
Official Responses to Environmental Report RAls

RAI 4

Provide clarifications and additional data for the cost-benefit analysis.

h. Provide 2010 market value per pound of each Fluorine Extraction Process product.

The information in Chapter 7, "Cost-Benefit Analysis, " of the ER (IIFP, 2009a) either needs clarification

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the

EIS.

RESPONSE: Product market prices (in yr-2010$) of $30 per pound and $10 per pound are used for highpurity SiF 4 and for BF 3, respectively. The de-conversion service fees are expected to range from $ 2.40

per pound DUF 6 de-converted, where oxide disposal costs are paid (pass-through cost) by the customer,

to $3.95 per pound where oxide disposal costs are not a pass-through cost to the customer. De-conversion

costs are expressed in year-20 10$. For purposes of the Environmental Report cost-benefit calculations,

IIFP used a $3.85 (yr-2009$) per pound DUF 6 estimated fee because oxide disposal costs are included in

the cost-benefit information provided in the Environmental Report (See line item #1 of Table 7-10 in the

report).

Environmental Report Documentation Impact: None.

Environmental Report Request for Additional Information (RAI 4) Page 40
Official Responses to Environmental Report RAls

RAI 5

Provide clarifications and additional information regarding U0 2 shipments.

a. Clarify the packaging and number ofpackages per shipment for U02 byproduct material. Section

3.2.2.2, "Facility Operation Phase, " of the ER (IIFP, 2009a) states that low-level radioactive

waste (LLW) will be shipped in 55-gallon drums, with 20-25 drums per shipment. State whether

these drums will contain the U0 2 byproduct from the deconversion process, and whether the LL W

discussed in Section 3.2.2.2 "Facility Operation Phase" is the U0 2 byproducts from the

deconversion process. If not, describe the packaging and truck loading for U02 and describe the

material that is considered LL W referred to in Section 3.2.2.2 "Facility Operation Phase. "

The ER (IIFP, 2009a) provides scaled informationfrom other analyses, but it does not present sufficiently

detailed information for a project-specific analysis. The requested data above are necessary to perform a

radiological consequence analysis with the computer code, RADTRAN, for the IIFP project in order to

assess the associated transportation impacts in the EIS.

RESPONSE: Packaging will be in DOT-approved containers that meet the requirements of 40 CFR 71

(CFR, 2009m) and 49 CFR 171-173 (CFR, 2009hh; CFR, 2009ii). The exact amount (poundage) to be

included in a container will depend on the bulk density of the material being shipped such that the number

of containers in the shipments will meet the DOT load requirements. All LLW will be disposed of off

site, at a licensed burial site, including uranium oxides produced from the deconversion process.

For number of packages per shipment of each type of low-level wastes, see the Environmental Report

Documentation Impact for RAI 5-e.

Environmental Report Documentation Impact: The I" paragraph of Section 3.2.2.2, "Facility

Operations Phase," subheading "Uranium Wastes" will be revised to provide this clarification and will be

revised to read as follows:

Uranium Wastes

Radioactive waste materials will be transported in packages by truck via highway in accordance with 40

CFR 71 (CFR, 2009m) and 49 CFR 171-173 (CFR, 2009hh; CFR, 2009ii). Detailed descriptions of

radioactive waste materials which will be shipped from the IIFP facility for disposal are presented in ER

Section 3.12, "Waste Management." These wastes will typically be packaged and shipped in 55-gal

drums using t..ucks with a nominal 20 to 25 d.,ams. per truck shipmeHt. The exact amount (poundage) to

be included in a container will depend on the bulk density of the material being shipped such that the

number of containers in the shipments will meet the DOT load requirements. All LLW will be disposed

of off site. at a licensed burial site, includin, depleted uranium oxides produced from the deconversion

process.

Environmental Report Request for Additional Information (RAI 5) Page 41
Official Responses to Environmental Report RAIs

RAI 5

Provide clarifications and additional information regarding U0 2 shipments.

b. Provide the radionuclide inventory (in curies) of each package of U0 2 and the expected dose rate

at contact, 1 meter, and 2 meters.

The ER (IIFP, 2009a) provides scaled information from other analyses, but it does not present sufficiently

detailed information for a project-specific analysis. The requested data above are necessary to perform a

radiological consequence analysis with the computer code, RADTRAN, for the IIFP project in order to

assess the associated transportation impacts in the EIS.

RESPONSE: Table RAI 5-e-1 will be used in the review and modeling for incident-free transport of

radioactive material. Table 4-4, "Annual Incident-Free Transportation Radiological Dose to the Public

and Worker," will be updated for the uranium oxide and miscellaneous LLS shipments.

Table RAI 5-e-1, Shipments of Miscellaneous Low-Level Waste

Material Depleted Expcted Dose Rates

Waste Material Mass Uranium Curies D

(lb/drum) Mass (Ci/drum) Contact 1 meter 2 meters

(Ib/drum) (lb/drum)

Activated Alumina 98 4.9 8.00 E-04 6.19E-02 6.35E-03 2.03E-03

AirVentilation 14 0.28 4.57 E-05 3.72E-03 3.78E-04 1.21E-04

Filters

Carbon 350 7 1.14 E-03 6.18E-02 6.46E-03 2.04E-03

Clinkers of DUF 4 1,000 750 1.22 E-01 1.55E+00 1.64E-01 5.05E-02

Coke 140 1.4 2.29 E-04 1.71E-02 1.77E-03 5.63E-04

Contaminated 210 2.1 3.43 E-04 2.32E-02 2.41E-03 7.65E-04

Pallets

Crushed Drums 392 3.9 6.37 E-04 2.55E-02 2.65E-03 8.33E-04

Dust Collector Das 

Bags 70 10.5 1.71 E-03 1.38E-01 1.41E-02 4.52E-03

Ion Exchange Resin 343 10.3 1.68 E-03 8.58E-02 8.99E-03 2.84E-03

Radioactive Waste 70 0.7 1.14 E-04 9.25E-03 9.45E-04 3.02E-04

Trash

Scrap Metal 392 3.9 6.37 E-04 2.55E-02 2.65E-03 8.33E-04

Sintered Metal 700 7 1.14 E-03 3.71E-02 3.92E-03 1.22E-03

Tubes

Sodium Fluoride 679 6.8 1.11 E-03 1.99E-02 2.08E-03 6.47E-04

Spent Blasting Grit 1,000 50 8.16 E-03 1.94E-01 2.07E-02 6.39E-03

Uranium Oxide 1,000 881.48 1.44E-01 1.83E+00 1.93E-01 5.95E-02

Reference: DOE-STD-1 136-2009, Section 2.5

Curies/drum = (pounds DU per drum) x (453.59 gram/pound) x (3.6E-7 Curies/gram)

Environmental Report Request for Additional Information (RAI 5) Page 42
Official Responses to Environmental Report RAls

Environmental Report Documentation Impact: Remove Chapter 4 of the Environmental Report,

Revision A in its entirety and replace with the revised Chapter 4 that will be provided in a separate

document as part of the official RAI ER response package. Table 4-4, "Annual Incident-Free

Transportation Radiological Dose to the Public and Worker," will be revised based on these shipments of

depleted uranium oxide and miscellaneous low-level wastes shown in Table 3-2, "Shipments Based on

Estimated Annual Quantities of Low Level Waste Generated at the IIFP Facility." See Environmental

Report Documentation Impact for ER RAI-5e.

Environmental Report Request for Additional Information (RAI 5) Page 43
Official Responses to Environmental Report RAIs

RAI 5

Provide clarifications and additional information regarding U0 2 shipments.

c. Clarify the number of shipments of U02. In the ER, Table 4-4, "Annual Incident-Free

Transportation Radiological Dose to the Public and Worker, "states that there will be 450

shipments of uranium oxide and miscellaneous LLW.

The ER (IIFP, 2009a) provides scaled information from other analyses, but it does not present sufficiently

detailed information for a project-specific analysis. The requested data above are necessary to perform a

radiological consequence analysis with the computer code, RADTRAN, for the IIFP project in order to

assess the associated transportation impacts in the EIS.

RESPONSE:

The DOT maximum axle net-load limit is approximately 42,000 pounds. Density of the uranium oxide is

approximately 2.5g/cc or 156 lb/ft3. Drums can be filled to approximately 1,000 lb per drum plus 50 lb

drum weight or a total 1,050 lb/drum of U0 2 Shipments of UO 2 will be expected to contain

approximately 40 drums. Assuming consistent bulk density and 40 drums per shipment then Phase 1 U0 2

shipments will be approximately 145-155. Other LLW materials will not be bulk density consistent,

therefore, bulk density will be much smaller and trailers will be space limited or volume limited, not

weight limited. In Phase 2 (Phase 1 plus the expansion) operations, DUO 2 total shipments are

approximately 450-500 annually.

Environmental Report Documentation Impact: Remove Chapter 4 of the Environmental Report,

Revision A in its entirety and replace with the revised Chapter 4 that will be provided in a separate

document as part of the official RAI ER response package. Section 4.2.8.2, "Radioactive Treatment and

Packaging Procedure," will be revised to provide this clarification. Section 4.2.8.2 will read as follows:

4.2.68.2 Radioactive Treatment and Packaging Procedure

Specific handling of radioactive and mixed wastes is discussed in detail in ER Section 3.12, "Waste

Management." Packaging of product material, radioactive waste and mixed waste will be in accordance

with f•-a+A-faci itvimplementation procedures that follow 10 CFR 71 (CFR, 2009m) and 49 CFR 171-173

(CFR, 2009hh; CFR, 2009ii). Depleted UF6 shipments will have additional packaging controls in

accordance with ANSI N 14.1 (ANSI, 2001). Waste materials will have additional packaging controls in

accordance with each respective disposal or processing site's acceptance criteria (CFR, 2009m). The DOT

maximum axle net load limit is approximately 42.000 pounds. Density of the depleted uranium oxide is

approximately 2.5g/cc or 156 lb/tf'. Drums can be filled to approximately 1,000 lb per drum plus 50 lb

drum weight or a total 1.050 lb/drum of DUO,. Shipments of DUO, will be expected to contain

approximately 40 drums. AssuLine consistent bulk density and 40 drums per shipment then Phase 1

DUO, shipments will be approximately 145 to 155 annually. In Phase 2 operations, DUO, total shipments

are approximately 450-500 annuia ly.

Other LW materials will not be bulk density consistent, therefore, bulkl density will be much smaller and

trailers will be space limited or volume limited, not weight limited. These LIW materials will include:

Environmental Report Request for Additional Information (RAI 5) Page 44
Official Responses to Environmental Report RAls

* Activated Alumina,

* Activated Carbon

* Air Ventilation Filters,

" Carbon,

" Clinkers of DUF 4.

* Coke.

• Contaminated Pallets.

" Crushed Drums,

" Dust Collector Bags.

* Ion Exchange Resin,

* Radioactive Waste Trash,

• Scrap Metal.

* Sintered Metal Tubes,

* Sodium Fluoride, and

* Spent Blasting Sand/Grit.

Environmental Report Request for Additional Information (RAI 5) Page 45
Official Responses to Environmental Report RAIs

RAI 5

Provide clarifications and additional information regarding U0 2 shipments.

d. Clarify if each of the 450 shipments contains 20-25 drums of U02 per shipment.

The ER (IIFP, 2009a) provides scaled information from other analyses, but it does not present sufficiently

detailed information for a project-specific analysis. The requested data above are necessary to perform a

radiological consequence analysis with the computer code, RADTRAN, for the IIFP project in order to

assess the associated transportation impacts in the EIS.

RESPONSE:

The DOT maximum axle load limit is net 42,000 pounds. Density of the uranium oxide is approximately

2.5g/cm 3 or 156 lb/ft3. Drums can be filled to approximately 1,000 lb/drum plus 50 lb-drum weight or a

total 1,050 lb/drum of DUO 2. Shipments of DUO 2 are expected to contain approximately 40 drums.

Assuming consistent bulk density and 40 drums per shipment then Phase 1 DUO 2 shipments will be

approximately 145-155. In Phase 2 integrated operations, DUO2 total shipments are approximately 450-

500. Other LLW materials will not be bulk density consistent, therefore, bulk density will be much

smaller and trailers will be space limited or volume limited, not weight limited.

Environmental Report Documentation Impact Remove Chapter 4 of the Environmental Report,

Revision A in its entirety and replace with the revised Chapter 4 that will be provided in a separate

document as part of the official RAI ER response package. See Environmental Report Documentation

Impact for ER RAI 5-c for the revision of Section 4.2.8.2, "Radioactive Treatment and Packaging

Procedure."

Environmental Report Request for Additional Information (RAI 5) Page 46
Official Responses to Environmental Report RAls

RAI 5

Provide clarifications and additional information regarding U0 2 shipments.

e. Describe the shipment of "miscellaneous LLW" in terms of types ofpackages, number of

packages, and curie content.

The ER (IIFP, 2009a) provides scaled information from other analyses, but it does not present sufficiently

detailed information for a project-specific analysis. The requested data above are necessary to perform a

radiological consequence analysis with the computer code, RADTRAN, for the IIFP project in order to

assess the associated transportation impacts in the EIS.

RESPONSE: Table RAI 5-e-1 will be used in the review and modeling for incident-free transport of

radioactive material. Table 4-4, Annual Incident-Free Transportation Radiological Dose to the Public and

Worker will be updated for the uranium oxide and miscellaneous LLS shipments. Section 3.2.2.2,

"Facility Operations Phase," will be revised to show the shipments of low-level wastes generated during

the operations of the IIFP Facility. Also, Table 3-2, "Shipments Based on Estimated Annual Quantities of

Low Level Waste Generated at the IIFP Facility," will be added. Additionally, Section 4.2.4.3,

"Operations" will be revised to show the impact from the low-level waste shipments along with other

operational deliveries and UF 6 cylinder shipments.

Table RAI 5-e-1, Shipments of Miscellaneous Low-Level Waste

Estimated Material

Waste Material Mass Depleted Uranium Mass Curies

(lb/drum) (lb/drum) (Ci/drum)

Activated Alumina 98 4.9 8.00 E-04

Activated Carbon 140 7 1.1 4E-03

Air Ventilation Filters 14 0.28 4.57 E-05

Carbon Filter Elements 350 7 1.14 E-03

Clinkers of DUF4 1,000 750 1.22 E-01

Coke 140 1.4 2.29 E-04

Contaminated Pallets 210 2.1 3.43 E-04

Crushed Drums 392 3.9 6.37 E-04

Dust Collector Bags 70 10.5 1.71 E-03

Ion Exchange Resin 343 10.3 1.68 E-03

Miscellaneous 70 2.1 3.43E-04

Radioactive Waste Trash 70 0.7 1.14 E-04

Scrap Metal 392 3.9 6.37 E-04

Sintered Metal Tubes 700 7 1.14 E-03

Sodium Fluoride 679 6.8 1.11 E-03

Spent Blasting Grit/Sand 1,000 50 8.16 E-03

Uranium Oxide 1,000 881.48 1.44E-01

Reference: DOE-STD-1 136-2009, Section 2.5

Curies/drum = (pounds DU per drum) x (453.59 gram/pound) x (3.6E-7 Curies/gram)

Environmental Report Request for Additional Information (RAI 5) Page 47
Official Responses to Environmental Report RAIs

Environmental Report Documentation Impact: The 2"d paragraph of the Environmental Report

Section 3.2.2.2, "Facility Operations Phase," subheading "Uranium Wastes" will be revised to show the

shipments of low-level wastes generated during the operations of the IIFP Facility to read as follows:

Low-Level Radioactive Waste (LLW) generated from the processing the DUF 6 will be shipped to an offsite disposal facility. The majority of wastes generated during the operations of the ItFP Facility will be

LLW. The maximum number of shipments from each of the LLWs expected to be generated during Phase

I and the Phase 2 operations (Phase I plus Phase 2) is shown in Table 3-2. The expected disposal site is

the Energy Solutions facility at Clive, UT. A potential site that could be licensed in the future is the Waste

Control Specialists facility near Eunice, NM. Refer to ER Section 3.12.2.2, "RadiOactive and Mixed

-WasteSolid Waste Mana.gements," for disposition options of other wastes.

Environmental Report Documentation Impact: Section 4.2.4.3, "Operations", paragraph four will be

revised to show the impact from the low-level waste shipments along with other operational deliveries

and UF 6 cylinder shipments.

The a--imtu- potential increase to traffic due to operational deliveries and waste removal shipments

during Phase I is estimated at about 2,650 round trips per year. This value is based on estimated g-5700

radiological shipments per year plus I .02O non-radiological shipments per year. Thus, an average of

approximately 10 round trips for operational deliveries and waste management will occur daily during a

normal 5-day work week. During Phase 2 integrated operations, the number of radiological shipments per

year will increase by 2,150 or a total of4.100 shipments annually. Operational delivery and waste

removal shipments will increase by 16 round trips per year. Compared with the transportation commuting

statistics in Lea County from the 2000 census data and the traffic count on the specific highways, this

increase in traffic from operational deliveries and waste removal will be SMALL either for Phase I or

Phase 2 operations. One mitigation measure to be considered by IIFP is to schedule operations worker

shift changes and truck shipments for off-peak traffic periods, when practical. For cumulative impacts for

Phase I operations and Phase 2 construction, see Section 4.2. 10, "Cumulative Impacts."

Environmental Report Documentation Impact: Remove and replace Chapter 4 of the ER, Revision A

in its entirety and replace with the revised Chapter 4 that will be provided in a separate document as part

of the official RAI ER response package. Section 4.2.6.3, "Incident-Free Scenario Radiological Dose,"

will be revised to incorporate the revised shipments of uranium oxides and low-level wastes. Former

Table 4-5 (now 4-4), "Annual Incident-Free Transportation Radiological Dose to the Public and Worker

(Phase 2)," will be revised based on these shipments of uranium oxide and miscellaneous low-level

wastes shown in Table 3-2, "Shipments Based on Estimated Annual Quantities of Low Level Waste

Generated at the IIFP Facility" (removed and replaced, as shown below) as well as, new Table 4-4,

"Annual Incident-Free Transportation Radiological Dose to the Public and Worker (Phase 1)."See Section

4.2.6.3, "Incident-Free Scenario Radiological Dose," of the enclosed rewrite to Chapter 4.

Environmental Report Request for Additional Information (RAI 5) Page 48
Official Responses to Environmental Report RAIs

Table 3-2 Shipments Based on Estimated Annual Quantities of Low Level Waste Generated at the

IIFP Facility

Estimated Phase ] Wastes Phase 2 Wastes

Material Mass, : Ran Shipments Intt Drums Shipments

______________~bdrutnj ii 1115 per y

Activated 98 2,000-4,000 20-40 1 2,000-4.000 20-40 1

Alur Vinta t io

Air Ventilation 14 50-100 4-8 0.2 65-100 5-8 0.2

filters _ _

Carbon 350 2 3_5,000 71-142 3.6 35 ,000 71-142 3.6

Off-specification L 5,000- 5-10 0.3 5,000- 5-10 0.3

DU_ __000 4 10.000 .10.000

Coke 140 8,000- 58-86 2.2 8,000- 58-86 2' "2 12.000 -- 12.000 -'"

Contaminated 210 1.000-4000 14-57 1.4 3,000- 43-171 4.3

Pallets 2 12.000 43-171 ____3

Crushed Drums 392 1.000-3,000 3-8 0.2 2,000-5.000 3-8 0.2

Dust Collector 70 500-3,000 7-43 1.1 1,000-3,000 14-43 1.1

Bacs _

Ion Resin Exchange 0., 343 1,000-2.000 3-6 0.2 2.000-4,000 6-12 0.3

Radioactive Waste 70 35 000- 500-785 19.6 1000- 5.7

Trash' 55A000 100,000 1,429

Scrap metal 392 4,000-8,000 - 10-20 0.5 -- 126000- 16.000- 30-40 1

Sintered Metal 700 1.000-2,000 2-3 0.1 2,000-3,00 3-5 0.1

Tubes__ __

Sodium Fluoride 679 2.000-4,000 3-6 0.2 2,000-4,000 3-6 0.2

Spent Blasting .000 1 00-200 0 0 100-200 0 0 G~rit` ....

2.800.000- 2.800- 48 8.700,000- 8700 476 Uranium Oxide 1,000 6,200.000 6.200 20,000.000 20,000

*Maximum1rn Shipments at 40 drums per trailer or 42,000

pouinds/sh ipment__ 179 527_

waste not compacted. 2 Blastin., srit lo be recycled. 3'1he-reficilkv PIhase I shnimrnent shouw ivera(,c. 1A4 It 1 55 while Ph'anse 2 hiami z;hniIlnM 'c..r'n,, '1 I, tI .nt

VIRN 110L11d average 218 to 450

Environmental Report Request for Additional Information (RAI 5) Page 49
Official Responses to Environmental Report RAIs

RAI 6

Provide the radionuclide inventory of an "empty" DUF6 cylinder.

Table 4-4, "Annual Incident-Free Transportation Radiological Dose to the Public and Worker, " of the

ER (11FP, 2009a) refers to 789 shipments of empty DUF6 cylinders. It is expected that these empty

cylinders would contain a heel comprised of nonvolatile uranium progeny and possibly some nonsublimated DUF6 . The curie content of these progeny would be considerably less than the heel described

in Table D-1 of the Louisiana Energy Services (LES) EIS (NRC, 2005), which represents an enriched

heel. The ER does not provide the radionuclide inventory of an empty cylinder and, thus, does not present

sufficiently detailed information for a project-specific analysis. The requested data are necessary to

perform a radiological consequence analysis with the computer code RADTRAN for the I1FP project in

order to assess the associated transportation impacts in the EIS.

RESPONSE:

Nonvolatile uranium progeny produced in a DUF 6 cylinder are assumed to remain after the cylinder is

initially emptied. The heel of an empty cylinder generally contains no more than 50 pounds of depleted

UF 6 plus the quantities of progeny generated from decay of a full DUF 6 cylinder. Table RAI 6-1

illustrates the radionuclide inventory 30 days after the cylinder is initially emptied. Inventory values were

determined by Microshield® 8.03 software.

Table RAI 6-1 Radionuclide Inventory of an Empty DUF 6 Cylinder

Isotope Inventor030 :Days After Cylinder iISlitially Emptied (C•.)

Ac-227 1.82E-05

Bi-210 6.33E-07

Bi-211 1.82E-05

Bi-214 1.73E-06

Fr-223 2.52E-07

Pa-231 3.65E-05

Pa-234 4.34E-03

Pa-234m 2.71 E+00

Pb-2 10 6.34E-07

Pb-21 1 1.82E-05

Pb-214 1.73E-06

Po-210 6.15E-07

Po-21 I 4.96E-08

Po-214 1.73E-06

Po-215 1.82E-05

Po-218 1.73E-06

Ra-223 1.82E-05

Ra-226 1.73E-06

Rn-219 1.82E-05

Rn-222 1.73E-06

Th-227 1.79E-05

Environmental Report Request for Additional Information (RAI 6) Page 50
Official Responses to Environmental Report RAls

Isotope' Inventory 30 Days After Cylinder is Initially Emptied (Ci)

Th-230 1.61E-04

Th-231 3.45 E-02

Th-234 2.71E+00

TI-207 1.81E-05

U-234 6.60E-04

U-235 6.39E-05

U-238 5.01E-03

Environmental Report Documentation Impact: None

Environmental Report Request for Additional Information (RAI 6) Page 51
Official Responses to Environmental Report RAIs

RAI 7

Provide information regarding hydrogen generation to support the description of the proposed action.

a. Describe how hydrogen would be generated for use in the deconversion processes.

The ER (IIFP, 2009a) contains limited information on the source of a major reactant. This information is

needed in order to completely describe the proposed action within the EIS.

RESPONSE:

Hydrogen is generated on demand using a vendor supplied packaged unit. The hydrogen is produced by

steam reforming natural gas followed by purification using pressure swing adsorption (PSA). This type

system is being used at the DOE de-conversion plants (7 total units) and also in other commercial

facilities for on-demand supply of hydrogen.

Environmental Report Documentation Impact: The hydrogen supply will be inserted into the 4 th

paragraph of Section 2.1.3.2 with resulting in two paragraphs. The 4th paragraph and the resulting new

paragraph will read as follows:

The DUF 6 cylinder is placed in a containment-type autoclave; where the contents are vaporized. The

DUF 6 vapor is fed to a reaction vessel where it undergoes exothermic reaction with hydrogen to produce

DUF 4 and AHF. The gaseous hydrogen supply for the DUF, to DUF 4 reaction vessel is generated on site

using a vendor supplied packaged system of a safe design commonly used in other industrial applications.

The hydrogen is produced by steam reforming natural gas followed by purification using pressure swing

adsorption (PSA). The packaged unit is located about 107 m (350 ft) from the DUF 4 Process Building and

about 91 in (300 ft) firom the nearest other process buildings. The generated hydrogen from the remote

unit is piped through a relatively small diameter (about 1-2 in) steel pipe on an elevated pipe rack that has

mechanical barrier protection. The piping enters the upper level of the DUF 4 Process Building near the

top of the reaction vessel mixing head. A minimum length of piping run is used inside the building. The

unit when operating generates approximately 6-9 lb/hr of gaseous hydrogen at about 24.7 to 29.7 psia

pressure. The unit starts and operates automatically to produce high purity hydrogen (> 99%) and is

designed with internal safety system controls. The DUF6, to DUJF 4 process demand is estimated to be

approximately 7 lb/hr. Theoretically, 12 to 18 lb/hr natural gas will be required to produce 6 to 9 lb/hr

hydrogen. Assuming a unit efficiency of approximately 75% will place the natural gas requirement at 16

to 24 pounds per hour or 359 to 539 SCFH. The 7 lb/hr demand will require 18.7 lb/hr or 420 SCFH of

natural gas at 75% unit efficiency. No storage equipment is provided for the accumulation of hydrogen.

However, a small surge tank is located at the package unit for pressure and flow control.

The DUF 4 solid powder is continuously withdrawn from the reaction vessel bottom through a cooling

screw mechanism and transferred to storage hoppers. A -two-stage dust collector system is provided to

control and recycle DUF 4 dusts that are internal to the solids handling equipment and generated by air or

gas flows associated with the handling equipment. The DUF 4 in the storage hoppers is transferred to the

FEP plant for use as raw material feed in producing SiF4 and BF 3.

Environmental Report Request for Additional Information (RAI 7) Page 52
Official Responses to Environmental Report RAls

RAI 7

Provide information regarding hydrogen generation to support the description of the proposed action.

b. Provide the production capacity of the hydrogen plant and the demand for hydrogen.

The ER (IIFP, 2009a) contains limited information on the source of a major reactant. This information is

needed in order to completely describe the proposed action within the EIS.

RESPONSE:

The hydrogen generating unit is capable of supplying approximately 6-9 lb/hr of gaseous hydrogen at

about 24.7 to 29.7 psia. The DUF 6 to DUF4 process demand is estimated to be approximately 7 lb/hr. The

unit starts and operates automatically to produce high purity hydrogen (> 99%) and is designed with

internal safety system controls.

Environmental Report Documentation Impact: The 4th paragraph of Section 2.1.3.2 will be revised,

resulting in two paragraphs. See Environmental Report Documentation Impact for RAI ER 7-a above.

Environmental Report Request for Additional Information (RAI 7) Page 53
Official Responses to Environmental Report RAls

RAI 7

Provide information regarding hydrogen generation to support the description of the proposed action.

c. State the hydrogen storage capacity.

The ER (IIFP, 2009a) contains limited information on the source of a major reactant. This information is

needed in order to completely describe the proposed action within the EIS.

RESPONSE:

No storage equipment is provided for the accumulation of hydrogen. However, a small surge tank is

located at the package unit for pressure and flow control.

Environmental Report Documentation Impact: The 4 th paragraph of Section 2.1.3.2 will be revised,

resulting in two paragraphs. See Environmental Report Documentation Impact for RAI ER 7-a above.

Environmental Report Request for Additional Information (RAI 7) Page 54
Official Responses to Environmental Report RAls

RAI 7

Provide information regarding hydrogen generation to support the description of the proposed action.

d. State whether the provided natural gas demand includes the demand for generation of hydrogen.

If not, provide the amount of natural gas required for hydrogen generation.

The ER (IIFP, 2009a) contains limited information on the source of a major reactant. This information is

needed in order to completely describe the proposed action within the EIS.

RESPONSE:

Theoretically, 12 to 18 lb/hr natural gas will be required to produce 6 to 9 lb/hr hydrogen. Assuming a

unit efficiency of approximately 75% will place the natural gas requirement at 16 to 24 pounds per hour

or 359 to 539 SCFH. The 7 lb/hr demand will require 18.7 lb/hr or 420 SCFH of natural gas at 75% unit

efficiency.

Environmental Report Documentation Impact: The 4 th paragraph of Section 2.1.3.2 will be revised,

resulting in two paragraphs. See Environmental Report Documentation Impact for RAI ER 7-a above.

Environmental Report Request for Additional Information (RAI 7) Page 55
Official Responses to Environmental Report RAIs

RAI 8

Provide additional information regarding air emissions during construction of the IIFP facility.

a. Provide the site-specific assumptions that went into the estimates of the air emissions resulting

from operation of off-road construction equipment in Table 4-11 of the ER (IIFP, 2009a). Include

vehicle types and assumptions regarding quantity totals that make up the thirteen support

vehicles and the thirteen construction vehicles.

The requested air emissions and refueling information is needed to properly assess the impacts to air

quality during construction.

RESPONSE:

The makeup and quantities of the thirteen construction vehicles and the twelve support vehicles used in

Phase 1 construction are shown in Table RAI 8-a-I with the calculation of their contribution to each of

the emission parameters. See the attached guidance on page 159 for calculations of emissions, "NonRadiological Emissions and Impacts for Phase 1 and Phase 2 Construction Activities." It is expected that

construction in Phase 1 will last approximately 18 months. Some the equipment will be utilized the entire

time, some will be sequential, and others may be only intermittent. The calculation of Phase I emissions

and impacts are shown in Tables RAI-8-a I through RAI-8-a-12 in Section A below.

For Phase 2 construction, 14 pieces of equipment are anticipated to be involved in construction activities.

Those pieces of construction equipment are shown in Table RAI 8-a-12 with the calculation of their

contribution to each of the emission parameters. Phase 2 construction is estimated to last one year. As

above, some the equipment will be utilized the entire time, some will be sequential, and others may be

only intermittent. The calculations of Phase 2 emissions and impacts are shown in Tables RAI-8-a-13

through RAI-8-a-22 in Section B below.

Environmental Report Request for Additional Information (RAI 8) Page 56
Official Responses to Environmental Report RAls

A. Phase 1 Construction Emissions and Impacts

Table RAI 8-a-1 Average Horsepower Hours per Month

on. Month 6 onMonth 8onth Mo•ftith 

Equipment pMonth 1. Month 2 Month 3 Month 4 Month 5 Monthi6 Month 7 Month Month 9

Hp-hoEr.

Tractor/backhoe 150 0.21 10080 10080 10080 10080 0 0 0 0 0 0 0 0

Grader 400 0.59 37760 37760 37760 37760 0 0 0 0 0 0 0 0

Excavator 500 0.59 47200 47200 47200 47200 0 0 0 0 0 0 0 0

Dump Truck 300 0.21 20160 20160 20160 20160 6300 6300 6300 6300 6300 6300 6300 6300

Dozer 400 0.59 37760 37760 37760 37760 0 0 0 0 0 0 0 0

Air Compressor 325 0.43 0 0 0 0 44720 44720 44720 44720 44720 44720 44720 44720

Concrete Pump 125 0.43 0 0 0 0 8600 8600 8600 8600 8600 8600 8600 8600

Crane 175 0.43 0 0 0 0 12040 12040 12040 12040 12040 12040 12040 12040

Fuel Truck 250 0.59 7375 7375 7375 7375 7375 7375 7375 7375 7375 7375 7375 7375

Water Truck 250 0.59 7375 7375 7375 7375 7375 7375 7375 7375 7375 7375 7375 7375

Forklift 200 0.59 5900 5900 5900 5900 37760 37760 37760 37760 37760 37760 37760 37760

Flatbed, 2 ton 200 0.59 0 0 0 0 37760 37760 37760 37760 37760 37760 37760 37760

Generator 33 0.43 0 0 0 0 4540.8 4540.8 4540.8 4540.8 4540.8 4540.8 4540.8 4540.8

Welder 50 0.21 0 0 0 0 1680 1680 1680 1680 1680 1680 1680 1680

Small Truck 150 0.21 3150 3150 3150 3150 7875 7875 7875 7875 7875 7875 7875 7875

Environmental Report Request for Additional Information (RAI 8) Page 57
Official Responses to Environmental Report RAls

This table identifies the assumed tailpipe emission rate for each pollutant and each item of construction equipment. These values are based on AP42 non-road emission factors for diesel-fired equipment. These emission factors have been adjusted to account for AP-42 transient adjustment

factors and deterioration factors. These emission factors apply to Phase 1 and to Phase 2 equipment.

Table RAI 8-a-2 Tailpipe Emission Factors

Max Hp Load Factor i•' Diesel Fuel

Equipment Max Hp Load Factor Burned

lb/h -hr

Tractor/backhoe 150 0.21 1.19E-02 5.06E-03 1.31E-03 1.28E-03 1.72E-03 3.44E-04 4.69E-04 3.67E-01

Grader 400 0.59 1.28E-02 4.63E-03 5.13E-04 4.96E-04 4.79E-04 3.60E-04 4.62E-04 3.67E-01

Excavator 500 0.59 1.27E-02 4.63E-03 5.12E-04 4.95E-04 4.78E-04 3.59E-04 4.64E-04 3.67E-01

Dump Truck 300 0.21 1.37E-02 4.44E-03 1.19E-03 1.16E-03 1.59E-03 3.65E-04 4.60E-04 3.67E-01

Dozer 400 0.59 1.28E-02 4.63E-03 5.13E-04 4.96E-04 4.79E-04 3.60E-04 4.62E-04 3.67E-01

Air Compressor 325 0.43 1.34E-02 3.02E-03 3.86E-04 3.71E-04 4.57E-04 3.57E-04 4.64E-04 3.67E-01

Concrete Pump 125 0.43 1.19E-02 1.40E-02 2.37E-03 2.30E-03 2.67E-03 3.52E-04 4.63E-04 3.67E-01

Crane 175 0.43 1.25E-02 1.73E-03 5.33E-04 5.07E-04 6.93E-04 3.60E-04 4.67E-04 3.67E-01

Fuel Truck 250 0.59 1.18E-02 2.64E-03 6.82E-04 6.62E-04 7.23E-04 3.58E-04 4.59E-04 3.67E-01

Water Truck 250 0.59 1.18E-02 2.64E-03 6.82E-04 6.62E-04 7.23E-04 3.58E-04 4.59E-04 3.67E-01

Forklift 200 0.59 1.18E-02 2.65E-03 6.86E-04 6.61E-04 7.29E-04 3.56E-04 4.66E-04 3.67E-01

Flatbed, 2 ton 200 0.59 1.18E-02 2.65E-03 6.86E-04 6.61E-04 7.29E-04 3.56E-04 4.66E-04 3.67E-01

Generator 33 0.43 1.05E-02 3.45E-03 7.27E-04 7.27E-04 5.91E-04 4.09E-04 4.55E-04 4.08E-01

Welder 50 0.21 1.09E-02 8.73E-03 1.55E-03 1.55E-03 1.36E-03 3.64E-04 4.55E-04 4.08E-01

Small Truck 150 0.21 1.18E-02 2.64E-03 6.82E-04 6.62E-04 7.23E-04 3.58E-04 4.59E-04 3.67E-01

NO 2- Nitrogen Dioxide, VOC - Volatile Organic Chemicals, SO2 - Sulfur Dioxide, PM,0 Particulate Matter less than 10 microns, PM 25 Particulate Matter less than 2.5 microns, HAP - Hazardous Air

Pollutants

Environmental Report Request for Additional Information (RAI 8) Page 58
Official Responses to Environmental Report RAIs

This table summarizes the results from the individual 12-month tables calculating the pollutant tailpipe

emissions as a product of the horsepower-hours and emission factor. This table also calculates the

maximum monthly tailpipe emissions and annual tailpipe emissions for each pollutant.

Table RAI 8-a-3 Summarize Tailpipe Emissions

• :•: ...... •': ....... C ombustion D e e

Month NO2 CO PM'0 PM 2.5 VOC SO2 CobAPs Diesel

MONTH 01 2240 771 116 113 125 63.5 81.8 64,871

MONTH 02 2240 771 116 113 125 63.5 81.8 64,871

MONTH 03 2240 771 116 113 125 63.5 81.8 64,871

MONTH 04 2240 771 116 113 125 63.5 81.8 64,871

MONTH 05 2161 595 125 121 138 63.1 81.7 64,857

MONTH 06 2161 595 125 121 138 63.1 81.7 64,857

MONTH 07 2161 595 125 121 138 63.1 81.7 64,857

MONTH 08 2161 595 125 121 138 63.1 81.7 64,857

MONTH 09 2161 595 125 121 138 63.1 81.7 64,857

MONTH 10 2161 595 125 121 138 63.1 81.7 64,857

MONTH 11 2161 595 125 121 138 63.1 81.7 64,857

MONTH 12 2161 595 125 121 138 63.1 81.7 64,857

NO2 - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, S02- Sulfur Dioxide, PMI( Particulate Matter less than 10 microns, PM2 .5

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Pollutants

Table RAI 8-a-4 Calculate Average Tailpipe Emission Rates

Average Com bustion

Area: ...2: •2.5... 10.. ,.. ... • RA H Ps

Emission g/s/m 2

Rate

I-hr 1.82E-05 6.26E-06 1.01E-06 9.79E-07 1.12E-06 5.15E-07 6.64E-07

3-hr 1.82E-05 6.26E-06 L.OIE-06 9.79E-07 1. .12E-06 5.15E-07 6.64E-07

8-hr 1.82E-05 6.26E-06 1.OIE-06 9.79E-07 1. 12E-06 5.15E-07 6.64E-07

24-hr 7.58E-06 2.61E-06 4.22E-07 4.08E-07 4.67E-07 2.15E-07 2.77E-07

8,760-hour 3.89E-06 1.16E-06 2.17E-07 2.1OE-07 2.38E-07 1.12E-07 1.45E-07

NO 2 - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, SO2- Sulfur Dioxide, PM1 o Particulate Matter less than 10 microns, PM2 .

5

Particulate Matter less than 2,5 microns, HAP - Hazardous Air Pollutants

Construction area 274 m x 354 m

Table RAI 8-a-5 Calculate Fugitive Dust Emission by Month

Month TSP (ton/acre) Hours TSP (ton) PM1 0 (ton) PM2.s (ton)

Month 01 1.2 208 14.4 2.16 1.08

Month 02 1.2 208 14.4 2.16 1.08

Month 03 1.2 208 14.4 2.16 1.08

Month 04 1.2 208 . 14.4 2.16 1.08

Month 05 0.3 208 3.6 0.54 0.27

Month 06 0.3 208 3.6 0.54 0.27

Month 07 0.3 208 3.6 0.54 0.27

Month 08 0.3 208 3.6 0.54 0.27

Environmental Report Request for Additional Information (RAI 8) Page 59
Official Responses to Environmental Report RAIs

Month TSP (ton/acre) Hours TSP (ton) PM10 (ton) PM2

.s(ton)

Month 09 0.3 208 3.6 0.54 0.27

Month 10 0.3 208 3.6 0.54 0.27

Month 11 0.3 208 3.6 0.54 0.27

Month 12 0.3 208 3.6 0.54 0.27

Assumptions

1. size of the construction site - 40 acre

2. fraction of the site with active construction at any given time - 0.6

3. effective area of the construction site - 24 acre

4. construction dimension - 274 m x 354 m

5. fraction of TSP that is PM10 - 0.15 ton PMIO/ton TSP

6. fraction of TSP that is PM 2.

5 - 0.075 ton PMI 0/ton TSP

7. TSP suppression due to application of water on unpaved surfaces - 50 %

Table RAI 8-a-6 Calculate average fugitive emission rates (PMl 0 and PM2.

5)

Area Emission Rate

Time Rate, . M 10* PM2.

5 1

1-hr 2.70E-05 1.35E-05

3-hr 2.70E-05 1.35E-05

8-hr 2.70E-05 1.35E-05

24-hr 1.12E-05 5.62E-06

8,760-hour 3.84E-06 1.92E-06

PM1 o Maximum Monthly Total (ton): 2.16 PM 1 0 Annual Total (ton): 12.96

PM 25, Maximum Monthly Total (ton): 1.08 PM2.5 Annual Total (ton): 6.48

PM1 o Annual Total (Ib): 25920 PM 2.

5 Annual Total (lb): 12960

PM I( Maximum Monthly Total (g): 1.96E+06 PM 1 0 Annual Total (g): 1.18E+07

PM 2 .

5 Maximum Monthly Total (g): 9.80E+05 PM 2.

5 Annual Total (g): 5.88E+06

Maximum Hours per month (hrs): 208

Table RAI 8-a-7 Calculate fugitive HAP emissions

778336 lb diesel burned - mass of diesel fuel consumed by construction equipment over the entire year

0.000028 lb HAP / lb Diesel emission factor for a diesel service station

Total HAP over one year = 22 lb

Table RAI 8-a-8 Summarize Criteria, HAP, and VOC Annual Emissions

Pollutant Tailpipe (Ib) Fugitive (Ib) Annual'(Ib)

NO 2 26,245 0 26,245

CO 7,846 0 7,846

PM 10 1,463 25,920 27,383

PM 25. 1,416 12,960 14,376

VOC 1,606 21.8 1,628

SO 2 759 0 759

HAPs 981 22 1,002

NO2 - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, SO2 - Sulfur Dioxide, PM to Particulate Matter less than 10 microns, PM2 5

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Pollutants

Environmental Report Request for Additional Information (RAI 8) Page 60
Official Responses to Environmental Report RAIs

Table RAI 8-a-9 Summarize Criteria Pollutant Area Emission Rates

•Emksn ;Average Area Emission Rfi•, as•m/•'i2

AFac~tor NO2, C ()'1⁄2 PM10 PM 2,

51 S02

1-hr 1.82E-05 6.26E-06 2.80E-05 1.45E-05 5.15E-07

3-hr 1.82E-05 6.26E-06 2.80E-05 1.45E-05 5.15E-07

8-hr 1.82E-05 6.26E-06 2.80E-05 1.45E-05 5.15E-07

24-hr 7.58E-06 2.61E-06 1.17E-05 6.03E-06 2.15E-07

8,760-hr 3.89E-06 1.16E-06 4.06E-06 2.13E-06 1.12E-07

LNU2 - i•itrogen Dloxide, VU. - volatile Organic Chemicals, S02 -

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Polh

Sullur lioxide, PM,ýsV 0 Particulate Matter less man 10 microns, ivM2.5

Table RAI 8-a-10 ONE HOUR POLLUTANT CONCENTRATIONS BASED ON ANNUAL AVERAGE

EMISSIONS RATES

10 6.88E-01 2.30E+00 1.26E+00 2.40E+00 6.66E-02

20 7.04E-01 2.36E+00 1.29E+00 2.46E+00 6.81E-02

30 7.15E-01 2.39E+00 1.31E+00 2.49E+00 6.91E-02

40 7.31E-01 2.44E+00 1.34E+00 2.55E+00 7.06E-02

50 7.46E-01 2.50E+00 1.37E+00 2.60E+00 7.21E-02

60 7.63E-01 2.55E+00 1.40E+00 2.66E+00 7.37E-02

70 7.77E-01 2.60E+00 1.42E+00 2.71E+00 7.52E-02

80 7.92E-01 2.65E+00 1.45E+00 2.76E+00 7.66E-02

90 8.06E-01 2.69E+00 1.48E+00 2.81E+00 7.79E-02

100 8.26E-01 2.76E+00 1.51E+00 2.88E+00 7.99E-02

200 9.63E-01 3.22E+00 1.76E+00 3.36E+00 9.31E-02

300 7.41E-01 2.48E+00 1.36E+00 2.58E+00 7.16E-02

400 5.33E-01 1.78E+00 9.76E-01 1.86E+00 5.15E-02

500 4.24E-01 1.42E+00 7.78E-01 1.48E+00 4.31E-02

600 3.56E-01 1.19E+00 6.52E-01 1.24E+00 3.44E-02

700 3.07E-01 1.03E+00 5.62E-01 1.07E+00 2.97E-02

800 2.70E-01 9.03E-01 4.95E-01 9.42E-01 2.61E-02

900 2.41E-01 8.07E-01 4.42E-01 8.42E-01 2.33E-02

1000 2.19E-01 7.32E-01 4.01E-01 7.63E-01 2.11E-02

1200 1.85E-01 6.20E-01 3.40E-01 6.47E-01 1.79E-02

1400 1.61E-01 5.39E-01 2.95E-01 5.62E-01 1.56E-02

1600 1.42E-01I 4.74E-01I 2.60E-01 4.95E-01 1.37E-02

1800 1.26E-01 4.21E-01 2.31E-01 4.39E-01 1.22E-02

2000 1.13E-01 3.78E-01 2.07E-01 3.94E-01I 1.09E-02

MAXIMUM: 9.63E-01 3.22E+00 1.76E+00 3.36E+00 9.31 E-02

PROPERTY

BOUNDARY: 2.41E-01 8.07E-01 4.42E-01 8.42E-01 2.33E-02

ONE MILE: 1.42E-01 4.74E-01 2.60E-01 4.95E-01 1.37E-02

NO2 - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, SO 2 -

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Polh

I Sulfur Dioxide, PM10 Particulate Matter less than 10 microns, PM 2.5

Environmental Report Request for Additional Information (RAI 8) Page 61
Official Responses to Environmental Report RAIs

Table RAI 8-a-I I SUMMARIZE THE MAXIMUM RESULTS

Maximum Impact (uR/m3)

Average CO- NO 2 PM 2.

5 PM10 SO2

1 -hr 5.18E+00 1.50E+01 1.20E+01 2.32E+01 4.27E-01

3-hr 5.18E+00 1.50E+01 1.20E+01 2.32E+01 4.27E-01

8-hr 5.18E+00 1.50E+01 1.20E+01 2.32E+01 4.27E-01

24-hr 2.16E+00 6.27E+00 4.99E+00 9.65E+00 1.78E-01

Annual 9.63E-01 3.22E+00 1.76E+00 3.36E+00 9.31E-02

NO2 - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, SO 2 - Sulfur Dioxide, PM1

l Particulate Matter less than 10 microns, PM 2,

5

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Pollutants

Property Boundary Impact (tg/m3)

Average CO NO 2 PM25 PM10 S02

1 -hr 1.30E+00 3.77E+00 3.OOE+00 5.81E+O0 1.07E-01

3-hr 1.30E+00 3.77E+00 3.OOE+00 5.81E+00 1.07E-01

8-hr 1.30E+00 3.77E+00 3.OOE+00 5.81E+00 1.07E-01

24-hr 5.41E-01 1.57E+00 1.25E+00 2.42E+00 4.46E-02

Annual 2.41E-01 8.07E-01 4.42E-01 8.42E-01 2.33E-02

NO 2 - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, SO 2 - Sulfur Dioxide, PM1 0 Particulate Matter less than 10 microns, PM2.5

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Pollutants

One Mile Impact (m!/m3)

Average CO NO 2 PM 2.

5 PM10 SO2

1-hr 7.63E-01 2.21E+00 1.76E+00 3.41E+00 6.28E-02

3-hr 7.63E-01 2.21E+00 1.76E+00 3.41E+00 6.28E-02

8-hr 7.63E-01 2.21E+00 1.76E+00 3.41E+00 6.28E-02

24-hr 3.18E-01 9.23E-01 7.34E-01 1.42E+00 2.62E-02

Annual 1.42E-01 4.74E-01 2.60E-01 4.95E-01 1.37E-02

NO 2 - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, SO 2 - Sulfur Dioxide, PM 1 Particulate Matter less than 10 microns, PM 25

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Pollutants

Table RAI 8-a-12 COMPARE RESULTS WITH NAAQS

NAAQS Maximum Property. One Mileimpact Pollutant Average N Sm 3 Impact Bounday: 3 Pg :• .•1

CO 1-hr 10,000 5.184 1.299 0.763

CO 8-hr 40,000 3.628 0.909 0.534

NO 2 1-hr 188 15.049 3.771 2.215

NO 2 Annual 100 0.258 0.065 0.038

PM 25 24-hr 35 1.996 0.500 0.294

PM 2.

5 Annual 15 0.141 0.035 0.021

PMto 24-hr 150 3.861 0.968 0.568

SO 2 1 -hr 200 0.427 0.107 0.063

SO 2 3-hr 1300 0.384 0.096 0.057

SO 2 24-hr 365 0.071 0.018 0.010

SO 2 Annual 80 0.007 0.002 0.001

Environmental Report Request for Additional Information (RAI 8) Page 62
Official Responses to Environmental Report RAIs

NO - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, SO2 - Sulfur Dioxide, PMl0 Particulate Matter less than 10 microns, PM2.5

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Pollutants

Assumptions:

I. Pollutant impacts are determined based on the peak emissions generated by site preparation.

2. The peak one-hour concentrations are as determined by SCREEN3.

3. To determine the peak 3-hour concentration, the peak one-hour concentration is scaled by 0.9 based on EPA guidance

on EPA guidance.

4. To determine the peak 8-hour concentration, the peak one-hour concentration is scaled by 0.7 based on EPA guidance.

5. To determine the peak 24-hour concentration, the peak one-hour concentration is scaled by 0.4 based on EPA guidance

and by 10/24 to account for limited work day.

6. To determine the peak annual concentration, the peak one-hour concentration is scaled by 0.07 based on EPA guidance,

by 10/24 to account for limited work day, then adjusted to account for 4 months of peak emissions (site preparation),

7.5 months of reduced emissions (post site preparation), and two weeks of zero emissions.

7. Scale Factors to estimate impact concentrations other than one hour based on Average 1-hr as 1.00, 3-hr as 0.9, 8-hr as

0.7, 24-hr as 0.4, and annual as 0.08.

8. Based on Average 1-hr as 1.00, 3-hr as 0.9, 8-hr as 0.7, 24-hr as 0.4, and annual as 0.08.

Environmental Report Request for Additional Information (RAI 8) Page 63
Official Responses to Environmental Report RAIs

B. Phase 2 Construction Emissions and Impacts

RAI 8-a-13 Average Horsepower Hours per Month

This table combines the results from the previous two steps to calculate the horsepower-hours for each item of equipment, by month

Equimen b.69 Month Month Month Month I Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 10 11 U2

Hp-hours

Tractorlbackhoe 150 0.21 1575 1575 1575 0 0 0 0 0 0 0 0 0

Dump Truck 300 0.21 3150 3150 3150 0 0 0 0 0 0 0 0 0

Air Compressor 325 0.43 0 13975 13975 13975 13975 13975 13975 13975 13975 13975 13975 13975

Concrete Pump 125 0.43 0 5375 5375 5375 2687.5 2687.5 2687.5 2687.5 0 0 0 0

Crane 175 0.43 0 7525 7525 7525 3762.5 3762.5 3762.5 3762.5 0 0 0 0

Fuel Truck 250 0.59 2950 2950 2950 2950 2950 2950 2950 2950 2950 2950 2950 2950

Water Truck 250 0.59 2950 2950 2950 2950 2950 2950 2950 2950 2950 2950 2950 2950

Forklift 200 0.59 9440 11800 11800 11800 11800 11800 11800 11800 5900 5900 5900 5900

Flatbed, 2 ton 200 0.59 9440 11800 11800 11800 11800 11800 11800 11800 5900 5900 5900 5900

Generator 33 0.43 0 2270.4 2270.4 2270.4 2270.4 2270.4 2270.4 2270.4 2270.4 2270.4 2270.4 2270.4

Welder 50 0.21 0 0 1050 1050 1050 2100 2100 2100 2100 2100 2100 2100

Small Truck 150 0.21 3150 3150 3150 3150 3150 3150 3150 3150 3150 3150 3150 3150

Environmental Report Request for Additional Information (RAI 8) Page 64
Official Responses to Environmental Report RAIs

This table summarizes the results from the individual 12-month tables calculating the pollutant tailpipe

emissions as a product of the horsepower-hours and emission factor. This table also and calculates the

maximum monthly tailpipe emissions and annual tailpipe emissions for each pollutant.

RAI 8-a-14 Summarize Tailpipe Emissions

: : : • ~~Combustion I ::: "

Month NO2 CO PM10 : PM2,5 VOC SO2 Cobstio Diesel

MONTH 01 391 96 25 24 28 11.7 15.1 11984

MONTH 02 816 247 52 50 59 23.9 30.9 24506

MONTH 03 827 256 54 52 60 24.2 31.3 24934

MONTH 04 765 234 48 46 52 22.5 29.2 23200

MONTH 05 686 190 39 38 43 20.2 26.2 20833

MONTH 06 698 199 41 40 44 20.6 26.6 21262

MONTH 07 698 199 41 40 44 20.6 26.6 21262

MONTH08 698 199 41 40 44 20.6 26.6 21262

MONTH 09 480 124 25 24 26 14.1 18.1 14564

MONTH 10 480 124 25 24 26 14.1 18.1 14564

MONTH II 480 124 25 24 26 14.1 18.1 14564

MONTH 12 480 124 25 24 26 14.1 18.1 14564

NO 2 - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, SO2 - Sulfur Dioxide, PM1 o Particulate Matter less than 10 microns, PM 2.

5

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Pollutants

RAI 8-a-15 Calculate Average Tailpipe Emission Rates

Average NO2 CO PM10 PM2s VOC S02 Combustion

Area 2 O252HAPs

Emission g/S/M2

Rategs

1-hr 2.68E-04 8.30E-05 1.74E-05 1.68E-05 1.95E-05 7.85E-06 1.02E-05

3-hr 2.68E-04 8.30E-05 1.74E-05 1.68E-05 1.95E-05 7.85E-06 1.02E-05

8-hr 2.68E-04 8.30E-05 1.74E-05 1.68E-05 1.95E-05 7.85E-06 1.02E-05

24-hr 1.12E-04 3.46E-05 7.24E-06 7.OOE-06 8.12E-06 3.27E-06 4.23E-06

8760-hour 4.44E-05 1.25E-05 2.60E-06 2.52E-06 2.82E-06 1.31E-06 1.69E-06

NO2 - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, SO2 - Sulfur Dioxide, PM1 o Particulate Matter less than 10 microns, PM2 5

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Pollutants

Environmental Report Request for Additional Information (RAI 8) Page 65
Official Responses to Environmental Report RAls

RAI 8-a-16 Calculate Fugitive Dust Emission by Month

t T (ton/acre) I -,Hrs SP, , (ton) ,.: w ( PM (ton):

Month 01 0.3 208 0.09 0.0135 0.00675

Month 02 0.3 208 0.09 0.0135 0.00675

Month 03 0.3 208 0.09 0.0135 0.00675

Month 04 0.3 208 0.09 0.0135 0.00675

Month 05 0.3 208 0.09 0.0135 0.00675

Month 06 0.3 208 0.09 0.0135 0.00675

Month 07 0.3 208 0.09 0.0135 0.00675

Month 08 0.3 208 0.09 0.0135 0.00675

Month 09 0.3 208 0.09 0.0135 0.00675

Month 10 0.3 208 0.09 0.0135 0.00675

Month 11 0.3 208 0.09 0.0135 0.00675

Month 12 0.3 208 0.09 0.0135 0.00675

Assumptions

1. size of the construction site - I acre

2. fraction of the site with active construction at any given time - 0.6

3. active area of the construction site - 0.6 acre

4. active construction dimension- 49.3 m x 49.3 m

5. fraction of TSP that is PM 10 - 0.15 ton PM 10/ton TSP

6. fraction of TSP that is PM2.5 - 0.075 ton PM 10/ton TSP

7. TSP suppression due to application of water on unpaved surfaces - 50 %

RAI 8-a-17 Calculate average fugitive emission rates (PM10 and PM2.5)

~. ~I Area Emissioi Rate,.

Time Rate PMo0 'PM• -

2

• 5

g/S/M 2

1-hr 6.73E-06 3.36E-06

3-hr 6.73E-06 3.36E-06

8-hr 6.73E-06 3.36E-06

24-hr 2.80E-06 1.40E-06

8,760-hour 1.92E-06 9.59E-07

PM,11 Maximum Monthly Total (ton):

PM2.

5 Maximum Monthly Total (ton):

PM10 Annual Total (lb):

PM111 Maximum Monthly Total (g):

PM25 Maximum Monthly Total (g):

Maximum Hours per month (hrs):

0.0135

0.00675

324

1.22E+04

6.12E+03

208

PMI( Annual Total (ton):

PM2.

5 Annual Total (ton):

PM 2.

5 Annual Total (lb):

PMI Annual Total (g):

PM2.

5 Annual Total (g):

0.162

0.081

162

1.47E+05

7.35E+04

Environmental Report Request for Additional Information (RAI 8) Page 66
Official Responses to Environmental Report RAIs

RAI 8-a-18 Calculate fugitive HAP emissions

227499 lb diesel burned - mass of diesel fuel consumed by construction equipment over the entire year.

0.000028 lb HAP / lb Diesel emission factor for a diesel service station.

Total HAP over one year = 6 lb.

Assumptions

I. Assumed equipment types are listed in Table RAI 8-a-I 3.

2. Construction equipment is operated 10 hours per day, 5 days per week, 50 weeks per year.

3. All construction equipment is fueled with diesel.

4. On average, construction equipment consumes diesel fuel at a rate of 0.054 gal/hp-hr (ATTRA, 2007).

5. Annual storage tank evaporation losses are five percent of tank capacity (ATTRA, 2007).

6. The temporary onsite fuel storage tank is equipped with enhanced vapor recovery equipment to minimize fugitive VOC emissions.

RAI 8-a-19 Summarize Criteria, HAP, and VOC Annual Emissions

Pollutant Tailpipe(lb)',, Fugitive (lb) . Annual (•i••)

NO 2 7,497 0 7,497

CO 2,115 0 2,115

PM10 439 324 763

PM 2 .5 425 162 587

VOC 477 6.4 484

SO 2 221 0 221

Combustion HAPs 285 6 291

NO - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, SO - Sulfur Dioxide, PMjo Particulate Matter less than 10 microns, PM25

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Pollutants

RAI 8-a-20 Summarize Criteria Pollutant Area Emission Rates

Emission , Average Area Emission Rate g/s/m 2 ________,__

Factor NO 2 " _______P 'CO. _-oPM 2 .

5 SO2

1-hr 2.68E-04 8.30E-05 2.41 E-05 2.02E-05 7.85E-06

3-hr 2.68E-04 8.30E-05 2.41E-05 2.02E-05 7.85E-06

8-hr 2.68E-04 8.30E-05 2.41E-05 2.02E-05 7.85E-06

24-hr 1.12E-04 3.46E-05 I.OOE-05 8.41E-06 3.27E-06

8,760-hr 4.44E-05 1.25E-05 4.52E-06 3.48E-06 1.31E-06

NO 2 - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, S02 Sulfur Dioxide, PM1 o Particulate Matter less than 10 microns, PM2.5

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Pollutants

RAI 8-a-21 SUMMARIZE THE MAXIMUM RESULTS

Maximum Impact (tlg/m3)

Average CO NO 2 PM2 .

5 PMt0 SO2

1 -hr 2.10E+01 6.79E+01 5.12E+00 6.11 E+00 1.99E+00

3-hr 2.10E+01 6.79E+01 5.12E+00 6.11E+00 1.99E+00

8-hr 2.1OE+01 6.79E+01 5.12E+00 6.11E+00 1.99E+00

24-hr 8.77E+00 2.83E+01 2.13E+00 2.55E+00 8.30E-01

Annual 3.17E+00 1.12E+01 8.81E-01 1.15E+00 3.31E-01

NO2 - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, S02 -

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Polht

Sulfur Dioxide, PM1 o Particulate Matter less than 10 microns, PM2 .

5

Environmental Report Request for Additional Information (RAI 8) Page 67
Official Responses to Environmental Report RAls

Property Boundary Impact (6tW/m3)

No, sPNj. .Average ., .CO.... Pm ... So, 0 -

1-hr 9.41E-01 3.04E+00 2.29E-01 2.73E-01 8.90E-02

3-hr 9.41E-01 3.04E+00 2.29E-01 2.73E-01 8.90E-02

8-hr 9.41E-01 3.04E+00 2.29E-01 2.73E-01 8.90E-02

24-hr 3.92E-01 1.27E+00 9.53E-02 1.14E-01 3.71E-02

Annual 1.42E-01 5.03E-01 3.94E-02 5.12E-02 1.48E-02

NO2 - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, SO 2 - Sulfur Dioxide, PM10 Particulate Matter less than 10 microns, PM 2 5

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Pollutants

One Mile Impact (tg/m3)

e0 N , ,NII Mso

I-hr 3.99E-01 1.29E+00 9.69E-02 1.16E-01 3.77E-02

3-hr 3.99E-01 1.29E+00 9.69E-02 1.16E-01 3.77E-02

8-hr 3.99E-01 1.29E+00 9.69E-02 1.16E-01 3.77E-02

24-hr 1.66E-01 5.36E-01 4.04E-02 4.82E-02 1.57E-02

Annual 6.01E-02 2.13E-01 1.67E-02 2.17E-02 6.28E-03

NO2 - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, SO 2 - Sulfur Dioxide, PM1o Particulate Matter less than 10 microns, PM2 .

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Pollutants

RAI 8-a-22 COMPARE RESULTS WITH NAAQS

- Polan NAAQS ý- :i'~irniu t oundar (N On NieImpact - 0ilutant Average WI ,Impact Bo N pg/m3

CO 1-hr 10,000 2.1OE+l 9.41E-1 3.99E-1

CO 8-hr 40,000 1.47E+1 6.59E-1 2.79E-1

NO2 1-hr 188 6.79E+1 3.04E+0 1.29E+0

NO2 Annual 100 9.00E-1 4.02E-2 1.70E-2

PM2. 24-hr 35 8.53E-1 3.81E-2 1.62E-2

PM2 ,

5 Annual 15 7.05E-2 3.15E-3 1.34E-3

PM, 0 24-hr 150 1.02E+0 4.56E-2 1.93E-2

SO 2 1-hr 200 1.99E+0 8.90E-2 3.77E-2

SO 2 3-hr 1300 1.79E+0 8.01E-2 3.39E-2

SO 2 24-hr 365 3.32E-1 1.48E-2 6.29E-3

SO 2 Annual 80 2.65E-2 1.19E-3 5.02E-4

NO2 - Nitrogen Dioxide, VOC - Volatile Organic Chemicals, S0 2 - Sulfur Dioxide, PM 1 Particulate Matter less than 10 microns, PM 2.

5

Particulate Matter less than 2.5 microns, HAP - Hazardous Air Pollutants

Pollutant impacts are determined based on the peak emissions generated by site preparation. The peak one-hour concentrations are as determined

by SCREEN3.

To determine the peak 3-hour concentration, the peak one-hour concentration is scaled by 0.9 based on EPA guidance on EPA guidance.

To determine the peak 8-hour concentration, the peak one-hour concentration is scaled by 0.7 based on EPA guidance.

To determine the peak 24-hour concentration, the peak one-hour concentration is scaled by 0.4 based on EPA guidance and by 10/24 to account

for limited work day.

To determine the peak annual concentration, the peak one-hour concentration is scaled by 0.07 based on EPA guidance, by 10/24 to account for

limited work day, then adjusted to account for 4 months of peak emissions (site preparation), 7.5 months of reduced emissions (post site

preparation), and two weeks of zero emissions.

Scale Factors to estimate impact concentrations other than one hour based on Average I-hr as 1.00, 3-hr as 0.9, 8-hr as 0.7, 24-hr as 0.4, and

annual as 0.08.

Environmental Report Documentation Impact: Section 4.6.1.1, "Air Quality Impacts from

Construction," has been revised based on the calculations from the EPA-420-R-10-018 (EPA 2010)

reference. Section 4.6.2, "Incremental Impacts from the Phase 2 Facility," has been added to Section 4.6.

Environmental Report Request for Additional Information (RAI 8) Page 68
Official Responses to Environmental Report RAls

Section 4.6.3, "Combined Impacts for the Phase 2 Facility" was also added to Section 4.6. See the

following sections and tables from the rewrite of Chapter 4:

* 4.6.1 Phase 1 Facility

a 4.6.1.1 Air Quality Impacts from Construction

* Table 4- 13 NAAQS Emission Rates during Phase I Construction

* Table 4- 14 Predicted Property-Boundary Air Concentrations From Phase I Construction and

Applicable National Ambient Air Quality Standards

* 4.6.2 Incremental Impacts from the Phase 2 Facility

* 4.6.2.1 Construction

* Table 4- 21 Comparison of NAAQS Air Emissions for Phase 2 Construction Less Phase 1 Air

Emissions

* 4.6.3 Combined Impacts for the Phase 2 Facility

* 4.6.3.1 Construction

* Table 4- 23 NAAQS Annual Air Emissions during Phase 2 Construction

• Table 4- 24 Predicted Property-Boundary Air Concentrations For Phase 2 Construction and

Applicable National Ambient Air Quality Standards

Environmental Report Request for Additional Information (RAI 8) Page 69
Official Responses to Environmental Report RAls

RAI 8

Provide additional information regarding air emissions during construction of the IFP facility.

b. Describe how the on-site fueling of gasoline and diesel vehicles will take place.

The requested air emissions and refueling information is needed to properly assess the impacts to air

quality during construction.

RESPONSE:

Diesel fuel will be stored on site during construction and will be hand pumped into construction vehicles

and other facility vehicles involved in construction. The fuel tanks will be stored on a containment-type

pad, and trucks will be driven onto the containment-type pad to start the dispensing process. The pad will

be sloped and curbed for containment. The above ground fuel storage and dispensing apparatus is selfcontained and includes a support frame on which a fuel storage tank is mounted and surrounded by a fuel

containment vessel. The ER will be revised to address on-site fueling of IIFP vehicles.

Environmental Report Documentation Impact: The 6 th paragraph of Section 4.6.1, "Air Quality

Impacts from Construction," will be revised to address on-site fueling of diesel vehicles. See the

following section below as it appears in the rewrite to Chapter 4:

Diesel fiuel will be stored on site during construction and will be hand pumped into construction vehicles

and other plant vehicles involved in construction. The fuel tanks will be stored on a containment pad, and

trucks will be driven onto the containment pad to start the dispensing process. The pad will be sloped and

curbed. The above ground fuel storage and dispensing apparatus is self-contained and includes a support

frame on which a fuel storagze tank is mounted and surrounded by a fuel containment vessel.

Environmental Report Request for Additional Information (RAI 8) Page 70
Official Responses to Environmental Report RAIs

RAI 8

Provide additional information regarding air emissions during construction of the IIFP facility.

c. Provide air impact analysis for the fuel storage and dispensing activities.

The requested air emissions and refueling information is needed to properly assess the impacts to air

quality during construction.

RESPONSE: Air impact analysis has been performed for the fuel storage and dispensing activities for

Phase 1 and Phase 2 construction. Those analyses have been included in the enclosed rewrite of Chapter

4.

Environmental Report Documentation Impact: Section 4.6.1, has been renamed_"Phase I Facility,"

has been revised and includes the air impact analysis for fuel storage and dispensing Phase I construction

activities. Section 4.6.3, "Combined Impacts for the Phase 2 Facility" was also added and includes the

Phase 2 construction air impact analysis for fuel storage and dispensing activities. See the following

paragraphs below from the enclosed rewrite to Chapter 4:

Section 4.6.1 Phase I Facility

Section 4.6.-4.6.1.1 Air Quality Impacts from Construction (Last paragraph)

Pollutant emissions and diesel fuel consumption attributable to construction activities were estimated

based on the anticipated types and sizes of construction equipment, monthly hours of operation. EPA AP42 emission factors. and fugitive dust emission rates of 1.2 and 0.3 tons of total suspended particulate pet

acre of construction area per month for initial site preparation and post-site preparation activities,

respectively. Annual totals for Phase I include combustion of 109.848 gallons of diesel fuel which would

generate VOC and HAP emissions of 1.606 pounds and 981 pounds, respectively. VOC fugitive losses

attributable to diesel fuel storage and transfer operations are estimated at 22 pounds. for an annual VOC

emission total of 1.628 pounds. The annual VOC/-IAP emissions for l-ea County NM are on the order of

5.4 million pounds. VOC/!HAP emissions attributable to IIFP Phase I construction activities represent a

ver, small fraction of the present regional emissions. Therefore, the air quality impacts attributable to

construction activities and operation of an on-site diesel fuel station would be SMALL.

Section 4.6.3.1 Construction (Last paragraph)

Pollutant emissions and diesel fuel consumption attributable to construction activities were estimated

based on the anticipated types and sizes of construction equipment, monthly hours of operation. and EPA

AP-42 emission factors. Annual totals for Phase 2 include combustion of combustion of 32.107 gallons of

diesel fuel which Would generate VOC and [lAP emissions of'477 pounds and 285 pounds. respectively.

VOC fugitive losses attributable to diesel fuel storage and transfer operations are estimated at 6 pounds.

for an annual VOC emission total of 483 pounds. As seen in Section 4.5.2.1. VOC fugitive losses

attributable to diesel fuel storage and transfer operations from Phase I construction are estimated at 22

pounds, for an annual VOC emission total of 1,628 pounds. 'T'he annual VOC/H-lAP emissions for Lea

County NM are on the order of 5.4 million pounds. VOC/HAP emissions attributable to IIFP Phase I and

Phase 2 constlruction activities represent a very small fraction of the present regional emissions.

Environmental Report Request for Additional Information (RAI 8) Page 71
Official Responses to Environmental Report RAls

Therefore. the air Cquality impacts attributable to construction activities and operation of an on-site diesel

fuel station durinR Phase I and Phase 2 construction would be SMALL.

Environmental Report Request for Additional Information (RAI 8) Page 72
Official Responses to Environmental Report RAls

RAI 9

Provide additional information regarding air emissions during the operation of the IIFP facility.

a. Describe representative capacity (make and models if available) of the gas-fired boilers to be

used at the facility and the source of the data used to estimate the boiler emissions.

The requested information is needed to properly assess the impacts to air quality during operation.

Section 4.6, "Air Quality Impacts, " of the ER (IIFP, 2009a) contains much information on air dispersion

coefficients and current annual emissions for the 50 mile radius. However, the ER does not include

information on the plant boilers or diesel generators, or on the annual emissions expected from plant

operations. In addition, the ER does not contain information on modeling input assumptions or stack

parameter assumptions, and the meteorological data used for the ER (Midland-Odessa) or another NWS

weather station have not been provided.

RESPONSE:

Boiler make and model has not been determined; however, emissions have been estimated using AP 42

Table 1.4-1 and Table 1.4-2. IIFP requires two 10,000 lb/hr boilers operating one at a time. The boiler

was assumed to be 85% efficient. Assumptions will be presented in the ER Table 15.

Environmental Report Documentation Impact: Table 4-15 (old Table 4-13), "Applicable NAAQS Air

Emissions during Phase 1 Operation of On-Site Boilers (Natural Gas)," has been revised with the

appropriate assumptions in the enclosed rewrite of Chapter 4 as follows:

Table 4- 15 Applicable NAAQS Air Emissions during Phase I Operation of On-Site Boilers

(Natural Gas)

Emission Eisos Eiso>Ui msin

Pollutant Factor EmssonsN ,1 UitEmsson

j>(lb/sct)l (bya) ;(~iya)&s

Carbon Monoxide (CO) 8.4E-05 2,065 1.03 0.0297

Nitrogen Dioxide (NOx) lE-05 246 0.12 0.0035

Particulate Matter Less Than 2.5 8.01-05 187 0.09 0.0027

Microns (PMF25) 9

Particulate Matter Less Than 10 8.076E-056 187 0.09 0.0027

Microns (PM.o)

Sulfur Oxides (SO.) 61_E-06-7 15 0.01 0.0002

Volatile Organic Carbon4AL-C) 5.5E-06

FIoN- particulate matter less tnan 1u microns; SO. -sulfur oxides; NO. -nitrogen dioxide; VUL - Volatile Organic Caruon; .u-caroon monoxide

Source AP 42 Table 1.4-1 and lable 1.4-2 Emission Factots For Criteria Pollutants and GIrenhouse Gases Fromt Natural Gas CombUstion

L_ Assutnntions: Emission Factors from EPA -APF- 42. 1.4 natural eas emissions-ulicontrolled One Boiler - 10.0001bhr (iS 85% efficiency

Environmental Report Request for Additional Information (RAI 9) Page 73
Official Responses to Environmental Report RAIs

RAI 9

Provide additional information regarding air emissions during the operation of the IIFP facility.

b. Describe representative make and models of the diesel generators to be used at the facility,

estimate the hours per year that the generators will be in use, and provide the source of the data

used to estimate the generator emissions.

The requested information is needed to properly assess the impacts to air quality during operation.

Section 4.6, "Air Quality Impacts, " of the ER (IIFP, 2009a) contains much information on air dispersion

coefficients and current annual emissions for the 50 mile radius. However, the ER does not include

information on the plant boilers or diesel generators, or on the annual emissions expected from plant

operations. In addition, the ER does not contain information on modeling input assumptions or stack

parameter assumptions, and the meteorological data used for the ER (Midland-Odessa) or another NWS

weather station have not been provided.

RESPONSE:

The diesel generator make and model have not been determined; however, emissions have been estimated

using AP42 Table 3.4-1 and Table 3.4-2. IIFP standby generator will have an expected output of 530 HP

and a firewater diesel pump with an output of approximately 75 HP. Emission data have been extracted

from AP42 Tables 3.4-1 and 3.4-2 and modified based on the horsepower size from web site

www.airguality.utah.gov to more conservative emissions. Additionally, air emissions from the on-site

hydrogen generator have been estimated from vendor data.

Environmental Report Documentation Impact: Chapter 4 of the ER was rewritten to address Phase 1,

Phase 2, and the delta between the two phases. The various sections and tables listed below deal with the

emissions from the generators and the assumptions for operations. See the following sections and tables

from rewrite for Chapter 4(provided in a separate document as part of the official RAI ER response package):

* 4.6.1.2 Air Quality Impacts from Operations

* Table 4-16 Applicable NAAQS Air Emissions during Phase I Operation of On-Site Generators

and Fire-Water Pump

* Table 4- 17 Applicable NAAQS Air Emissions during Phase 1 Operation of On-Site Hydrogen

Generation at the Hydrogen Generator Stack

" Table 4- 18 Phase I Operations Applicable NAAQS Air Emissions

* 4.6.2.2 Operations

* Table 4- 22 Differential in NAAQS Air Emissions between Phase 1 and Phase 2 Operations

" 4.6.3.2 Operations

" Table 4-26 Applicable NAAQS Air Emissions during Phase 2 Operation of On-Site Hydrogen

Generation at the Hydrogen Generator Stack

• Table 4- 27 Phase 2 Operations NAAQS Air Emissions

Environmental Report Request for Additional Information (RAI 9) Page 74
Official Responses to Environmental Report RAIs

RAI 9

Provide additional information regarding air emissions (luring the operation of the IIFP facility.

c. Describe the methods/analyses used to estimate the annual emissions from the facility, by

pollutant, including the model (name and source of the model) used for estimating annual

gaseous effluent concentrations, and modeling inputs and assumptions.

The requested information is needed to properly assess the impacts to air quality during operation.

Section 4.6, "Air Quality Impacts, " of the ER (IIFP, 2009a) contains much information on air dispersion

coefficients and current annual emissions for the 50 mile radius. However, the ER does not include

information on the plant boilers or diesel generators, or on the annual emissions expected from plant

operations. In addition, the ER does not contain information on modeling input assumptions or stack

parameter assumptions, and the meteorological data used for the ER (Midland-Odessa) or another NWS

weather station have not been provided.

RESPONSE:

Process emissions from the IIFP Facility were estimated with the following assumptions:

a. Scrubbers assumptions:-primary, secondary and tertiary with efficiencies 80%, 95% and 99%

respectively (Total units-2 primary, 2 secondary, 2 tertiary).

b. UF 4 and Oxide Dust Collector Systems assumptions: 1% of hopper solids feed to primary dust

collectors. Each dust collector has 99.5+% efficiency (Total of 4 dust collectors for Phase land 6 for

Phase 2).

c. UF 4 Vacuum Transfer Dust Collector System has primary plus secondary filter with 99.5+ %

efficiency and 99% efficiency, respectively.

d. Calcium Fluoride Dust Collector System only has a primary filter and is 99.5+% efficient from the

1% solids input. Dust Collector operates 4 hours per day = lb/hr x 310 days/yr.

e. Lime Dust Collector 99.9% efficient, only used during unloading.

f. Lb/yr = lb/hr x 8,760 x 0.85 on stream factor.

In the rewrite to Chapter 4, Sections 4.6.1, 4.6.2, and 4.6.3 deal with the NAAQS air emissions from the

boilers, generators, and fire water pump during Phase I and Phase 2 operations with the differential also

shown in the rewrite. Section 4.6.4 deals with the process air emissions from Phase 1 and Phase 2

operations through the process scrubbers and dust collectors. Modeling was addressed in Section 4.6.4.2.

Environmental Report Documentation Impact: See the Chapter 4 rewrite (provided in a separate

document as part of the official RAI ER response package) for following sections dealing with NAAQS

air emissions from the operations of the boilers, generators, etc. and process emissions not captured by the

process scrubbers and dust collectors. Modeling is addressed in Section 4.6.4.2.

0 4.6.1 Phase I Facility

* 4.6.2 Incremental Impacts from the Phase 2 Facility

* 4.6.3 Combined Impacts for the Phase 2 Facility

* Table 4- 29 Process Emissions from the Operation of the IIFP Facility

* 4.6.4 Description of Gaseous Effluents

* 4.6.4.2 Calculation of Dilution Factors and Pollutant Dispersion

Environmental Report Request for Additional Information (RAI 9) Page 75
Official Responses to Environmental Report RAls

* Table 4- 30 Dispersion Coefficient Formulas Recommended by Briggs

* Table 4- 31 Average Annual Dilution Factors by Sector and Distance for Lea County, NM

(sec/m3)

Environmental Report Documentation Impact: Section 4.12, "Public and Occupational Health

Impacts," has been updated in the rewrite to Chapter 4 (provided in a separate document as part of the

official RAI ER response package) addressing the emission data. See the following sections and table

below addressing the health impacts from the operational emissions data from Phase 1 and Phase 2

operations:

* 4.12.1 Non-radiological Impacts

* 4.12.1.1 Site Preparation and Construction

* 4.12.1.2 Routine Gaseous Effluent

* Table 4-37 Estimated Annual Non-Radiological Gaseous Effluent from Phase 1 Operations.

* Table 4- 38 Estimated and Bounding Radiological Releases from the Stacks during Phase 1

Operations

* Table 4- 39 Estimated Annual Non-Radiological Gaseous Effluent from Phase 2 Operations

* Table 4- 40 Estimated and Bounding Radiological Releases from the Stacks during Integrated

Phase 2 Operations

* 4.12.1.3 Routine Liquid Effluent

a 4.12.2.2.2 Public and Occupational Exposure Impacts

* Table 4- 41 Annual and Committed Dose Equivalents for Exposures to the MEI from

Gaseous Effluents from Phase I Operations

* Table 4- 142 Annual and Committed Dose Equivalents for Exposures to the Nearest Resident

from Gaseous Effluents during Phase 1 Operations

* Table 4-43 Annual and Committed Dose Equivalents for Exposures to the ME1 from

Gaseous Effluents from the Integrated Phase 2 Operations

• Table 4- 44 Annual and Committed Dose Equivalents for Exposures to the Nearest Resident

from Gaseous Effluents during Integrated Phase 2 Operations

* Table 4-45 Estimated Dose Rates for Site Boundary Locations, MEI, and Nearest Resident

for Phase I or Phase 2

* Table 4- 46 Phase I Collective Dose Equivalents to All Ages Population (Person-Sv) (gas

release pathways)

* Table 4- 47 Phase I Collective Dose Equivalents to All Ages Population (Person-rem) (gas

release pathways)

* Table 4- 48 Phase 2, Collective Dose Equivalents to All Ages Population (Person-Sv) (gas

release pathways)

0 Table 4- 49 Phase 2, Collective Dose Equivalents to All Ages Population (Person-rem) (gas

release pathways)

Environmental Report Request for Additional Information (RAI 9) Page 76
Official Responses to Environmental Report RAIs

RAI 9

Provide additional information regarding air emissions during the operation of the IIFP facility.

d. Provide the stack parameter assumptions such as stack height(s), stack diameter, gas exit

velocity, and stack gas exit temperature.

The requested information is needed to properly assess the impacts to air quality during operation.

Section 4.6, "Air Quality Impacts, " of the ER (IIFP, 2009a) contains much information on air dispersion

coefficients and current annual emissions for the 50 mile radius. However, the ER does not include

information on the plant boilers or diesel generators, or on the annual emissions expected from plant

operations. In addition, the ER does not contain information on modeling input assumptions or stack

parameter assumptions, and the meteorological data used for the ER (Midland-Odessa) or another NWS

weather station have not been provided.

RESPONSE:

Former Table 2-2, "IlFP Plant Major Vent Stacks," provided the stack height for five (5) vent stacks. The

table will be revised to include the stack diameter, gas exit velocity, and the gas exit temperature for those

stacks as well as 9 other stacks that have been added and renumbered as Table 2-3.

Environmental Report Documentation Impact: Former Table 2-2 showing five (5) stacks has been

deleted and replaced with Table 2-3 showing fourteen (14) vent stacks with an additional column

displaying the stack diameter, stack exit gas velocity, and gas exit temperature.

Table 243_IIFP Major Process Vent Stacks

(0 1) Plant KOI

Scrubbina System

Stack

Slightly East of

the DUF 4

Process

Building

90 20-100 f IF/SiF.4/13hL

4

229-1.149

Ambient

8

(02) DUF4 Dust Slightly East of

Collector S-t DUF.. Process 80 3.800-7,600 UF 4

/t IF 21.776

Sstem Building Ambient

Environmental Report Request for Additional Information (RAI 9) Page 76
Official Responses to Environmental Report RAIs

Stack

Stack Identification Estimate Diameter

Stck bentiatn Approximate Approximate Ranie of Vent Main Constituents (in) Stack

(Numbe r) ats Location Height" (ft) Flow Ratesb in Flow Stream Velocity

Description (/iin) (ft/mi)

Temperature

_8

(03) FEP West Side of Uranium Oxide/ 10888-

Clet Collector FPDust FEP Process 80 3.800-7.600 F/BF,776 Svst~ern B- uHl iI Building Ambient Am ien

Particulates/SOV/ 8

(04) Utilities Roof of Utilities NO,_VOC/

Boiler Stack B u ilding Methane/CO/TOC

300 0F

8

(05) (Future Phase Northeast

2 Plant) Oxide Corner of Future Uraniumn 10.888-

Dust Collector Oxide Process 0Oide/IF 21776

System Building Ambient

12

(06) Laboratory East of Various trace 3 800-5,100

Hood Stack Laboratory ,0004,000 reagent chemicals

Ambient

8

(07) Calcium Southwest Particulates as 8,600-

Fluoride Dust Corner of the 35 3,000-5,000 CaF, 14D4

Collector EPP

Ambient

8

(08) Decon Dust East of Decon Trace Uranium & 8,600- (08) 80 3.000-5 000 Metal Grit or Sand I2

Collector Stack Builig

Ambient

42

(09) Lime Dust Northwest 35 Particulates as 39-78

Collector Stack Corner of EPP ___).500-3,000 I H3

Ambient

Particulates/SO 2!

N(0O OOa./voc/ -8 (10) CaF`, Roof of EPP Methane!CO!TrOC

Combustion Dryer Roon 35 30-100 /CO/ 86-300

Stack Buildin500 /CO_50

Environmental Report Request for Additional Information (RAI 9) Page 77
Official Responses to Environmental Report RAIs

Estimate Dianeter,

Stack Identification Approximate Approximate Range of Vent Main Constituents (iiin) Stil

(Nunmber) andb n Location Heighta' (ft) Flow Ratesb in Flow Stream Velocity

Description ( 3/Min) (ft/epii)

Teniierature

Stearn/Particulates 8

SI)WateNOVOC/M 143-300

(I WtrEast of EPP 35 50-100 cthane/N---VCO/TO

Evaporator Stack Building ethaneiCOiTOC!C 212 TF

East side of 4

(12) 1-I2 Generation Plant near 35 214-283 2/N7/WO/CJ C 2,454-3.245

Stack sanitary waste Co

treatment 250

8

(13) DUF-j

Vacuum Transfer Roof of FEP Particulates as 13.753-

Dust Collector Building 8(_ 4,800-10.600 UF4 30.372

Stack Ambient

8

(14) B2 0 3 Silo Above B2093 Particulates as 5,733-

Dust Collector Silo Building 80 2.000-4,200 BO30 12.041

Stack S B--R

Ambient

'feet-multinlv by 0.3048 to Lx, meters

b l, i", t-noltipI v h' , (I 0)I) 17 hI, aOl nrH|ihi mol'ItrR

7 io L! cubi, mcicrs 1-11 r 1-1 1 F- I il QX QN; , 'r- fj .;.A, 012 0.. -,,~•T~la'b I ]•. - [ Tr•nhtm T,•trM'hu•virlo

S02 - Sulfur Dioxide NO. Nitrocen Oxides VOC -- Volatile Oreanic Chemicals CO Carbon Monoxid&

TOC Tolal Organic Chemicals CO. Carbon Dioxide Cal-, Calcium Fluoride Ca(OH); Calcium Hydroxide

N, Nitrocen O. OxVyen H 1-1,0 Water B1.0 Boron Trioxide

Environmental Report Request for Additional Information (RAI 9) Page 78
Official Responses to Environmental Report RAIs

RAI 9

Provide additional information regarding air emissions during the operation of the IIFP facility.

e. Provide the five years (1987 to 1991) of hourly meteorological data from the Midland-Odessa,

Texas, National Weather Service (NWS) station that were used in the ER.

The requested information is needed to properly assess the impacts to air quality during operation.

Section 4.6, "Air Quality Impacts, " of the ER (IIFP, 2009a) contains much information on air dispersion

coefficients and current annual emissions for the 50 mile radius. However, the ER does not include

information on the plant boilers or diesel generators, or on the annual emissions expected from plant

operations. In addition, the ER does not contain information on modeling input assumptions or stack

parameter assumptions, and the meteorological data used for the ER (Midland-Odessa) or another NWS

weather station have not been provided.

RESPONSE:

As shown in 3rd, 4 th and 5th paragraphs from below ER Section 3.6.1.4, "Wind," and from the 1 st

paragraph of ER Section 3.6.1.5, "Atmospheric Stability," the data came from NUREG-1790,

"Environmental Impact Statement for the Proposed National Enrichment Facility in Lea County, New

Mexico." The rationale used by the NRC for using this data is also provided in the 4 th paragraph of

Section 3.6.1.4 of the IIFP Environmental Report. The 3rd 4 th and 5 th paragraphs from ER Section 3.6.1.4

and from the Ist paragraph of ER Section 3.6.1.5 read as follows:

"In the Environmental Impact Study (EIS) conducted by the Nuclear Regulatory Commission (NRC) for

the National Enrichment Facility at Eunice, New Mexico (NRC, 2005), NRC staff examined climatology

data from four weather stations in the area. These locations include Eunice, New Mexico; Hobbs, New

Mexico; Midland-Odessa, Texas; and Roswell, New Mexico. See Table 3-25, "Weather Stations Located

near the IIFP Site," for the distances and directions of these stations from the IIFP Site and the length of

the records for the reported data.

The data from the NRC study is presented in Figure 3-57, "Wind Roses for Midland-Odessa, Roswell,

Hobbs, and Eunice for 1993." From this one-year comparison, the general wind patterns for MidlandOdessa, Hobbs, and Eunice were somewhat similar. Roswell data appeared to be different with a stronger

northerly and westerly component. The EPA requires that meteorological data be at least 75-percent

complete (with less than 25% missing data) to be reliably usable as inputs for dispersion models. Despite

the fact that Hobbs is the closest station to the IIFP Site, the Hobbs data did not meet the 75-percent

completeness criteria. However, Hobbs observations can be used for a general description of the

meteorological conditions at the IIFP Site. Midland-Odessa and Hobbs had comparable climate data

based on a comparative analysis of meteorological data at the four locations surrounding the IIFP Site.

Since Midland-Odessa was a first-order weather station with data completeness exceeding EPA

requirements, NRC used the data from the Midland-Odessa weather station for its dispersion modeling for

the EIS for the NEF.

The hourly meteorological observations at Midland-Odessa were used to generate wind rose plots.

Monthly wind speeds and prevailing wind directions at Midland-Odessa for the years 1987 to 1991 are

presented in Figure 3-58. The annual mean wind speed was 11 mph and the prevailing wind direction was

180 degrees with respect to North. The maximum five second wind speed was 70 mph (NRC, 2005).

Environmental Report Request for Additional Information (RAI 9) Page 79
Official Responses to Environmental Report RAIs

Five years of data (1987-1991) from Midland-Odessa weather station were used to generate joint

frequency distributions of wind speed (Figure 3-59) as a function of Pasquill stability class (A-F). The

stability class was determined using the solar radiation/cloud cover method. Figure 3-60, "Distribution of

Stability Classes for Midland-Odessa, 1987-1991" presents frequency distributions of wind speed and

direction as a function of Pasquill stability class (A-F). The most stable classes (E and F) occur 18.9%

and 13% of the time, respectively. The least stable (Class A) occurs 0.4% of the time. Important

conditions for atmospheric dispersion, stability class F, and low wind speeds 1 to 3 mph, occur 2.2% of

the time. The highest occurrences of the Class F and low wind speeds I to 3 mph with respect to wind

direction are 0.28% and 0.23% with south and south-southeast winds (NRC, 2005)."

The data that NRC used in that study was taken from the Environmental Report for the NEF December

2003 (LES, 2003). Tables 3.6-12 through 3.6-18 from the NEF Environmental Report below are the fiveyear data for the 1987-1991 for the Midland-Odessa station.

Table 3.6-12 Midland-Odessa Five Year (1987-1991) Annual Joint Frequency Distribution

For All Stability Classes Combined

Jan. 1, 1987-Dec. 31, 1991

Wind Speed m/s (mi/hr)

Calm = 2.53%

Page 1 of 1

Direction 0.5-1.3 (1-3) 1.8-3.1 (4-7) 3.6-5.4 (8-12) 5.8-8.1 (13-18) 8.5-10.7 (19-24) >11 (24.5) Total

N

NNE

119 702

71 291

722 563 225 57

509 556 207 58

2388

1692

NF: 64 79,5 R45 77A l 272 I 61 2103

ENE 51 382 738 I 726 170 27 2094

E 69 623 1176 713 95 15 - 2691

ESE 72 589 F 1061 557 i 75 12 I 2366

SE 70 931 1 1266 818 134 18 3237

SSE 127 1156 1555 1391 V 371 48 r4648

S 168 1755 2763 3178 820 100 1 8784

SSW 100 813 I. 1276 807 133 3136

SW 61 446 943 757 1 115 23 1 2345

WSW 68 356 667 637 191 78 1997

W 84 331 577 517 207 171 I 1887

WNW 77 244 281 269 75 51 997

NW 91 332 350 224 69 38 1104

NNW 79 500 365 228 80 20 1272

SubTotal 1371 9736 14894 12717 3239 1 784 . 42741

Environmental Report Request for Additional Information (RAI 9) Page 80
Official Responses to Environmental Report RAIs

Table 3.6-13 Midland-Odessa Five Year (1987-1991) Annual Joint Frequency Distribution

Stability Class A

Jan. 1, 1987-Dec. 31. 1991

Wind Speed m/s (mi/hr)

Calm = 0.06%

Page 1 of 1

Direction 0.5-1.3 (1-3)

N3

NNE 3 3

NE _1 0

ENE 1 2

E 3

ESE 3

SE 2

1.8-3.1 (4-7)

16

7

8

12

I5

8

10

3.6-5.4 (8-12) 5.8-8.1 (13-18)

0 0

0 0

0 0

0 0

8.5-10.7 (19-24)

0

0

0

0

0

0

0

0

>11 (24.5)

0

0

0

0

0

0

0

0

Total

19

10

8

14

18

11

12

10

0 ___ 9 ___ 0 0 SSE 0 10 0

S 3 16 n 0 0 19 S 319 SSW 2 9 _0 0_O0 0 11

SW 0 12 d 0 0 1 0 0 12

WSW 1 6 0 0 _ 0 0 7

W 0 5 0 0 0 0 5

WNW 0 i 2 0 0 0 0 2

NW 1 7 0 0 00 0 8

NNW 0 1 5 0 0 0 0 5

SubTotal 23 J 148 0 0 071

Table 3.6-14 Midland-Odessa Five Year (1987-1991) Annual Joint Frequency Distribution

Stability Class B

Jan. 1. 1987-Dec. 31, 1991

Wind Speed m/s (mi/hr)

Calm = 0.11%

Page 1 of I

Direction 0.5-1.3 (1-3) 1.8-3.1 (4-7) 3.6-5.4 (8-12) 5.8-8.1 (13-18) 8.5-10.7 (19-24) _>11 (24.5) Total

N 20 43 22 0 0 0 85 NNE 17 25 19 0 0 0 61

NE 16 32 22 0 1 0 0 70

ENE 14 46 36 0 _ 0 0 96

E 6 69 62 0 j 0 0 137

ESE 17 50 44 0 0 0 111

SE 9 48 45 0 0 0 102

SSE 15 54 64 0 0 0 133

S 25 96 138 __ _ 0 0 0 259

SSW . 12 53 59 0 1 0 124

SW 14 42 . 49 o 00 105

WSW 12 43 43 j 0 0 0 98

W 16 51 17 I 0 0 0 84

wNW.. 11 25 13 0 0 0 49

NW 18 21 14 I 0 0 0 53

NNW 15 27 9 0 r0 r I

SubTotal 237 725 856 L 0 0 0 1618

Environmental Report Request for Additional Information (RAI 9) Page 81
Official Responses to Environmental Report RAIs

Table 3.6-15 Midland-Odessa Five Year (1987-1991) Annual Joint Frequency Distribution

Stability Class C

Jan. 1. 1987-Dec. 31, 1991

Wind Speed m/s (mi/hr)

Calm = 0.12%

Page 1 of 1

Direction 0.5-1.3 (1-3) 1.8-3.1 (4-7) 3.6-5.4(8-12) j5.8-8

N 9 54 1 124 .

NNE 3 36 87 _

NE 5 __ 37 o5

ENE 0 52 93

E

SE

S

SSW

SW

WSW

4

54

411

Ill

3

13

5

36

65

103

62

164

147

S 179)

204

527

266

.................

.1(13-18) 8.5-10.7 (19-24) il(24.5) Total

20 6 3 218

3 7 5 . _ .............. ..1 .......

46 11 3 167

43 4 i 1093

G O • . . . . .......... ... . 2 5 9

1 0 9 ..................... .3t

199 52 [ 586

. .8 .. .... 9 1158

124 .1 13 1 491 . . ................ .......... .... . 2

115 11 2 "

01 22 f 7 _--316

76 21 10 251

25 7 1 130

21 4 _ 0 104

6 8 3 103

1402 285 I 57 5216

59

43 i 238 1 80 -I ~ -I - 4 3 , .

W

WNW

NW

NNW

5 39 100

4

7 36 i 57 21 4 - . .......

4 32

70n(

46

5~, ,hThi~I [ PRPO I __________ . .1 2620

Table 3.6-16 Midland-Odessa Five Year (1987-1991) Annual Joint Frequency Distribution

Stability Class D

Jan. 1. 1987-Dec, 31, 1991

Wind Speed mis (mi/hr)

Calm = 0,18%

Page 1 of 1

Direction

N

NN E

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

0.5-1.3 (1-3)

8

14

6

17

13

5

11

13

3

1.8-3.1 (4-7) 3.6-5.4 (8-12) 1 5.8-8,1 (13-18)

112 398 543

65 302 518

79 389 730

104 426 683

108 550 663

8.5-10.7 (19-24) >11 (24.5) Total

217 54 1242

2032 57_ 11I t__ 

261 58 1524

1•6 26 1411

88 15 1431

68 12 1143

124 _4_ !7 1461-_

319 1 4.3 2281

725 j 81 468_F)

_120 6 1_2.A55

104 1 21 1073'

169 1 71 --1042

95 458 497

92 514 709

98 I 818 1192

151 [ 949 2770

74 369 . 683

46 259 [ 6-42

XAJS~A4 2 42 1 182 575

W 4 I" 49 177 1 441 186 161 1018

WNW 5 T 29 81 i 244 68 50 1 477

NW 3 30 95 203 65 1 38 1T434

NNW 7 47 121 1 220 72 17 1484

SubTotal 109 1221 5798 1 11315 2954 727 . 22124

Environmental Report Request for Additional Information (RAI 9) Page 82
Official Responses to Environmental Report RAIs

Table 3.6-17 Midland-Odessa Five Year (1987-1991) Annual Joint Frequency Distribution

Stability Class E

Jan. 1, 1987-Dec. 31, 1991

Wind Speed mrs (mi/hr)

Calm = 0.00%

Page 1 of 1

Direction

N

NNE

NE

0.5-1.3 (1-3) 1.8-3.1 (4-7) 3.6-5,4 (8-12) 5.8-8.1 (13-18) 8.5-10

0 133 268 M 0 - 4 + 4- n 0 64 i 101 (}

0 v &

-

ENE

E

0

0

ESE

SE

SSE

S

SSW

SW

WSW

0

0

0

0

0

.

--.1

66 139

81 18 143 V 400 .3 ..... ................. ...... .................. .. . 131 412

236 28

259 609

380 1149

145 582

0

0

0

0

0

0

0

0

. ........

",--

. ....

1.7 (19-24) [>_.11 (24.5) Total

0 L 0 205

0 0 264

0 o-- r -1 ... ...... ...... . g 3 ....

o 0 ,i. 0. 543t•

0 0 1529

0 T_72

0 1 0._j462

0 _______ 322

0 0 325

0

0

65 397

60 262

-0

(1-

W 0 42 283 0

0

WNW 0

WNW 0 0 1 166 4 - + NW

NNW

0

0

36 130

50 190

98 187

198 i 5820

0

0

0 0 2166

0 0 [240

S _- 285 -

0 0 17809 ____________ .4 SubTotal 0 0

Table 3.6-18 Midland-Odessa Five Year (1987-1991) Annual Joint Frequency Distribution

Stability Class F

Jan. 1. 1987-Dec. 31, 1991

Wind Speed mis (mi/hr)

Calm= 2.07%

Page 1 of 1

Direction 0.5-1,3 (1-3)

N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

79

314

29

35

51

100

121

78

1.8-3.1 (4-7) 3.6-5.4 8-12) 5.8-8.1 (13-18) 8.5-10.7 (19-24)

3440 0 0

137 0

234 _0 0..o

509 ] 0 0 0

_>11 (24.5) 1Total

0 f423

0. 12

0 0

O 286

0 299

0 .6

0 11770

0 523 8

0 267

0 212

0 204

0 17

870 I a 0 0

670 1 0 0

1009 I 0 0 0

450 I1 0 0

SW

WSW

W

45

50

59

222

162

0 0

0

0_

0

0

WNW S 7

145 J 0

116 0

203 0

0

0

0

.4 - 4 NW 62 0 0 265

NNW 53 291 0 0 0 0 344

SubTotal 940 4863 i 0 0 0 0 5803

Environmental Report Documentation Impact: None

Environmental Report Request for Additional Information (RAI 9) Page 83
Official Responses to Environmental Report RAls

RAI 10 - Provide additional information regarding accident analyses.

Describe how the release rates required to exceed consequence levels at the IJFP facility boundary are

determined from the Goode (1995) paper referenced in Section 4.1.2, "Consequence Analysis" of the

IIFP Integrated Safety Analysis (ISA) Summary, (IIFP, 2009b).

This information is needed to evaluate the IIFP analysis so that accidents can be presented in the NRC

EIS. Neither the ER nor the ISA provide this information.

RESPONSE:

The Goode 1995 reference cited in the ISA Summary provides a descriptive overview of HGSYSTEM

evaluations for HF releases at the Paducah and Portsmouth gaseous diffusion plants; however, the Goode

1995 reference does not directly produce the release rates cited in the ISA Summary for the IIFP project

(4 lb/hr and 91 lb/hr release rates to produce consequence levels 2 and 3). Instead, the release rates cited

in the ISA Summary are based on preliminary calculations that were developed as part of the conceptual

design.

The conceptual design calculations applied HGSYSTEM to estimate the steady release HF release rate

that would produce each of the eight conditions shown in the table below. For the purpose of evaluation,

the distances to the site and property boundaries were assumed to be 200 meters and 900 meters,

respectively. The AEGL2 and AEGL3 values were assumed at 0.82 mg/m3 and 19.6 mg/m3 , respectively.

Releases were evaluated for FI and D2.5 atmospheric conditions. The bolded results in the "Required HF

Release Rate" column are cited in the ISA Summary.

Based on these Produce this HF At This Required HF Required HF

Index Atmospheric Concentration Downwind Release Rate Release Rate

Conditions (mg/mr3) Distance (m) (kg/sec) (lb/hr)

01 Fl AEGL2 = 0.82 200 2.85E-05 0.23

02 F1 AEGL3 = 19.6 200 7.28E-04 5.8

03 F1 AEGL2 = 0.82 900 3.50E-04 2.8

04 F1 AEGL3 = 19.6 900 9.05E-03 71.8

05 D2.5 AEGL2 = 0.82 200 5.05E-04 4.01

06 D2.5 AEGL3 = 19.6 200 1.15E-02 91.3

07 D2.5 AEGL2 = 0.82 900 9.67E-03 76.7

08 D2.5 AEGL3 = 19.6 900 2.06E-01 1635

The release rates determined by HGSYSTEM, as described in the IIFP ISA Summary, Section 4.1.2, were

explicitly developed as part of the early Process Hazards Analysis (PHA) to identify whether prevention

or mitigation measures may be needed. However, these release rates were not applied beyond the early

PHA stage of the project. In support of the ISA, all site boundary consequence calculations for all

postulated accidents are based on exclusively on the Gaussian Dispersion equation. None of the accident

consequence calculations or conclusions is based on HGSYSTEM. Because the HGSYSTEM results were

preliminary and do not support any of the results or conclusions of the ISA, the discussion about

HGSYSTEM will be removed from the ISA Summary.

Environmental Report Request for Additional Information (RAI 10) Page 84
Official Responses to Environmental Report RAls

Environmental Report Documentation Impact: The 5 th paragraph of Section 4.1.2, "Consequence

Analysis," of the ISA Summary will be deleted as shown below:

The H6SYSTEMS dispersioi model (Goode. 1995) was used to calculate release rates required to exeed

criteria concentr-ations at tile si4e boundary 4for hypothetical HE releases. Ik is estimated that r-elease rates

4f 4 lb/lw- are required to exceed interme(diate (Categoi'; 2) con~sequencee levels and 91 lb/hr- to exee~d

high (Category 3) ,o..seq.i..n. levels at. the site bounda.. .. . I. is anticipated that .m i.. .ediate plan

e.e.gency r.esponse to suc. an incident uld reduce the dur.ation oC the release and mitigae any off site

Environmental Report Request for Additional Information (RAI 10) Page 85
Official Responses to Environmental Report RAls

RAI 11

Provide additional information regarding groundwater.

a. Provide information about the existing site groundwater monitoring well network and indicate

whether a baseline ground water quality assessment will be established. Clarify what role if any

the Cunningham Plant monitoring wells, mentioned in the ER, Section 3.1.2, "Description of Offsite Areas, "willplay in the groundwater assessment. Specify whether the following information

is available for review onsite or can be submitted for reference:

* location of existing groundwater monitoring wells,

* New Mexico well registry numbers,

* well capacity (gpm),

* well depths,

* groundwater quality data, and

• any other relevant available information.

This information is needed in order to analyze local and regional groundwater resources to provide

sufficient detailfor inclusion in the EIS.

RESPONSE:

Section 3.4.15.7," Historical and Current Data from Site Wells," will be revised to include the location of

the existing Xcel Energy groundwater monitoring wells, well depths, and groundwater quality. Xcel

Energy has analyzed groundwater for a limited number of constituents. IIFP is proposing four monitoring

wells that will be sampled and analyzed for constituents that will be present at the I1FP facility. IIFP will

also sample for analytes that exceed standards in Xcel Energy monitoring wells.

Environmental Report Documentation Impact: Section 3.4.15.7 will be revised to include requested

information above. The text and Figure in Section 3.4.15.7 will be replaced with the following text,

figure, and table. Section 3.4.15.7 will be revised as follows:

3.4.15.7 Historical and Current Data from Site Wells

Four irrigation wells are on the IIFP site. See Figure 3 30, "Water Wlells Located oth

wroposed Uin Site" for loeations of Iheie iadrigation ondtorgells. FO!- th M3 monitolrn well ir the

Enpper !ef quadrant, the depth to 1ater (5T5t) is 16.8 n (55 ft) and the total depth (TD) is 50 m (1 64n f!).

Theý 4 well in the lowerý left quadrant has a DTW ol.3m (70 ft) and TD 4f57.9 in (190 f4).Th

irrfigatifn N42 well in the upper- right quadranit possessies a PTA 4f 16.8 m (55 4i) a;40 - TDP of 6.0.1 FN

(198 A). The other M5 well an the site ini the lower- r-ight quadr-aft has a DTNN of 2 1.3 m (70 Ai) and a TD

Four wells are located in Section 27 of the IIFP Site. See Fig'Ure 3-32 for the location of these wells

within Section 27 of the IIFP Site. Initial depth to groundwater (DTGW) in M3 (supply well for Xcel

Energy Maddox Station) was 16.8 m ('55 ft) when completed in 1965. Three Xcel Energy. Cunninghian'

Station monitoring wells are located along a north-south axis close to the western boundary of Section 27

and have been monitoring for DTGW as recently as November 2009 (GLEI, 2010d). DTGW within these

wells ranges from 18 in to 20.4 m (59 ft to 67 ft) below .round surface (bgs).

Environmental Report Request for Additional Information (RAI 11) Page 86
Official Responses to Environmental Report RAIs 6546O ". 6549500 =- 665200" 666600 ' " 665800 1 666100 1

International Isotopes Fluorine Products N

Well Locations

- Section 27 Bound ary

- IIFP Faciliy Boundoly

Q() IIFP Well Locations; | I 1ý 5 I -0 I",000 FeJX••el

Figure 3- 3_32 Water Wells Located oin Section 27 of the Proposed llFP Site

The Xcel Energy Cunnineham Station is located just west of Section 27. The Cunningham Station

operated with an unlined cooling tower and boiler cleanout pond for a number ofycars. The pond has

recently been lined. Xcel Energy monitoring wells located alonmg the western IIFP Section 27 boundary

were installed to monitor contaminants in groundwater that potentially originated from cooling water

pond and/or agaricultural fields. Shown in Figure 3-32 are monitoring wells locations within Section 27

around the Xcel Energy Cunningham Station (CU6. CUJ7, and CU8) for which water quality data has been

collected since 2004. Data from these monitoring well are shown in Table 3-10 (GLEI, 2010d). Results

that exceeded New Mexico Water Quality Control Commission (WQCC) Standards for Groundwater are

bolded text. CU8 consistently exceeded standards for sulfate and total dissolved solids. CU9 consistently

exceeded standards for sulfiate, chloride, and total dissolved solids. Groundwater quality data has not been

obtained for the Xcel Energy Maddox Facility supply well (M3).

Four monitoringv wells are proposed tor the I IFP use. Three monitoring, wells are proposed down gradient

(south) from the DUF 6 Cylinder Storage Pad. the Cylinder Pad Stormwater Retention Basin, and the

Stormwater Retention/Evaporation Basin. One monitoring well is proposed up gradient (north) from the

Environmental Report Request for Additional Information (RAI 11) Page 87
Official Responses to Environmental Report RAIs

primary production facility iust within the 1.2 ha (40-ac) security fence fir the IIFP Facility. Refer to

Figure 2-10. "IIFP Facility Site Plan."

An application for the Ground Wwater Discharge Permit has not been submitted to the Ground Wwater

Quality Bureau (GWQB) of the New Mexico Environmental Department., 4+t4-The GWQB-has

tentatively agreed to give approval to the proposed mfonitorinlg weil leeations pr-iet to i'ssuing the

Grountdwater Di;cha,,ge Perm.i has issued a conceptual monitoring plan that is subject to change as more

information becomes available during the discharge permit application process. The GWQB tentatively

agrees with the number and location of down gradient wells, but anticipates up to four up gradient wells

may be needed along the east and northeast side of the IIFP depending on the hydrologic information

provided during the application process. NMED will require that total dissolved solids, sulfate. chloride,

nitrate as nitrogen, total Kjeldahl nitrogen. fluoride, and isotopic uranium be analyzed for on a quarterly

basis (NMED, 2011).

Environmental Report Request for Additional Information (RAI 11) Page 88
Official Responses to Environmental Report RAIs

Table 3- 10 Site Water Quality As Depicted From Monitoring Wells froni Xcel Energy Cunninoham Station

2004 2005 2006 2007 2008 2009 2010

2i27 1 3,29 63 23 5929 12/15 3.28 616 2'27 2(1 3,2 1 627 ,5 125 2128 5,15 1 814 124 316. 52 SI'27, 11i8 3i 0

CU6 Monitoring Well

SO, 66 66 63 61 64 64 61 L1 16 65 62 6L5 4 SI 58 70 7'2 64 69 66 66 65

CI 26 25 24 2 266 28 26 24 27 3' 2 29 __ l3 37 26 31 32 30 32 33 35 NS

S NO • 10.2 10.2 10.2 11.1 10.2 10.2 10' 2 10..2 13.3 10.0 10 l 110.0 11.1 10.2 10.2 10.0 10. 10.0 90 9 .0 N SS

NOI-N 1-3 23 2.3 2.5 2.3 2.3 2.3 23 2.3 3.0 23 3 23 2.5 2.3 2.3 23 2.3 2.3 2.0 0 2.3

pH 7.5 7 T4 7.5 7.3 7-5 7,6 7.5 7.3 7.5 7.4 7.3 7. 5 7.5 7.5 7.3 7.4 7.4 7.3 7.4 N N INS

TDS 377 365 363 354 354 359 364 355 384 365 378 378 370 336 348 383 376 358 396 357 363 3j92

II 047 0.85 105 0.03 0.06 (1.02 001 (114 0.09 003 0 13 0.01 O-I1l NS 00' 0504 004 NS 0.32 007 NS NS

CU8 Monitoring Well

SO, 782 742 714 712 716 732 672 666 636 662 652 658 6,9 674 628 617 637 619 605 590 593 588

CI 136 135 132 136 130 133 2119 130 118 130 126 128 129 134 121 122 135 126 124 123 126 INS

NO, 1581 18.2 182 20118 18.2 199 19.9 19.9 19.0 19.9 18 19 19 19.0 16.8 19.0 21 19 19 19 19 N1S

NOI-N 3.4 4.1 41 4.7 4.1 4,5 45 4.5 4.3 4.5 4ý1 4.3 4.3 4.3 3.8 4.3 4.7 4.3 4.3 4.3 4.3 4.5

711- T2 6.7 7A 7.2 7.(1 7.2 7.3 72 7.1 7.3 7.1 6.9 7.1 7.2 72 72 73 7.1 7.0 7.0 NS NS

TDS 1569 1551 1536 1505 1502 1510 1492 1456 1479 1449 1456 1405 1379 1382 1364 1387 1357 1345 1351 1282 1277 1285

3 0.66 1.0 0.3 01 1 01 1 0.0 0.3 0.3 0.0 0.4 00 0.3 M'S 1-1 01 0.1 NS 0.6 0.3 NS NS

CU9 Monitorin' Well

SO., 778 743 704 7201 684 678 690 685 647 704 731 707 557 733 740 711 743 711 707 685 681 692

CI 525 414 408 390 429 483 504 541 521 557 527 481 496 463 492 412 399 395 384 378 383 NS

NO, 12A 14.2 14.2 154 15.1 12.0 18.2 19.0 15.1 1910 15 13 15 8.0 26 1 182 20 17 16 19 18 NS

NQ3N 327 32 3.2 3.6 34 27 4.1 4.3 3.4 4.3 3A 29 3.4 1.8 i.9 4.1 4.5 3.8 36 43 4.1 4.3

71._33 6.7 74 7.2 73 72 72 7.2 7.2 7.3 73 7.1 73 7.3 7.3 7.3 73 73 7.1 73 NS NNS

TDS 2202 2202 1969 1924 1964 20158 2105 2147 217A 2169 2206 2101 20186 2057 2012 1994 1951 1893 1870 1837 1838 1835

B 0.6 11l 0.4 0.1 0.2 0 1 00 01 013 0.1 014 0.0 03 NS I.I 10. 0.1 NS 0.7 0.3 N-S N S

Source: GLE1 201 Od. Results that exceeded New Mexico WQCC Standards for Groundwater are bolded.

SO, - Sulfate CI - Chloride NO, - Nirate NON - Nitrate as Nitrogen oH - Hvdroisen Ion Concentration TDS -Total Dissolved Solids B -Boron

Environmental Report Request for Additional Information (RAI 11) Page 89
Official Responses to Environmental Report RAIs

RAI 11

Provide additional information regarding groundwater.

b. Describe the proposed site groundwater monitoring well network to include information on well

locations, total depths, and well capacity (gpm).

This information is needed in order to analyze local and regional groundwater resources to provide

sufficient detailfor inclusion in the EIS.

RESPONSE:

Four monitoring wells are proposed for the IIFP use. Three monitoring wells are proposed down gradient

(south) from the DUF 6 Cylinder Storage Pad, the Cylinder Pad Stormwater Retention Basin, and the

Stormwater Detention/Evaporation Basin. One monitoring well is proposed up gradient (north) from the

primary production facility just within the 40-acre security fence for the IIFP Facility. Refer to Figure

RAI 11-b 1, "IIFP Groundwater Monitoring Well Locations." An application for the Ground Water

Discharge Permit has not been submitted to the Ground Water Quality Bureau (GWQB) of the New

Mexico Environmental Department. The GWQB has issued a conceptual monitoring plan that is subject

to change as more information becomes available the discharge permit application process. The GWQB

tentatively agrees with the number and location of down gradient wells, but anticipates up to four up

gradient wells may be needed along the east and northeast side of the IIFP Facility depending on the

hydrologic information provided during the application process. NMED will require that total dissolved

solids, sulfate, chloride, nitrate as nitrogen, total Kjeldahl nitrogen, fluoride, and isotopic uranium be

analyzed on a quarterly basis (NMED, 2011).

Environmental Report Request for Additional Information (RAI 11) Page 90
Official Responses to Environmental Report RAIs

Security Related Information - Withhold from Public Disclosure in accordance with 19 CFR §2.390

-~ (. (~P)s

[j~..

*v1.

i!~ I~______ j ____________

-V ... <<

M~s o.~W,5P

I Vt

Security Related Inftofnation

Withholdfrom Public Disclosure

In Accurdance With 10 CFR §2.390

40Aor~imPLT 1 PLAN cONFIIDENTtAL

-FEPi0UP FACiUT' .-.-

l~crccMr-000N nff

Figure RRA 11-b-i IIFP Groundwater Monitoring Well Locations

Environmental Report Documentation Impact: Section 3.4.15.7 will be revised to include requested

information above. See the Environmental Report Documentation Impact for RAI 11-a. The

communications to the GWQB, "Groundwater Discharge Permit Monitoring Requirements," and the

GWQB communications, "Preliminary Description of Monitoring Requirements for the Proposed

International Isotopes Uranium De-Conversion Facility near Hobbs, New Mexico," will be included in

Appendix B of the Environmental Report as below:

Environmental Report Request for Additional Information (RAI 11) Page 91
Official Responses to Environmental Report RAls

Tut national IsotoPes )[r.

January 27, 2011

Mr. Clint Marshall, Hydrologist

New Mexico Environment Department

Groundwater Quality Bureau

H190 St. Francis Dr.

Santa Fe, NM 87502

Re: Groundwater Discharge Permit Monitoring Requirements

Dear Mr. Marshall:

International Isotopes Fluorine Products, Inc. (IIFP) plans to construct and operate a facility on

40 acres of land located approximately 10 miles west of Hobbs, New Mexico. The proposed

facility will be located in Section 27, Range 18 South, and Township 36 East. The facility will

utilize depleted uranium hexafluoride to produce high purity inorganic fluorides, anhydrous

hydrofluoric acid and uranium oxides. The fluoride gas products and anhydrous hydrogen

fluoride will be sold for various industrial applications. International Isotopes Fluorine Products,

Inc. (111FP) requests a letter from the New Mexico Environment Department (NMIED) Ground

Water Quality Bureau outlining the potential monitoring, and reporting requirements required

under a groundwater discharge permit for operation of their facility.

IIFT facility operations will not result in the discharge of process water into ponds. Facility

designs do include multiple contained process and storage buildings, an outdoor depleted

uranium hexafluoride cylinder storage area, a site stormwater retention/detention pond, sewage

treatment facility, and treated sewage effluent land apply area.

The Xcel Energy Cunningham Station, a natural gas fired power plant, is located just west of

Section 27. The Cunningham Station operated for a number of years with an unlined pond that

received discharges from cooling towers and boiler cleanout operations. Xcel applied effluent

from the pond to agricultural fields that are located north of the Cunningham station. The

Cunningham Station and agricultural land apply area are approximately one hall' mile west and

hydrologically tip-gradient or cross-gradient of the proposed II FP Facility.

Xcel energy has installed a number of monitoring wells to observe contaminant concentrations in

the local aquifer that may have originated from Cunningham Facility operations. Three Xccl

monitoring wells CU6, CU8 and CU9 are located on the western boundary of Section 27. NMED

Groundwater Quality Bureau Discharge Permit 1429 files indicate groundwater monitoring was

initiated in these wells in 2004 and has continued to present time. CU8 has consistently exceeded

New Mexico Water Quality Control Commission (WQCC) standards for sulfate and total

dissolved solids, and CU9 consistently exceeded standards for sulfate, chloride, and total

4137 Commerce Circle, Idaho Falls, Idaho 83401

Phone: 208-524-5300, 800-699-3108 Fax: 208-424-1411

Website: www.intisoid.com

Environmental Report Request for Additional Information (RAI 11) Page 92
Official Responses to Environmental Report RAls

JJM-2011-09 Page 2 of2

dissolved solids. A Voluntary Remediation Program Application was submitted in November 30,

2011 by Lea County New Mexico requesting a Certification of Completion and a Covenant Not

to Sue from the Groundwater Quality Bureau for the existing ground water contamination.

It is our understanding that the Groundwater Bureau will review proposed facility designs to

ensure that they will be constructed in a fashion that will minimize the potential for discharge of

pollutants to groundwater. The Groundwater Bureau will also require a monitoring and reporting

program designed to monitor groundwater quality up-gradient of the proposed facility and detect

releases from facility structures with the potential to discharge pollutants into the groundwater.

Given this brief overview of the IIFP structures and pre-existing conditions, IIFP requests that

the NMED Groundwater Quality Bureau provide an outline for facility monitoring and reporting

requirements.

Please contact me by phone at (208) 524-5300 or by email at jjmiller@iintisoid.corn if you have questions

regarding these documents.

Sincerely,

John J. Miller, CH1P

Radiation Safety Officer

JJM-2011-09

Environmental Report Request for Additional Information (RAI 11) Page 93
Official Responses to Environmental Report RAls

NEW MEXICO M

ENVIRONMENT DEPARTMENT

Ground Water Quality Bureau

P.O. Box 5469

SUSANA MARTINEZ 1190 St. Francis Drive DAVE MARTIN

Governor Santa Fe, New Mexico 87502-5469 Secretary

JOHN SANCHEZ Phone (505) 827-2918 Fax (505) 827-2965 RAJ SOLOMAN, P.E.

Lieutenant Governor www~nmenv.sfate.nm.US Deputy Secretary

February 11, 2011

Mr. John Miller, CHP

Radiation Safety Officer

International Isotopes, Inc.

4137 Commerce Circle

Idaho Falls, Idaho 83401

RE: Preliminary Description of Monitoring Requirements for the Proposed International

Isotopes Uranium De-Conversion Facility near Hobbs, New Mexico

Dear Mr. Miller:

The Ground Water Quality Bureau of the New Mexico Environment Department (NMED) has

received your letter requesting an outline for ground water monitoring and reporting requirements

for the proposed uranium de-conversion facility. The facility will be constructed by International

Isotopes Fluorine Products, Inc. (IIFP) 10 miles west of Hobbs, NM in Section 27, T18S, R36E.

IIFP presented general information about the facility to NMED at a meeting on September 8,

2010. Among several topics discussed at the meeting, IIFP presented a general site plan showing

the layout of the facility components. In addition, the parties discussed the general hydrology of

the area and ground water impacts at nearby facilities. IIFP has yet to formally submit a discharge

permit application, therefore NMED is responding to your request based on the general

information that has been received to date. The conceptual monitoring plan described below is

preliminary and subject to change as more information becomes available through the forthcoming

discharge permit application process.

Preliminary Monitoring Requirements

Ground water monitoring wells will be required, at a minimum, downgradient of the following

facility components: 1) Cylinder Pad Stormwater Retention Basin, 2) Storm Water Retention /

Evaporation Basin, and 3) Sanitary Waste Treatment Plant. Upgradient monitoring wells will be

required along the west and northwest perimeter of the IIFP. NMED anticipates up to four

upgradient wells may be needed depending on the hydrologic information provided during the

application process.

Environmental Report Request for Additional Information (RAI 11) Page 94
Official Responses to Environmental Report RAIs

John Miller, International Isotopes, Inc.

February 11, 2011

Page 2

Regional ground water flow in this area is generallyto the east-southeast. However, several

high-capacity (250-500 gal/min) supply wells for the Cunningham and Maddox power stations are

located in the vicinity of the proposed IIFP site. In addition, based on the information provided,

new supply wells for the IIFP will be installed onsite. Periodic operation of these wells may

locally affect the regional ground water flow direction near the site. Based on the hydrologic

information provided after installation of the initial wells, additional monitoring wells may be

required.

NMED will require, at a minimum, that the following analytical parameters be measured quarterly

in all monitoring well samples: 1) total dissolved solids, 2) sulfate, 3) chloride, 4) nitrate as

nitrogen, 5) total kjeldahl nitrogen, 6) fluoride and 7) isotopic uranium (

234U, 2

35U, 238u).

NMED will require ground water quality to be reported quarterly.

As stated previously, the conceptual monitoring plan described above is subject to change based

on future information that is provided by IIFP during the discharge permit application process, as

well as any other information that may become available to NMED prior to issuing the discharge

permit. If you have any questions, please contact me at 505-827-0027 or

clint,.marshall@state.nm.us.

Since ly,

Clint Marshall, Hydrogeologist

Mining Environmental Compliance Section

Ground Water Quality Bureau

xc: Mary Ann Menetrey, Program Manager, MECS

Environmental Report Request for Additional Information (RAI 11) Page 95
Official Responses to Environmental Report RAls

RAIJ1

Provide additional information regarding groundwater.

c. Describe the proposed site groundwater production wells to include well locations, total depths,

and peak and average pumping rates (gpm), and annual maximum groundwater use; and

This information is needed in order to analyze local and regional groundwater resources to provide

sufficient detailfor inclusion in the EIS.

RESPONSE:

Present production wells for Xcel Energy within the 640-ac (259 ha) site are shown in Figure 4-4, "Water

Wells Located on the IIFP Site." The depth to water in the four wells ranges from 17 m (55 fi) to 21 m

(70 ft), with the total depth ranging from 50 m (164 ft) to 60 m (198 ft).

In addition, ER Sections 3.4.6 and ER Sections 4.4 through 4.4.11 (in the Chapter 4 re-write) have been

revised to clarify water use quantities in Phase 1 construction and operation, Phase 2 construction and in

the integrated IIFP operations after Phase 2 construction has been completed.

Lea County intends to drill a production well during the 2 nd quarter of 2011. This well will be sized to

meet the production needs for Phase I and 2 operations. The proposed well will be drilled to a depth of

between 200-250 feet with a casing size of 16 inches and a capacity of 350 gpm. A second well may be

needed for emergency preparedness purposes, this well, if required, would be drilled by International

Isotopes Inc. during the construction phase of the project.

Environmental Report Documentation Impact: See Environmental Report Documentation Impact for

RAI l I-a and RAI 1-a (Section 2.1.2.14 Water Well Drilling).

Environmental Report Documentation Impact: The first paragraph of ER Section, 3.4.6 will be

revised to provide the estimated water use quantities for construction and operations for Phase 1 and

Phase 2.

3.4.6 Quantitative Description of Water Use

A well (or wells) will be drilled an average estimated distance of up to 61 m (200 fi) into the Ogallala

Aquifer. The well(s) will have the capacity to pump about 3.8 m3/min (1,000 gal/min). It is anticipated

that 7.57 mn/day (2,000 gal/day) of groundwater will be used during Phase I construction and 3.79 m'/dav

(1 ,000 gyal/day) will be consumed during Phase 2 construction. Average and peak site water requirements

for Phase I operations for all purposes are expected to be approximately 11.36 mn3/day (2,300 gal/day) and

29.53 ni'day (7,800 gal/day). respectively. Average water usage during the integrated Phase 2 operations

is anticipated to be 11.36 m3/day (3,000 gal/day) to 17 m3

/day (4,500 gal/day) with peak usage less than

37.85 m3/day (10,000 gal/day).

Environmental Report Documentation Impact: Remove Chapter 4 of the ER, Revision A in its

entirety and replace with Chapter 4 rewrite provided as a separate document in the official RAI response

package. See Chapter 4 re-write for Section 4.4 through 4.4.11 for water use quantities for construction

and operations for Phase I and Phase 2.

Environmental Report Request for Additional Information (RAI 11) Page 96
Official Responses to Environmental Report RAIs

RAI 12

Provide copies of the IIFP site land surveys.

Information from surveys is necessary to accurately depict the site in figures and to provide a centroid for

demography, environmental justice, air impacts, accident impacts, and monitoring.

RESPONSE:

Site land surveys of the IIFP Site are being conducted and will need to be confirmed. The land survey is

currently scheduled for completion in the 2"d Qtr. of 2011.

Environmental Report Documentation Impact: None.

Environmental Report Request for Additional Information (RAI 12) Page 97
Official Responses to Environmental Report RAIs

RAI 13

Provide additional information regarding employment.

a. Provide an employment curve so the peak number of employees and the date that peak is

anticipated can be determined.

The information is needed to determine the maximum impact, as driven by an increase in the region-ofinterest population, to specific socioeconomic resources. Determining the approximate outmigration/work assignment completion dates influences the impacts of reduced dependency on some

socioeconomic resources (housing and public education for example).

RESPONSE:

Employment ranges were provided in the Environmental Report for the various construction and

operations phases. Table RAI 13-a-I provides those employment ranges as well as the employment for

the decommissioning phase of the IIFP Facility.

Table RAI 13-a-I IIFP Facility Construction, Operation, and Decommissioning Employment

Year Preconstruction Construction Operations Decommissioning Total

Low High Low High Low High Low High

2011 35 70 35 70

2012 120 140 120 140

2013 120 140 80 120 200 260

2014 120 138 120 138

2015 150 180 120 138 270 338

2016 150 180 145 160 300 340

2017- 145 160 145 160

2048

2049 145 160 40 185 200

2050 40 50

2051 1 40

Table RAI-13-a-2 provides the expected peak employment of the IIFP Facility by quarter with the overlap

between construction and operations (Phase 2) projecting the maximum in the ranges shown in Table

RAI-13-a-1. It is now projected that the Phase 1 construction is complete during the 2 nd quarter 2013 with

the functional testing for Phase I operations to begin during the 3rd quarter 2013 with operations startup in

the 4 th quarter 2013. The Environmental Report will be revised to reflect these schedule changes.

Environmental Report Request for Additional Information (RAI 13) Page 98
Official Responses to Environmental Report RAIs

Table RAI 13-a-2 Peak Employment During Construction, Operation, and Decommissioning of the

IIFP Facility

Year .I . Qtr. 2nd Qtr., 3 rd Qtr. 4 th Qtr.

2011 35 70

2012 100 120 140 140

2013 140 120 80 120

2014 120 138 138 138

2015 138 138 238 318

2016 318 280 138 150

2017-2048 160 160 160 160

2049 200 200 200 200

2050 40 40 40 40

2051 40 40 40 40

Environmental Report Documentation Impact: It is projected that the Phase 1 construction will be

complete during the 2nd quarter 2013 with the functional testing for Phase 1 operations to begin during the -, rd _, quarter 2013 with operations startup in the 4 th quarter 2013. The Environmental Report will be revised

to reflect these schedule changes. The sections below will be revised as indicated in the parenthesis as

follows:

EXECUTIVE SUMMARY -subheading "Proposed License Action (Renamed subheading Revised 4 th

paragraph.)

The IIFP facility will be constructed in two phases, with Phase I completing the DUF 6 to depleted

uranium tetrafluoride (DUF 4) process and the DUF4 to fluorine products processes and the supporting

infrastructure of the phl-4facilit1. The Phase 1 Facilitvp~hnt is scheduled for startup by the end of 2013_.

IIFP plans to expand the facility de-conversion capacity by completing construction of an expansion that

wil result in aefia Phase 2 f4ant-facilitv with a scheduled start by mi4late-2016. The Phase 2 ptant-faicility

will consist of additional de-conversion capacity using a process for direct conversion of DUF 6 to

uranium oxides.

1.1 General Description of the IIFP Facility and Proposed License Action (Renamed section and

revised 5th paragraph.)

The IIFP initialPhase 1 plaftFacilit,, scheduled for operation by end of 20132 consists of two main

chemical processes that, when integrated, will comprise the Fluorine Extraction Process and Depleted

Uranium De-conversion Plant (FEP/DUP). In performing the de-conversion services, IIFP utilizes the

fluoride extracted from the DUF 6 de-conversion to manufacture high-purity silicon tetrafluoride (SiF 4)

and boron trifluoride (BF 3). These fluoride gas products are valuable materials for applications in the

solar, semiconductor, and electronics industries. In addition, anhydrous hydrogen fluoride (AHF) is a byproduct of the de-conversion process and is sold as a high demand chemical for various industrial

applications.

Environmental Report Request for Additional Information (RAI 13) Page 99
Official Responses to Environmental Report RAls

1.1 General Description of the IIFP Facility and Proposed License Action (Renamed section and

revised 8th paragraph.)

PrecGonstruction of the Phase 1 jta*f.-Lcility is expected to begin in late 2011 and startup of operations is

expected to begin in the latemid-201332. The expansion construction for athe Phase 2-t~aet facilitv is

expected to begin in 2015 and operations start up in late 2016. The "Proposed Action" term that was used

in the Revision A of the Environmental Report has been renamed "Proposed License Action." The ER

does however include the Environmental Impacts and Cumulative Effects for both the Proposed License

Action (which is the Phase I Facility) combined with the Phase 2 Facility in order for NRC to prepare an

Environmental lmnact Statement (EIS) for the intearated Phase I and Phase IIFP Facilitv. Prior to the

Phase 2 expansion, IIFP will prepare and submit an amended license application for the Phase 2 Facility.

At the end of its useful life, the pIai4llFP Facility weo-k-will be decommissioned consistent with the

decommissioning plan that is developed and submitted in the IIFP License Application, Chapter 10,

"Decommissioning".

1.2.3 Projected Construction and Operational Startup Schedules (Revised It paragraph.)

Construction of the Phase 1 pla+4-facility is expected to begin in late-early 2014-2 and startup of operations

in the 4te-mid 2013-2. IIFP intends to request an exemption for some pre -lic-ense-construction that could

start by ea4y mnid 2011. In this ER, pre-44eense construction is considered in evaluating the environmental

impacts. It is anticipated that approval for pre 14eenseeconstruction will be obtained and that some

selective construction activities will be accomplished prior to issuance of a license by NRC. These pre-

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

1.2.3 Projected Construction and Operational Startup Schedules (Revised Table 1-2.)

Major milestones are shown in Table 1-2.

Table 1- 1-2 Project Major Milestones

Milestones Projected Date

Submit Licensing Application to NRC for Phase I End of 2009 (Complete)

Facility

Environmental Report to NRC for Phases 1 and 2 End of 2009 (Complete)

Complete Start Engineering for Phase 1 _3-"•L r±ffwmmid 2011

Start PreLc - Construction 3`1 Quarter 2011

Obtain NRC License for Phase 1 3-H4iL Quarter 2011

Initiate Phase 1 Facility Construction 34-2ýd Quarter 220-42012

Complete Construction of Phase I Facility 4-2'd Quarter 2013_2

Startup Phase I Facility 4ý- 3rd Quarter 2013_2

Submit Phase 2 amended License Application 2nd Quarter 2013

Complete Phase 2 Engineering and Initiate Phase 2 4-w2L"" Quarter 2015

Facility Construction

Complete Construction of Phase 2 Facility -4- -2ld Quarter 2016

Startup Phase 2 P-aat-Facilitv 2"d Quarter 2016

Environmental Report Request for Additional Information (RAI 13) Page 1O00
Official Responses to Environmental Report RAIs

2.1 Proposed License Action (Renamed section and revised 5 th paragraph.)

Phase 1, with a projected startup date of4aermid-20134, consists mainly of two processes:

* DUF6 de-conversion to depleted uranium tetrafluoride (DUF4), i.e. the DUF 6 to DUF4 plant.

* The Fluorine Extraction Process for producing SiF 4 and BF 3 by reacting the DUF 4 produced

in the de-conversion step with the oxides of silicon (SiO 2) and boron (B20 3), respectively.

4.5.2 Proposed Schedule of Activities (Revised section.)

The following is a tentative, abbreviated schedule of proposed activities. Refer to ER Section 1.2.3,

"Projected Construction and Operational Startup Schedules," for major steps in the Proposed Aet-ionIlFP

Facility:

" Submit Environmental Report--December 2009 (complete)

* Submit Integrated Safety Analysis--December 2009 (complete)

* Submit Facility License Application--December 2009 (complete)

" Initiate Pre licensing Constr'ttiOinPreconsttruction -& 3'3 Qtr._2011

* Initiate Phase 1 Facility Construction--"ateEarly 20124-

* Achieve Phase 1 Start-up Operation-_-4=ate4th Qtr. 2013_2

• Complete Phase 2 Construction -MarehMid 2016

* Achieve Phase 2 Start-up Operation ,-a-e- Mid 2016

4.10.1 Facility Construction (Revised section.)

Pre4 ...... • construction activities are assumed to begin in 2011 and to conclude i4t-4he-fal!ofprior to the

end of 201 I when NRC is expected to approve the IlIFP license. Pre44een4i*construction activities.

described in Section 4.1.1.1. "Construction Impacts," will be preparatory in nature and will not involve

any process or safety related equipment or systems. Approximately 35 to 70 workers will be involved in

preconstruction activities delineated in Section 2.1.2. "Site Construction."

Phase I Construction

IIFP Site 1naPhase 1 construction is scheduled to begin in 201224-, with construction continuing into

2013gI.The maximum construction workforce during Phase I is anticipated to range from 120 to 140

workers during the 20124--2013-2 period.

Phase 2 Construction

An additional 30 to 40 workers will be required during the construction of the add-on buildings for the

Phase 2 Facility. Construction of Phase 2 buildings is scheduled to be accomplished in 2015-2016 with an

average construction crew of 150 to 180 workers.

4.11.4 Proposed License Action (Renumbered and Renamed, revised Is paragraph)

if'h, the . ......se ,A e ... is• und.ftaken•, pr'e licensing ........ + .... + of. t-he, Plo•oosed 1112P t ai> t .... i w,,, ll ,•;n 

in early -20 1. in- late 2012, Phas ... oie-to ...... ,G . ..•'•• ..aei,. ..... ; b rý,,: .By , 2 a• 16, Phase 2 ..... faio ,:, ... he.

Environmental Report Request for Additional Information (RAI 13) Page 101
Official Responses to Environmental Report RAIs

Pr..posed li Facilit. is ex...eted to b4 ,ufly operational. The Proposed License Action addresses only

the construction and operation of the Phase I I IFP Facility. Prior to a future expansion that results in the

Phase 2 Facility, IIFP will prepare and submit an amended license application for the Phase 2 Facility.

However. the environmental justice impacts will be assessed for the construction and operation of both

Phase I and Phase 2 Facilities (intefgrated IIFP Facility).

4.11.4.2 Site Preparation and Construction (Renumbered and revised 1 st paragraph.)

Site preparation and construction of the rfopos;ed IeIFP Facility may require a labor force of as many as

200 employees; construction employment is projected to vary depending on the site preparation and

construction activities under way at any given time. Preparation of the IIFP facility site and construction

of the IIFP *_acility is projected to take approximately 20-24 months, beginning in 201214 and ending in

2013_2. During the site preparation and construction pha-sta-,e of the project, environmental impacts

(discussed in detail in the sections noted in parentheses) may include the following: (Bullets omitted.)

4.11.4.32_ Operation (Revised 1st paragraph.)

Operation of the Proposed IIFP Facility will be expected to begin operation of the Phase 1 pleAn-facilitv in

late 20132 and the Phase 2 plim4facilitv in mwi-the fall of 2016. The facility is projected to employ as

many as 138 FTEs engaged in Phase I operations and 160 FTEs engaged in Phase 2 operations. During

the operation phasestage of the project, potential environmental impacts (discussed in detail in the

sections in parentheses) may include the following: (Bullets omitted.)

7. COST-BENEFIT ANALYSIS (Revised 3 rd paragraph.)

It must be noted that all Chapters of the ER assess, where applicable, the environmental impacts of not

only a Phase 1 near-term construction, with facility operations scheduled to begin in late 2013_2- but also

that of a later expansion to become a Phase 2 Facility.

7.1.2 Basis of Construction and Operating Costs-Benefit Estimates for- the Proposed Aetion

(Renamed section and revised Ist paragraph.)

The project construction and operation cost estimates assume that project detailed engineering begins in

mid-244420) 1, and some pr. licensing . o.. tu.6.... preconstructio activities may start by eaf--'late

2011. Upon approval of the NRC license application, the full construction is expected to begin by the end

of 2`1 quarter 2014-2 with startup of the Phase I operation for functional testing bye-L-the 2!Lg quarter of

20132-. It is assumed that the facility would not reach significant production operating levels and receipt

of revenue streams until mid- to-late 2013, after operational checkout and test production runs are

completed and operations are well underway.

8.3.10 Socioeconomic Impacts (Revised I" paragraph.)

Pre lieensing constructions at the IIFP Ssite is scheduled for early-mid-201 1, with general construction

continuing 20 to 24 months into 20132-. A peak construction force of about 200 workers is anticipated

during the period 20124--20132-.

Environmental Report Request for Additional Information (RAI 13) Page 102
Official Responses to Environmental Report RAIs

RAI 13

Provide additional information regarding employment.

b. Provide anticipated annualized wage (gross payments to employee, not total payroll costs, which

would include benefits or overhead)for the average Phase ] construction workforce employee

(not by job category).

The information is needed to determine the maximum impact, as driven by an increase in the region-ofinterest population, to specific socioeconomic resources. Determining the approximate outmigration/work assignment completion dates influences the impacts of reduced dependency on some

socioeconomic resources (housing and public education for example).

RESPONSE:

It is anticipated that Phase 1 construction will begin in 2012 with preconstruction to start in the third

quarter 2011 if the NRC license has not be received. The workforce for Phase I and Phase 2 construction

is indicated in Table RAI 13-b-I. The annualized base wage for the average Phase 1 construction worker

will be $32,700 for a 40-hour week. IIFP will work 5 days/week for 50 weeks.

Table RAI 13-b-I Maximum Employment During Phase 1 and Phase 2 Construction of the IIFP

Facility

Year 1 St Qtr. 2 nd Qtr. 3 rd Qtr. 4.th Qr.

2011 35 70

2012 100 120 140 140

2013 140 120

2014

2015 100 180

2016 180 150

Environmental Report Documentation Impact: None.

Environmental Report Request for Additional Information (RAI 13) Page 103
Official Responses to Environmental Report RAls

RAI 13

Provide additional information regarding employment.

c. Identify when Phase 1 operations workers will arrive on site (by month and year), total

operations workforce (preferably a specific estimated number, not a range), and number of

workers that will overlap with the construction workforce for Phase 1. Include an employment

curve so the peak number of operations employees and the date that peak is anticipated can be

determined.

The information is needed to determine the maximum impact, as driven by an increase in the region-ofinterest population, to specific socioeconomic resources. Determining the approximate outmigration/work assignment completion dates influences the impacts of reduced dependency on some

socioeconomic resources (housing and public education for example).

RESPONSE:

There will be minimal overlap with the ending of Phase 1 construction and Phase 1 operations. The

construction will be complete during the second quarter 2013 while functional checkout of the systems

will occur during the third quarter 2013 with startup occurring during the fourth quarter 2013. The

operations employment curve is shown in Table RAI 13-c-1.

Table RAI 13-c-1 Maximum Employment During Phase I and Phase 2 Operations of the IIFP

Facility

Year 1 st Qtr 2 nd Qtr 3 rd Qtr 4 th Qtr

2011

2012

2013 80 120

2014 120 138 138 138

2015 138 138 138 138

2016 138 138 138 150

2017-2048 160 160 160 160

2049 160 160 160 160

2050

2051

Environmental Report Documentation Impact: None.

Environmental Report Request for Additional Information (RAI 13) Page 104
Official Responses to Environmental Report RAIs

RAI 13

Provide additional information regarding employment.

d. Provide an estimate of the peak workforce (i.e., an estimated number, rather than a range is

needed to assess resources impacts in the ER) for Phase 2 construction only, the anticipated

Phase 2 construction start date (month and year), the duration of this construction phase

workforce on site (from month and year to month and year). Include an employment curve so the

peak number of employees and the date that peak is anticipated can be determined.

The information is needed to determine the maximum impact, as driven by an increase in the region-ofinterest population, to specific socioeconomic resources. Determining the approximate outmigration/work assignment completion dates influences the impacts of reduced dependency on some

socioeconomic resources (housing and public education for example).

RESPONSE:

The employment curve for Phase 2 construction as well as Phase I construction is shown in the response

to RAI 13-b as shown in Table RAI 13-b-i, "Maximum Employment During Phase I and Phase 2

Construction of the IIFP Facility."

Environmental Report Documentation Impact: None.

Environmental Report Request for Additional Information (RAI 13) Page 105
Official Responses to Environmental Report RAIs

RAI 13

Provide additional information regarding employment.

e. Provide anticipated annualized wage (without benefits or overhead) for the average Phase 2

construction workforce employee (not by job category).

The information is needed to determine the maximum impact, as driven by an increase in the region-ofinterest population, to specific socioeconomic resources. Determining the approximate outmigration/work assignment completion dates influences the impacts of reduced dependency on some

socioeconomic resources (housing and public education for example).

RESPONSE:

The annualized wage (without benefits or overhead) for the average Phase 2 construction workforce

employee is $29,600 for a 40-hour work week.

Environmental Report Documentation Impact: None.

Environmental Report Request for Additional Information (RAI 13) Page 106
Official Responses to Environmental Report RAIs

RAI 13

Provide additional information regarding employment.

f Identify when Phase 2 operations workers will arrive on site (by month andyear), total

operations Phase 2 workforce (specific number, not a range), and number that will overlap with

the construction workforce of Phase 2 and the operations workforce of Phase 1. Provide an

employment curve so the peak number of employees and the date that peak is anticipated can be

determined.

The information is needed to determine the maximum impact, as driven by an increase in the region-ofinterest population, to specific socioeconomic resources. Determining the approximate outmigration/work assignment completion dates influences the impacts of reduced dependency on some

socioeconomic resources (housing and public education for example).

RESPONSE:

The overlap in employment during Phase 1 and Phase 2 operations is shown in Table RAI 13-c-1,

"Maximum Employment during Phase I and Phase 2 Operations of the IIFP Facility." The overlap in

employment during Phase 1 and Phase 2 operations and Phase 2 construction is shown in Table RAI 13-a2, "Peak Employment during Construction, Operation, and Decommissioning of the IIFP Facility."

Environmental Report Documentation Impact: None.

Environmental Report Request for Additional Information (RAI 13) Page 107
Official Responses to Environmental Report RAIs

RAI 14

Provide reports of ecologicalfield studies.

It is our understanding that IIFP is conducting seasonal ecological surveys of the site over a one-year

period. Provide any reports generated by these surveys. Information from trip reports or quarterly

summaries is necessary to ensure complete and accurate ecology descriptions within the EIS. Given that

the studies would continue to be conducted after the Draft EIS is completed, interim reports are

important.

RESPONSE:

The vegetation survey conducted by GL Environmental, Inc. has been completed for 2010 (GLEI, 2010a).

The 2010 Vegetation Survey Report is provided to the NRC separately from these RAI responses.

Sections 3.5.3 and 3.5.4 of the Environmental Report, Revision A, will be revised to reflect information

from that survey.

Additionally, field work has been completed by GL Environmental, Inc. to evaluate the IIFP Site for the

possible presence of the dunes sagebrush lizard (called the sand dune lizard in the Environmental Report).

Their report, "Status and Habitat of the Dunes Sagebrush Lizard at the Proposed Site for the International

Isotopes Fluorine Products Facility in Lea County, New Mexico," (GLEI, 20 1Ob) is provided to the NRC

separately from these RAI responses. Section 3.5.7.2, "Sand Dune Lizard," will be revised to reflect

information from this field work.

A wildlife baseline study was started in the 3rd Quarter 2010 and is scheduled for completion in 3rd

Quarter 2011. In addition, a survey for the lesser prairie-chicken is scheduled for completion in 2nd

Quarter 2011. Interim reports on these ecological field studies are not available at this time, upon

completion, copies of these respective reports will be provided to the NRC separate from these RAI

responses. When results become available, pertinent information from these ecological field studies will

be incorporated in future revisions of the ER, as applicable.

Environmental Report Documentation Impact: The 3rd paragraph of Section 3.5.3, "Major Vegetation

Characteristics," of the Environmental Report, Revision A, will be revised to incorporate information

from the 2010 Vegetation Survey. The 4 th, 5th, and 6 th paragraphs of Section 3.5.3 will be deleted. Section

3.5.3 will be revised to read as follows:

3.5.3 Major Vegetation Characteristics

The general vegetation community type that the subject property is located in is classified as Plains and

Great Basin Grasslands. The community is further characterized by the presence of forbs, shrubs, and

grasses that are adapted to the deep sand environment that occurs in parts of southeastern New Mexico.

The Plains Grasslands north of the Mescalero Ridge on the eastern portion of the Lea County consist of

the short-grass, mid-grass, and tall-grass prairies of the National Grasslands. These grasslands extend

throughout the Great Plains physiographic province and occur within the Southern High Plains, Pecos

Valley, Redbed Plains, and Texas High Plains eco-region sections. Climate ranges from subhumid to

semiarid as these grasslands extend from east to west. The characteristic plant species that are abundant

throughout the short-grass prairie include blue grama and buffalo grass. The mid-grass prairie ecosystem

Environmental Report Request for Additional Information (RAI 14) Page 108
Official Responses to Environmental Report RAIs

is co-dominated by little bluestem, blue grama, and plains bristle grass. The tall-grass prairie is dominated

by big bluestem. These different prairie ecosystems are aggregated and reduced to one category for this

assessment and reflects a wide range of ecological properties and processes (USDA, 2004).

The Basin and Range Grassland occurs south of the Mescalero Ridge. These grasslands are higher in

elevation and climatically cooler and moister than desert grasslands and are adjacent to and intermingle

with juniper savanna ecosystems. The Great Basin Grasslands are similar to Brown's (1994) Plains and

Great Basin grasslands and Dick-Peddie's (1993) Plains-Mesa grasslands exce-pt the geographic, .. -f,7 ange 

this categry. for this assessment is, r-esti•c.ted to the Basin and Range Physi.graphic pr.. vinc.e. Diagno.sti.

plantspeei ielode " blue -Faiia, galleta, Indian ricegr-ass, and sideeats gr-ama. Some dropseeds anid

welftaan arc ccE dominmanr and gadd4 to In WIverSrty 0 ftnlij caegry.ie neret la balIIIr' 9F raSaI teR10 tO Pe

drier than the ShOltgrass Ste.ppe grass..lands an.d haVe a blenid o)fN... Mind c001 .. S.aSoi f1id anid 4f1b

species. Shrubs that arcpeseti soito with grassland vegetation of this eategoty inelude fourwing

saltbush, saca.. ist... , ...... s l soapweed yucca. SkUn. bush .. sumac, and catcall mimosa..Asts gtraland

integrade .With savanna ecosystems, m..i.or- amou.ts ftree; suc. as emory oak, alliga.i jn, .. r.....

Uhjmpr- dominated woodA-elands, are evident (USDA. 2004). The 111-1 site generally is ehai-ater-istic .f

tie Brown's (.1994') -egetation. The majority of plant species and soils present at the IIFP Site are typical

of Plains-Mesa Grassland and Desert Grassland Communities (Dick-Peddie 1993). Plains-Mesa

Grassland and Desert Grassland Communities are characterized by the presence of significant amounts of

grasses with less than 10% of total cover being forbs and shrubs. Typical grasses for Plains-Mesa

Grassland and Desert Grassland Communities are Boweloua species (gralna grasses), buffalo grass.

Galleta grass, Indian ricegrass, Aristida species (three-awn grasses), Sporobolus species (drop seed

grasses), needle-and-thread grass, and western wheatgrass. Typical shrub species present on Plains-Mesa

Grassland and Desert Grassland Comm unities are honey mesquite and Echinocereus species (hedgehog

Hai--y gr.ama is prevalent on the IIFP site and is a n-ate,1• warm. Sea

between 10 and 20 inches. The leaf blade is flat or- slightly rolled; .52a fi, ,F per.en.niatl gr.ass. Ihe heiht. io s

o.mostly basal, mlarg,-ins haifry.

See Figure 3 33.. This grass yields more if it is not ove-grazed and grazing is defeiied every 2 to 3 years

during the period of mo.st active gr-owth. I-lair:.' graina makes little growth before summer ran beguin'.

moistur-e is adequate. it mlatures frapidly'.

During exceeptionally di-, years, it produces little forage but withstands drou~ght well. in the norither-n part

of its range, this grass usually has only 1 or- 2 spikes per- seedhead and short stooHns that lFom a sd..

Fr~ither south, it groews taller, mor-e like a bunch grass, and has 2 to 4 spikes per- seedhead. it is adapted to

sandy and sandy loam soils and grfavelly loam~s and does well on soils neutr-al to slightly calcar-eous. it is

otnassociate wih ble gr1a1bt s oe dr-ought r-esistant (NRCS, 2007).

Ring Muhl' (Figure 3 3') is also observed en thesie w..ith hai..' gr.ai.. a anid other various f..bS and

grasses. Mesquite, prickly pear, ho..se c-rippler ca•cti, an. d rainbow ea•ti were also obser'ved. See Figure 3

35 fori a typical site photogr-aph of gr-ound cover- on the 1JEP site.

A vegetation survey (GLEI, 2010a) was conducted at the proposed location in Section 27, Township 18

South, Range 36 East. Lea County. New Mexico. Several data collection methodologies were employed

to determine total vegyetative cover, production of perennial grasses and shrubs, and shrub density at the

IIFP Site.

A total of eighteen plant species was observed in cover transects during the 2010 survey (Table 3-13).

The total vegetative cover was 45.1%. Of this. 97.6% of the relative vegetative cover consisted of

Environmental Report Request for Additional Information (RAI 14) Page 109
Official Responses to Environmental Report RAIs

perennial greasses. Bouieloua tracilis (blue grarna) contributed the largest portion of relative cover at

27.8%. followed by Scleronogon brevifolius (burroarass) at 4.3%. B. eriopoda (black Eramna) and

Pleuranhis iamesii (James' Galleta grass) were the next two largest contributors. These snecies

represented 2.6% and 2.7% of the relative vegetative cover, respectively (GLEI, 2010a).

Table 3- 13 List of species observed on the IIFP Site

Scien tificc Narne I C omImon-NI I:• I, ....... I I \ ... 

Croton texensis Texas Croton

Hfelianthus ciliaris Texas Blueweed

Grindetia nuda Curly-Cup Gum weed

Two unknownspecies Two unknown species

Bouteloua curileanchdla Side-oats grama

Bouteloua eriot)oda Black grama

Boutelouia gracilis Blue grama

Eiraggrostis trichodes Sand lovegrass

Lvcnrus setosus Bristly wolfstail

Muhlenbergia pungens Sandhill muhlv

Pascopj'run sminhii Western wheatgrass

Pleuraphis jamesii James' Galleta

Scleriopogon brev/f/blizs Burrograss

Sporobolis cryptandrus Sand dropseed

Stipa coinata Needle and thread grass

~Shrubs

Prosopis glandulosa I lonev mesquite

Echinocereus Sp I Hedgehog cactus

Two shrub species occurred in the cover transects. Shrubs contributed 1.2% of the relative vegetative

cover. Prosonis vlandulosa (honey mesonite) was the dominant shrub nresent with 0.54% total cover

(G1,13, 201 Oa).

Vegetation species present in cover transects consisted oftthe following, forms: five (5) forb species.

eleven (11 ) grass species, and two (2) shrub species. Two forb species were not able to be identified

during the 2010 IIFP Vegetation Survey due to lack ofdistingzuishing floral characteristics. Subse0Cuent

surveys and reports will attempt to identify these unknown .species (GLEI. 201 0a).

The IIFP Site is dominated by perennial grasses with 96.8% of the relative frequency. Blue gramna

accounted for 6 2 .

6% of the relative frequency value. Black grama was the second greatest contributor

with 7.3% of the relative freCluency. Forbs totaled 2.5% of the relative freQUencv with Croton texensis

(Texas croton) at the greatest value of 1. 1%. Shrubs accounted for the least relative freCluencv at 1.2%.

Shrub frequency was predominantly honey mesquite at 1.1% of the relative frequency (GLEt, 2010a). See

Figures 3-35 and 3-36 for a tvyical site nhotogranhs of ground cover on the I IFP Site.

Environmental Report Request for Additional Information (RAI 14) Page I110
Official Responses to Environmental Report RAls

Figure 3-35 Perennial Vegetation Cover on IIFP Site

Figure 3-36 Site Photograph of Ground Cover on IIFP Site

Environmental Report Documentation Impact: The 5th paragraph of Section 3.5.4, "Habitat

Importance," of the Environmental Report, Revision A, will be revised to show the contact with

appropriate State and federal officials for threatened or endangered plant species of the IIFP Site. The 5th

paragraph of Section 3.5.4 will read as follows:

Shrubs provide habitat and seeds for bird and small mammal species. Perennial grasses provide forage for

large grazing mammals and seeds for small mammals. The dominant plant species should be distributed

uniformly across the site, such that no one area of the site contains that specie exclusively. New Me-iee

bFeDaftfflellt of-kiallie aflEt 1ý S 1. 1, S 1 alitt -W ei v ee. an t e ew ex eo tate oieswv

L~prmrt peisýOfciqe will be eentaetea !or- any threatenedl or* endanger-ec plant speeies; on thle II F I sit

Environmental Report Request for Additional Information (RAI 14) Page III
Official Responses to Environmental Report RAIs

Consultation with the New Mexico Department ol'(aame and Fish and U.S. Fish and Wildlife Setvice

indicated that there are currently no threatened or endangered plant species listed for Lea County, New

Mexico. Additional consultation was sought with the New Mexico Ecological Services for potential

habitat and known populations of a candidate species (Wright's Marsh Thistle). The nearest location

containing known populations of Wripght's Marsh Thistle are in the Black River drainage at least 32.2 km

(20 mi) southwest of Carlsbad, New Mexico and at least 97 km (60 mi) from the IiFP proper!'.

Additionally, no potential habitat was found to be present on the IIFP Site for the Wrigtht's Marsh Thistle

during the vegetation survey.

Environmental Report Documentation Impact: The 3 d paragraph of the "Habitat Requirements"

subsection of Section 3.5.7.2, "Sand Dune Lizard," will be revised to include the conclusion of the field

work conducted to evaluate the site for the possible presence of the sand dune lizard. That 3rd paragraph

will become the 3 rd and 4th paragraphs of this subsection. The 3 rd and 4 th paragraphs of the Environmental

Report, Section 3.5.7.2, "Habitat Requirements" subsection, will be revised to read as follows:

Dunes that have become completely stable by vegetation appear to be unsuitable habitat. The sand dune

lizard diet consists primarily of insects such as ants, crickets, grasshoppers, beetles, spiders, ticks and

other arthropods. Most feeding appears to take place with or immediately adjacent to patches of

vegetation. It is likely that the IIFP Ssite provides an adequate food source for the sand dune lizard.-

The proposed site for the I IFl is comprised of a shortgrass prairie with intermittent mesquite. Shortgrass

prairies are comprised of several herbaceous plant-soil associations including side-oats grama (Bouteloua

curtipendula). blue grama (Bouteloua gracilis), and buffalograss (Biichloe dact:loides) on well drained

soils or rocky slopes and blue grama/hairy grama and (Bouteloua hirsuta) on loamy or sandy soils. The

IIFP Site contains sandy loam soils. The lack of the shinnery oak on the proposed location leads to the

conclusion that the sand dune lizard does not exist at this site. The site does not support shinnerv oak or

have the required sand blowouts which comprise the sand dune lizard's primary habitat. In addition to the

lack of appropriate soil types, there are not enough sand particles in the appropriate size range to meet the

habitat needs of this species (GIEI, 2010b).hWlowever, the habitat areas likely containing the sand dune

lizard starts approximated 191.3 km (a4--_7_mi) south of the IIFP Ssite. See Figure 3-44!4_1 "Expected

Range of the Sand Dune Lizard," in Lea, Eddy, and Chaves Counties, New Mexico (Painter, 2004). The

lack of the shinnery oak and sand dunes on the proposed location makes it unlikely that the dunes

savebrush lizard exists at this location.

Environmental Report Request for Additional Information (RAI 14) Page 112
Official Responses to Environmental Report RAIs

RA115

Provide the rationale, including appropriate documentation, that jurisdictional wetlands are, or are

not, present within the proposed 40-acre facility (plant compound) construction area.

It is our understanding that IIFP may submit a jurisdictional wetlands determination application for the

depressional areas that appeared to support some hydrophytic vegetation. During the NRC site visit on

July 27, 2010, the NRC staff noted one depression had standing water.

RESPONSE:

It should be noted that a very heavy rainfall event (approximately 8 in) occurred the previous weekend

prior to the July 27, 2010 NRC visit. GL Environmental, Inc. evaluated the IIFP Site for a jurisdictional

determination with respect to Waters of the United States on October 15, 2010. The depressional areas

during this site visit were dry. The jurisdictional determination letter to the USACE for Section 27, Range

18 South, Township 36 East (GLEI, 201 Oc) is attached to these responses to the RAIs. Communications

with the USACE confirm that the USACE agrees with the GL Environmental assessment. The

Jurisdictional Determination from the USACE that there are no waters of the United States on the project

site was issued January 26, 2011.

According to New Mexico Environment Department (NMED) Surface Water Quality Bureau, the State of

New Mexico does not have a wetland delineation procedure other than the United States Army Corps of

Engineers (USACE) wetland delineation procedure. If surface water is present in the depressions on

Section 27, the water may be considered "Waters of the State". Currently there are no New Mexico state

regulations against conducting activities within the depressions, but liquid discharges would need to be

authorized under the appropriate state and federal permits. International Isotopes Flourine Products (IIFP)

will not discharge process water into surface waters as a result of facility operations. IIFP will obtain

coverage under an Environmental Protection Agency (EPA), National Pollutant Discharge Elimination

System (NPDES) Stormwater permit for both construction and operation of the IIFP facility. The EPA,

Region 6 is the permitting authority for the Clean Water Act in the State of New Mexico. Therefore the

EPA, not the State of New Mexico, is the permitting authority for NPDES permits in New Mexico.

Environmental Report Documentation Impact: Section 3.4.9, "Description of Wetlands," will be

revised to reflect the results of the surface depressions evaluation conducted by GL Environmental, Inc.

October 15, 2010. Section 3.4.9 will be revised as follows:

3.4.9 Description of Wetlands

A1n e-'auation ,f the site and of available wetlands informationl has been used to determin'e that the site

does not c..tain juril0 .. tlan.. or thos ar... sujet to the regulations of the . n ter, Act o,4e!

h7i. Jurisdiction wetlan.ds are generally con.cave or l.w lying topographic fa thati-, ollect, . sto.e, or

T'!here exist "undivided" wetlands a-, shown in Figure -3 27. "Waterou.rses. Floodplains, and Playas M.ap.-"

Small surface depressions are located throughout Section 27. Several of the most substantial depressions

are identified on Figure 3-3 "Location of Intermittent Surface Water Around the IIFP Site." The

depressions tend to be circular in shape and range from 15.2 in to 91.4 in (50 ft to 300 ft) in diameter and

0.9 to 1.5 m (3 ft to 5 fi) in depth below the surrounding grade. The depressions occasionally fill with

Environmental Report Request for Additional Information (RAI 15) Page 113
Official Responses to Environmental Report RAts

water in response to precipitation events. The frequency and duration of surface water in the depressions

is unknown, however, it is likely that water or saturated conditions are present for less than 10% of the

ear (G(LEI, 201 Oc).

A change from the surrounding vegetation cornmmunity occurs within the surface depressions. Vegetation

within the depressions is dominated by the perennial grasses Burro grass (Scleropoqon brevi/blius) and

Galleta Grass (Pleuraphis iaunesii). Neither plant species are included in the National List of' Vascular

Plant Species ihat Occur in Wetlands: 1996 National Sunnmary. Vine Mesquite (Panicuni obtusuin),

Western wheatgrass (Pascoirzun smnithii), and Blueweed (Helianthus cilaris) were present at low densities

(<5% of areal herbaceous cover). Each of these three species is described as equally likely to occur in

wetlands or non-wetlands (estimated probability 34%-66%). in the National List. A soil core was

collected from two of the deeper depressions on Section 27. Each of the cores was approximately 16

inches in depth. The soil consisted of dark brown sandy to silty loam with some organic matter. No

mottling or sulfidic material was observed in the cores (GLEI, 2010c).

"Waters of the 1U.S" are not present in Section 27. Surface drainage flows are infirequent, low volume and

short in duration. Additionally, the drainage is not connected through surface channels to regional surface

water features. See Section 3.1.1. "Land Use Status." for additional information on surface drainage and

for a site map showing the surface drainage and the surface depressions. Surfiace depressions are not

dominated by wetland plants, lack indicators ofanoxic soil conditions, and most likely are not saturated

for more than 10% of the year. The surface depressions lack the characteristics of wetlands as defined in

the Corps of Engineers "Wetlands Delineation Manual," January 1987 (GLEI, 201 Oc). Concurrence has

been obtained firom the USACE that the water features on Section 27 are isolated and "Waters of the

U.S." are not present within Section 27 (USACE, 2011). According to NMED Surface Water Quality

Bureau, the State of New Mexico follows the USACE wetland delineation procedure.

Environmental Report Documentation Impact: Section 3.1.1, "Land Use Status," will be revised to

reflect the results of the surface drainage conducted by GL Environmental, Inc. October 15, 2010. A new

paragraph fifth will be added and former paragraph five will shift down with revisions. Rename and

replace figure for Figure 3-3 "Location of Intermittent Surface Water Around the IIFP Site." Section 3.1.1

will read as follows:

Two small intermittent drainages are located on the southwest quadrant of Section 27. Surface flow most

likely occurs in response to precipitation events. The drainages grade to the southeast and coalesce

approximately 396 m ( 1,300 ft) south of the section boundary. The western drainage is clearly defined on

Section 27 due to a moderately incised channel and the presence of Iloney Mesquite bushes along the

banks. The drainage to the east is shallow and not easily delineated from the surrounding land surface

(GLEI, 2010c.

The coalesced drainage continues to grade to the south/southeast toward Monument Draw. Monument

Draw is a maior surface drainage feature in southern Lea County and is clearly present in topographical

maps approximately 22.5 km (14 mi) southeast of the section boundary. Although the drainage present in

Section 27 grades toward Monument Draw, a review of topographic maps did not reveal a clear physical

connection to Monument Draw. The drainage terminates in a plava approximately l 2.9 km (8 mi)

southeast of the section (GLEI, 201 Oc). Surface drainage at the site is also contained within a few

depressions that have no external drainage. See Figure 3-3 for location of these depressions and the two

intermittent drainages from the site. Runoff does not drain to one of the state's major rivers. Surface water

is lost through evaporation, resulting in high salinity conditions in both the waters and soils associated

with the playas. These conditions are not favorable for the development of viable aquatic or riparian

Environmental Report Request for Additional Information (RAI 15) Page 114
Official Responses to Environmental Report RAIsAI

I12Rfl1T2IT' I nere V I 1F.1 I '~I I "tr'~rnn TrIo ri in'. cr'~m 1ns~ n"ron""."'1 on one "'~i rnr'l~a 'v~vc'.'. 01w nrnn '~rr' 1mm

is predominntly dry durin, the year. See Figure 3 3 which is a topographic map i ..e pr..posed .FP site

wAhich Shows the low terrain wher~e the stream anid playas are located during periods of rain. There isn

desig-nated Federal Emier-gency Maniagemenl Agnc (FEMA) Zone A area at the 11Fl) location; tha_.t would!

be inutndated durinig a 1 00 year flood ell_-nt ... to .efe Figur-e 3 27, "Watercoaurses, Floodplains. anid Playas

International Isotopes Fluorine Products

Section 27, Township 18 S, Range 36 E

Map 2

- Scti. 27 Boundary ltFP Faciy Bo.d.'y

- &,I..c .. I., dOrahogo fealubo Ocprmwsiob

NOuO.Oe,2~ .20,•10

A

000o 1,000 2,000 Feet

-1-1~

Source: GI Environmental, Inc.

Figure 3- 3 Location of Intermittent Surface Water Around the IIFP SiteTopographic Milli of the

Proposed IIFP Site

Environmental Report Documentation Impact: Section 3.4.12.2, "Drainage Areas," will be revised to

reflect the results of the surface drainage conducted by GL Environmental, Inc. October 15, 2010. Insert

new Figure 3-28 "Surface Drainage from the IIFP Site" (after text). The 3rd paragraph of Section 3.4.12.2

will be revised to read as follows:

Environmental Report Request for Additional Information (RAI 15) Page 115
Official Responses to Environmental Report RAIs

Two small intermittent drainages are located on the southwest quadrant of Section 27. The drainages

grade to the southeast and coalesce approximately 396 rn (1,300 11) south of tile section boundary. The

coalesced drainage continues to grade to the south/southeast toward Monument Draw. Monument Draw is

a maior surface drainage feature in southern Lea County and is clearly present in topographical maps

approximately 22.5 kin (14 mi) southeast of the section boundary. Although the drainage present in

Section 27 grades toward Monument Draw. a review of topographic maps did not reveal a clear physical

connection to Monument Draw. The drainage terminates in a plava approximately 12.9 km (8 mi)

southeast of the section (GLEI, 201 Oc). See Figure 3-28. Thus. Ssurface drainage at the 259 ha (640-ac)

Section is contained within several local depressions playas lae - that have no external drainage. Runoff

does not drain to Pecos River. The Pecos River Basin has a maximum basin width of 209 km (130 mi)

and a drainage area of 115,345 km 2 (44,535 mi 2)

660000 65000 670000

*~ .. .. .....

International Isotopes Fluorine Products N JTM NAD 03, Zo

Section 27, Township 18 S, Range 36 E 2

Map 3

- Setion 2 7 Bouroury AJ playa

S- urtface water drainage leature "IP I Feclity orndary 0 1 2 4Mh'__ u t F S I r IDraw

-Monumient Draw

G I. Environmental Inc.

Figure 3- 28 Surface Drainage from the IIFP Site

Environmental Report Documentation Impact: The U.S. Army Corps of Engineers has issued it

jurisdictional determination of isolated waters in Section 27 of the IIFP Site (USACE, 2011). A copy of

Environmental Report Request for Additional Information (RAI 15) Page 116
Official Responses to Environmental Report RAIs

that determination will be added to Appendix B" of the Environmental Report "Consultation

Documents." The copy of the correspondence is below:

Environmental Report Request for Additional Information (RAI 15) Page 117
Official Responses to Environmental Report RAIls

_ DEPARTMENT OF THE ARMY

ALBUQUERQUE DISTRICT, CORPS OF ENGINEERS

A •Las Cruces Regulatory Field Office

505 S. Main St. Suite 142

Las Cruces, New Mexico 88001

(575)-556-9939

January 26, 2011

RI:LY W

Regulatory Division

New Mexico/Texas Branch

SUBJECT: Action No. SPA-2011-00030-LCO, International Isotopes Fluorine Products

Facility

G. L. Environmental, Inc.

Attn: Mathew Lane

P. O. Box 1746

Las Vegas, New Mexico 87701

Dear Mr. Lane:

The U.S. Army Corps of Engineers (Corps) is in receipt of your letter dated

January 12, 2011 concerning a request by GL Environmental Inc. for an approved

jurisdictional determination (A-JD) ofan isolated waters for a project site located 10

miles west of Hobbs, Lea County, New Mexico. The activity involves construction of a

fluorine products facility located within section 27, 'T 18 S, R 36 E, on an approximately

40 acre site. The facility will utilize depleted uranium hexafluoride to produce high

purity inorganic fluorides, uranium oxides, and anhydrous hydrofluoric acid. We have

assigned Action No. SPA-2011-00030-LCO to-this activity. To avoid delay, please

include this number in all future correspondence concerning this project.

We have reviewed this project in accordance with Section 404 of the Clean Water

Act (CWA) and Section 10 of the Rivers and Harbors Act of 1899 (RHA). Under

Section 404, the Corps regulates the discharge of dredged and fill material into waters of

the United States, incliding wetlands. The Corps responsibility under Section 10 is to

regulate any work in, or alTecting, navigable waters of the United States, Based on your

description of the proposed work, other information available to us, and current

regulations and policy, we have determined that this project will not involve any of the

above activities. Therefore, it will not require Department of the Army authorization

under the above laws. However, it is incumbent upon you to remain informed of any

changes in the Corps Regulatory Program regulations and policy as they relate to youtr

project.

Environmental Report Request for Additional Information (RAI 15) Page 118
Official Responses to Environmental Report RAls

-2 -

The Corps based this decision on an approved jurisdictional determination (.1)) that

there are no waters of the United States on the project site. The basis for this approved

JD is: that the project site contains intrastate waters with no nexus to interstate or foreign

commerce. The JD form is available at

http://www.spa.usace.army.mlil/reg/JI urisdictional Determinations/juirisdictionaldeterm in

ations.asp. This approved JD is valid for a period of no more than five years firom tile

date of this letter unless new information warrants revision of the determination before

the expiration date.

You may accept or appeal this approved JD or provide new information in

accordance with the Notification of Administration Appeal Options and Process and

Request For Appeal (NAAOP-RFA). This form is available at

http://www.spa.usace.aimy.mi l/reg/AdMinistrative%2OApj.eals/ap-pea-s priocess.asp. If

you elect to appeal this approved JD, you must complete Section II (Request For Appeal

or Objections to an Initial Proffered Permit) of the form and return it to the Army

Engineer Division, South Pacific, CESPD-PDS-O, Attn: Toni Cavanaugh,

Administrative Appeal Review Officer, 1455 Market Street, Room 1760, San Francisco,

CA 94103-1399 within 60 days of the date of this notice. Failure to notify the Corps

within 60 days of the date of this notice means that you accept the approved JD in its

entirety and waive all rights to appeal the approved JD.

If you have any questions concerning our regulatory program, please contact me at

(575)-556-9939 or by e-mail at richard.h.gatewood@usace.army.mil. At your

convenience, please complete and return the attached Customer Service Survey.

Sincerely,

Richard Gatewood

Regulatory Manager for

Southern New Mexico and West Texas

Environmental Report Request for Additional Information (RAI 15) Page 119
RAI 16

Provide additional information regarding ambient noise level monitoring results mentioned in the ER.

It is our understanding that IIFP is conducting noise level readings at the corners of the site to document

existing conditions. The results of those measurements and survey report are needed in order to document

the existing baseline noise at the site for the Affected Environment section of the EIS.

RESPONSE:

The baseline noise survey of the IIFP Site has not been conducted. The noise survey is being scheduled

for the third quarter 2011.

Environmental Report Documentation Impact: None.

Environmental Report Request for Additional Information (RAI 16) Page 120
Official Responses to Environmental Report RAIs

RAI 17

Clarify the status and/or schedule of the various state permits mentioned in the ER, including a list of

those determined to not be necessary.

IJFP is preparing applications and requesting permits as described in the schedule presented in Table 1-

4, "Required Federal and State Permits ", of the ER (JJFP, 2009a). An update of the permit status since

submittal of the ER in December 2009 is necessary to ensure accurate information in the EIS. Because

the ER describes some permits as potentially unnecessary, this updated information is needed to ensure

that extraneous information is not included in the EIS.

Also provide a copy of the New Mexico Office of State Engineer Water Rights Permit for inclusion in the

EIS. If the permit has not yet been received, provide a copy of the Water Rights Permit Application.

RESPONSE:

The existing Table 1-4 will be deleted and replaced with a new table showing the requirements for

application and only those required for the IIFP Facility. The new table will be renumbered Table 1-3.

The Air Construction Permit, the Air Operation Permit, and the NESHAPS Permit have been combined

with the Air Quality: New Source Review/Authority to Construct Permit. The NPDES General Permit for

Industrial Stormwater and the NPDES Construction Stormwater General Permits for both the federal and

state agencies have been combined in the NPDES SWPPP/NOI Permit. The Hazardous Waste Permit, the

EPA Waste Activity EPA ID Number, and the RCRA Operations Permits have been combined for the

EPA Hazardous Waste ID Number. The Access Permit has been renamed "Highway Right-of-Way

Permit." The "Drinking Water System Permit," the "Above Ground Storage Tank Registration," and the

"Clean Water Act, Section 404" have been added to the new table. Also, a copy of the New Mexico

Office of State Engineer Water Rights Agreement will be included in the Environmental Report,

Appendix B as shown below in the Environmental Report Documentation Impact for Appendix B.

See also RAIs ER-14 and ER-20a.

Environmental Report Documentation Impact: Table 1-4, "Required Federal and State Permits," will

be deleted and replaced with Table 1-3, "IIFP Required Federal and State Permits. (Former Table 1-3,

Revision A has previously been deleted.)The 2 'd paragraph of Section 1.5, "Building Permits and

Licenses," will be revised to add the required permits with the revised Table 1-3. The 2 nd paragraph and

the table will read as follows:

A number of licenses and permits will be required for construction and operation of the IIFP f+Aa4ltcility.

Permits include the following:

o Air Quality: New Source Review/Authority to Construct) Permit,

" Ground Water Dischartge Permit/Liquid Waste (sewage) Permit,

* EPA Hazardous Waste ID Number.

* Drinking Water System Permit

o Radiation Protection Permit,

* Above Ground Storage Tank Registration.

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

* State Access (Higxhway Right of Way) Permit,

* Clean Water Act. Section 404, and

Environmental Report Request for Additional Information (RAI 17) Page 121
Official Responses to Environmental Report RAls

* Rare. Threatened, and Endangered Species Survey Permit.

A summary-The status of licenses and permits that are currently known to be required are-is listed in the

Table 1-34. During the federal and State permitting process, any changes in requirements will be reevaluated.

Table 1- 3 iFP Required Federal and State Permits

A ; " I . f -f- fl"_

NPDES

SW PlPP/N O1

EPA Region

6iNMED

best management practices, receiving waters

determination, Lgenerate SWPPP, and produce and

2 nd Qtr. 2011

submit NPDES NOL.

Highway Right- NMDOT One month traffic study and right-of-way 2nd Otr. 2011

OWax application.

Air Quality: New Equipment list tor stacks. generators, boilers, etc.

Source ) B petroleum storage tanks, emission calculations, Review!/Authtority NMED/A.QB rdQt. 20

to Construct facility design layout, air dispersion modeling, and

Permit Public Notice

Facility design; calculations for stormwater

discharge rate, effluent discharge rate. and P.E. Grondi Water stamped water balance; effluent quality

Discharge NMED/GWQB determination: effluent processing: treatment. 3 d Qtr. 2011

Waste Permit storage, and disposal plans" baseline conditions;

domestic waste land apply strategy mov" itoring

plan; contingency plan: and Public Notice

Drinking Water NMEDiDWB Drinking water system design, monitoring plan, and 2nd t 2012

System Permit operator certi fication

EPA Hazardous Determination of generator status (Large Quantity

Waste ID NMED/HWiBA Generator, Snmall Quantity Generator, or Small 3r' Qtr. 2012

Number Quantity Exempt)

Radiation 

Protection NMED!RCB List 

-. and description of all radiological source 20( 2 Otr t.212012

Permit equipmnent.

Above Ground Store Storage Tank Tank NM EJ/PST-B 1 Petroleum fuel typ~e)4"Qt.2 storage tanks (size, designi specifications, 4(' Qtr. 2012)

Registration

Clean Water Act. USACE Site vegetation characterization and wetland Complete

Section 404 determination to the !JSACE

This permit would be required for conducting Complete for

Endanered NMDFG surveys of the U.S BLM lands for Lesser-Prairie Lizard

Species Survey Chicken and Sand Dune l..,izard. 2)"' Qtr. 2011

Right-of-Ertry, IlFP has obtained this pennit for entry onto Section PermitNMSLO 26 27 34. or 35 Complete

State Land Swap NMSL)O This arrangement requires that an environmental Complete

Environmental Report Request for Additional Information (RAI 17) Page 122
Official Responses to Environmental Report RAls

Su bm ittalI PII•ermit Agency • Recquired for Application Time Fr.m.

Arrangement assessment and a cultural resources survey be

conducted on lands offered for exchange..

Class II Cultural NMSHPO IIFP has obtained this permit to conduct surveys on SNrvev Permit Section 26. 27, 34, or 3-5.

NPDES -. National Polltutant Discharge Elimination Systemý I P11A.N1,.,.S ..Environmental Protection .Agenc'v: N1.E.S1-I P..:.:.... Nati ... l missions

Standards for Hlazardous Air Pollutants: NNDOT - New Mexico Departnlenlt of Transpor(ation: NM [D)/AQB - New Mexico Environment

Department /Air Quality Bureau: NIMEDiWB - New Mexico Environment Department/llazardous Waste Bureati NM F,D/RC[ B - New Mexico

Environmenl DepartmentiRadioloeical Control Bureau: NMED'GWOB -- New Mexico Ensironment DepartmentiGroUnd Water Dualily Bureau:

NMDGF - New Mexico Department of Game and Fish: NMSI.O - New Mexico Slate land Office NMSI-IPO - New Mexico Stale Historic

Preservation Office. NMEDiDWB - New Mexico Environment Deartiment/Drinking Water Bureau USACE - U.S. Army Corps of Engineers.

NMEDiI'STB - l'etroleunt Storae T'ank Bureau, U.S. BLNI U.S. Bureau of Land Manavement

Environmental Report Documentation Impact: Verbiage has been added to ER Sections 3.12 (see also

RAI ER-20a), Section 4.13.3.3, Liquid Wastes," and new Section 4.13.6, "Cumulative Impacts" as

follows to clarify that liquid process wastes are not discharged from the IIFP production facilities.

3.12 Waste Management (revised It paragraph, split into two paragraphs)

Waste Management for the IIFP facility is divided into gaseous. liquids, and solid wastes. Liquid process

wastes are not discharged from the IIFP production facilities as shown in Table 3-58. After tertiary

treatment, sanitary water would be discharged to a tree farm. If needed after heavy rainfall events.

stormwater would be discharged from the retention basins to the tree farm after the stornwater was

analyzed and met all groundwater discharge limits. The types of wastes are tabulated in Table 3-58.

Descriptions of the generation, management, and disposal of various wastes from construction and

operations are discussed in this section. Disposal plans, waste minimization, and environmental impacts

are discussed in ER Section 4.13, "Waste Management Impacts."

4.13.3.32 Liquid Wastes (formerly 4.13.3.2; revised I

t paragraph)

The facility does not discharge any process effluents to natural surface waters or grounds, and there is no

tie into a Publicly Owned Treatment Works (POTW). No public impact is expected from routine liquid

effluent discharge as no process liquids are discharged off site (process wastes are recycled). After tertiary

treatment. sanitary water would be discharged to a tree farm. If needed after heavy rainfall events,

stormwater would be discharged from the retention basins to the tree farm after the stormwater was

analyzed and met all discharge limits.

4.13.6 Cumulative Im pacts ( 1st paragraph)

Minimal liquid wastes are generated during, the construction of the IIFP Facility. All process liquid wastes

are recycled during the operation of the facilitv. After tertiary treatment, sanitary water would be

discharged to a tree farm. If needed after heavy rainfall events, stormwater would be discharged from the

retention basins to the tree farm after the stotmwater was analyzed and met all discharge limits.

Environmental Report Documentation Impact: The Environmental Report, Appendix B will be revise

to include a copy of the New Mexico Office of State Engineer Water Rights Agreement as shown below:

Environmental Report Request for Additional Information (RAI 17) Page 123
Official Responses to Environmental Report RAIs

STATE OF NEW MEXICO

COUNTY OF LEA

RESOLUTION NO. 10-DEC-043R

CONTRACT WITH NEW MEXICO STATE LAND OFFICE FOR WATER USE AGREEMENT

WHEREAS, pursuant to Section 4-38-1 NMSA 1978 Comp., the Board of County Commissioners of Lea

Countyhas the power to exercise the powers granted the County as a political subdivision of the State of New

Mexico,"and,

WHEREAS, pursuant to Section 4-38-1 NMSA 1978 Comp., the Board of County Commissioners of Lea

County has the power to purchase real and personal property, including water rights and uses, as they deem

necessary in the exercise of their authority, and

WHEREAS, the board has determined that it is in the best interest of the County to execute a New Mexico

State Land Office Water Use Agreement relating to SEO file No. L-4719-A, a copy of which is attached hereto

as Exhibit "A' and is incorporated herein by reference ("Agreement' hereinafter) for future economic

development in accordance with the Local Economic Development Act and the Lea County Local Economic

Development Ordinance, and

WHEREAS, pursuant to New Mexico law and the regulations of the New Mexico State Land Office, the Board

has applied to receive this proposed Agreement, and

WHEREAS, the Commissioner of Public Lands tas agreed to enter into such Agreement with the County,

THEREFORE BE IT RESOLVED, that the entering into the Agreementis hereby approved.

IT IS FURTHER RESOLVED, that Gregory H. Fuller, Chairman of the Board of County Commissioners, is

authorized to approve, execute all docurments, pay all fees, and take such action as is necessary to finalize and

accomplish the entering into the Agreement with the New Mexico State Land Office.

PASSED, APPROVED AND ADOPTED in open meeting this 9,, day of December, 2010.

LEA COUNTY BOARD OF COUNTY COMMISSI, ER•"

F er, Chairma Michael Whitehead, Vice Chairman

Dale uap, Member Ron Black, Member

f-Rector Ramirez, emer

ATTEST: Pat Chappetle APPROVED AS TO FORM AND LEGAL

Lea County Clerk SUFFICIENCY:

Anie g, eptGar Don Reagan ,'

tnterim Lea County Attorney

Agei~o no 

3vec-or Pap 1.°o.0! 20 No oc, UOR fow "2,i 'E '

Environmental Report Request for Additional Information (RAI 17) Page 124
Official Responses to Environmental Report RAIs

Exhibit "A"

Subject L..,and

Coniniis.i6hier of Public Lands

NEW MEXICO STATE LAND OFFICE

WATER USE AGREEMENT No.

Grantor: New Mexico Commissioner of Public Lands

Grantee: Lea County

Effective Date:

Expiration Date:

Date:

This Agreement for the use of water is made between [Ie New Mexico Commissioner of Public Lands, acting trustee p'suanot to the Act of June2, 1910. 36 Stat. 557, oh. 310, § 10 (Grantor) and Lea County,

(Grantee) whose address for purposes of notice is __

The effective date of this Agreement shall be the date upon which it is executed by the Grantor.

a. declarations The parties understand and acknowledge that in his capacity as trustee of th state larids

managed by the hini, Grantor is the owner oftlte right to use the quantity of water which is the subject of

this Agreement (use-right), that nothing in this Agreement shall be construed to convey anything to Grantee

other than a portion of such useright, arid that title to the water rights being used shall at all times during

the term ofthis Agreement remain in Southwest public Service Company.

b. grant of use-rights Grantor hereby grants to Grantee, for consideration, the right to usc lifty (50) acre- feet per annum of water to be taken from L-4719-A or permitted supplemental wells within the same seetion:

Subdivision Section Township Range Acreage Diversion Priority SEO file No.

35 19S 36E 50 AF/ann. 9-15-61 L-4719-A

Subject to the terms of this Agreement, Grantee mata change said point of diversion,.

c. consideration for use-rights Grantee shall pay in advance to Grantor the non-reftudable annual base atnotnt of$500.00 per annum, to be due in fall on or before the effective date oftthis agreemnent, arid

thereafter on or before the anniversary of that date. Said base amount shall increase at the rate of2.5% to be calculated as. follows: (current base amount) X 1.025 n subsequent base antount. In additon, Grantee

shall pay quarterly in,alTears to the Commissioner a surcharge equal to SO0lo per thousand gallons taken

from the well. Said base amount and surcharge shall escalate at the rate of $0.02 quinquennially (see

Exhibit A), Paynents of tte surcharge shall be suhbmitted alonig with an accounting of tle anount of water taken. Grantee must maintain a totalizing tinder for purposes of calculating said quarteriy surcharge; and surcharge paymttents shall be submitted with a report of the readings from such totalizing meter. Any costs or fees incurred for transportation or treatment of said water, for drilling or re-drilling any

supplemental wells, for installation or maintenance of any meter or other infrastructure, of otherwise to employ the use-rtghts grauned herein, shall be borne solely by Giantee.

Environmental Report Request for Additional Information (RAI 17) Page 125
Official Responses to Environmental Report RAls

Resolution No. 10-DEC-043 R

LCBC Meeting 12-09-2010

Page 2 of 2

Environmental Report Request for Additional Information (RAI 17) Page 126
Official Responses to Environmental Report RAIs

1. commercial sale of water. In addition Granltee shall pay 20 % of all gross

revenues received from the lease or sale of water to third parties, Gross revenues shall be paid and

reported quarterly to Grantor atthe time surcharges are paid. As used herein, "Gross Reveaues"

means the aggregate total revenue actually received by Grantee during quarter fiom the lease or

sale of water, provided that Gross Revenues shall not include revenues derived front (a) aty

amounts received as settlement, judgment amounts, liquidated damages, or sithilia payments

based on a claim of breach of contract, unless such income is intended as damage for lost

revenues, or, (b) sales of water for which payment is not received, ticluding because ofa default

by the purchaser thereof (except that Lessee shatl promptly pay Lessor when and if it ultimalcly

receives such payment). As used herein, the "lease or sale of water to third parties" meaus the

disposition of svater to anyttiird party or entity. "Pumaping Costs" shall mean Actual out-ofpocket annual expenses involved in the pumping of the subject water, and will not include any

deductions for insasgible amounts such as depreciation. Grantee shall provide Crantor a-n ihemized

statement of "pumping costs" each year; and during the first three years the parties will negotiate

Grantee's methodology for calculating pumping costs. If the parties fail to agree on pumping cost methlodology, the panics will resolve this through binding arbitration with the arbitrator to be

mutually selected by the parties and paid for by Grantee.

d. term of Azreement The term of this Agreement shall be for forly (40) years from the effective date,

e. permitted uses 'lihe water shall be beneficially used only for the following purpose(s), subject to any

restrictions upon use which the Newe Mlexico State Engineer may impose: for lease, sale or other

disposition, to such entity or entities as Grantor and Grantee may agree upon, ott Section 27 Township 18

South Range 36 East. Grantee will inform Grantor in writing of any such restrictions imposed by the Stale

Engineer imnmediately upon approval of Grantee's application.

f. applications and permits Grantee shall, in confornits' withNMSA 1978 72-6-1 el saq. be solely

responsible for making all applications, paying all fees and related costs, and obtaining all permits

necessary from the New Mexico State Engineer's Office, and for making aly and all reports as may be

required by the State Engineer. Subject to the approval oftheConunissioner, Grantee may list Grantor as a

co-applicant with the understanding that Grantor is prohibited from expending any sums in support ofsuabh

application. Grantee's rights under this Agreement are contingent upon the approval of the State Engineer. Griantee shall immediately notify, Grantor ifand when the State Engineer approves Grantee's application.

If Grantee's application is rejected by the State Engineer, and Grantee fails to prosecute a successful appeal

of that determination, then this Agreement tshall, upon Grantee's written notice ofasues, expire.

g. liens and encumbrances Grantee shall in no way permit any lien or encumbrance to attach to or burden the subject use-right, and Grantee will indemnify Grantor for all damages, costs, and fees arising

out of or in connection with any lien or encumbrance which may attach to or burden said use-right during

the tenr of this Agreement.

It. prohibition against issiinment Grantee will in no way sublease, assign, or otherwise convey to any

iltird party any interest in all or part of the subject use-right without Grantor's express, wrinen consent, anti

Grantee will indemnify Grantor for all datnages, costs, and fees arising out of or in connection with any act

by or attempt ofGrantee to sublease, assign, or other•ise dispose of any interest in the subject use-right.

Any sublease, assignment or other disposition of any interest in the subject use-right without Grantor's

express written consent, shall be void.

i. improvemetnts rieght-of-wav Grantee acknowledges the need to obtain Grantor's consent, by way of

a standard lease or grant of right-of-way or other easement, for any roadways, wells, pipes, pumps, or other

items of equipment installed by Grantee oin State Lend Office trust lands by Grantee in coninection with this

Agreement or otiherwise.

i. holdintg over If this Agreement terminates or is cancelled and Grantee continues using the subject userights witiout Grantor's consent, such use shall be deemed a trespass and a conversion, giving rise to such

25

Environmental Report Request for Additional Information (RAI 17) Page 127
Official Responses to Environmental Report RAIs

remedies at law or in equity as Grantor may then have. However, Grantor may elect to consider such

continued use a holding over for which Grantee shall owe a monthly rental at the rate of 125% of the

consideration amounts stated above.

k. abandonment Grantee's nontuse of the use-rights granted herein for a period of 180 days without

Grantor's consent shall be deemed an abandonment, and said use-rights shall tlten ipsofaclo revert to

Grantor. Grantor's failure to discover such non-use shall not waive the abandonment, and rey subsequent

use shall not re-instate such use-rights.

I. default IfGrantee defaults in tlse perfonrtatnce of any of lie terms of this Agreetment, including the

obligation to timely pay the above consideration, Grantor shall give Grtuatee written notice of such default

with 30 days to remedy that default. If Grantee fails to satisfactorily remedy (lte default withit that 30-day

period, this Agreement shall autotatically terminate without further act or notice required of Grantor, and

the use-rights shall ijpsofiscto revert to Grantor. Such automatic cancellation shall be itt addition to any

other remedies at law or in equity which Grantor may have for Grantee's default. Grantee shall be liable for

all costs and fees incurred by Grantor in seeking enforcement of this Agreement or in seeking damages for

Grantee's default.

in. relinquishment Grantee may relinquish this Agreement upon 30-days written notice to Grantor at any

time provided Grantee is then current on all payments due Grantor and is in full compliance with all terms

oftthis Agreenment. No refund of rental or other consideration paid shall be due to Grantee upon such

reliuquishment. Any such relinquishmenlt shall be made upon written application to Grantor accompanied

by such relinquishment fee as is then established by tite Commissioner.

n. compliance with laws Grantee shall fully comply with all laws, whether statutory or court-made,

regulations, rules, ordinances and requirements, including but not limited to, all current NMSLO Rules and

Regulations and those that may be hereafter promulgated. Governmental agencies prontulgating such laws,

regulations, rulest ordinances and requirements shall not be deemed third party beneficiaries uinder this

Agreement. Grantee's compliance shall be at its own expense and shall not be considered ant offset to the

rent or other consideration due under this Agreement.

o. hoal harmless Grantee shall be solely liable for any liability that may arise due to Grantee's acts or

omissions tmader or in connection with this Agreement, and Grantee shall save and hold harmless the State

of New Mexico, Grantor and Grantor's eniployees, agents and contractors, in both their official and

individual capacities, from any and all liabilities, claims, losses, damages, or expenses, including btt not

limited to reasonable attorneys' fees, third party' claims, costs or penalties for removal, remedial or

restoration arising out of, alleged to arise out of, or iudirectly connected with Grantee's use of Gratttor's

'ater rights.

p. miscellaneous

I. This Agreement incorporates all the agreements, covenants and understandings between

Grantor attd Grantee, and all such agreements, covenants and understandings are merged into this written

Agreement. No prior agreement or understanding between Grantor and Grantee shall be valid or

enforceable ttless expressly embodied in) this Agreement.

2. Tlits Agreement shall not be altered, changed or autnctded except by an instrtument executed

by both Grantor arid Grantee.

3. In the event Lessee is aggrieved by any decision of Grantor relating to this Agreement

including any decision to terminate this Agreement, Grantee shall titely file an administrative contest

plursuant to NMSA 1978, § 19-7-64 and Land Office Rule 15 (19.2.15 NMAC). Grantee shall initiate no court action regarding this Agreemtent except to appeal a final decision of the Commissioner of Public

Lands rendered pursuant to such a contest proceeding, and as provided by NMS.A 1978, § 19-7-67.

3. This Agreement shall be governed by the laws of the State of New Mexico, without giving

effect to the conflict oflaw provisions of the State of New Mexico. Any disputes arising under or in

connection with this Agreement must be resolved pursuant to administrative contest under Land Office

Rule 15 (19.2.15 NTeIAC). For purposes ofappeals therefrom Grantee consents to venue andtjurisdiction in

tie First Judicial District Court ofCounty of Santa Fe, New vMexico, and to service of process under the

3

Environmental Report Request for Additional Information (RAI 17) Page 128
Official Responses to Environmental Report RAIs

remedies at law or in equity as Grantor may then have. H-owever, Grantor may elect to consider such

continued use a holding over for which Grantee shall owe a monthly rental at the rate of 125% of dte

consideration amounts stated above.

k. abandonment Grantee's non-use of the use-rights granted herein for a period of 180 days without

Grantor's consent shall be deemed an abandoament, and said use-rights shall then ipsojieto revert to

Grantor. Grantor's failure to discover such non-use shall not waive the abandonment, and any subsequent

'use shall not re-instate such use-rights. . .....

I. default If Grantee defaults in the performnance of any of the terms of this Agreement, including the

obligation to timely pay the above consideration, Grantor shall give Grantee written notice of such default

with 30 days to remedy that default. If Grantee fails to satisfactorily remedy the default within that 307day

period, Ihis Agreetient sltall automatically termtitnate without further actor notice required of Grantor, and

the use-rights shall ipsofatclo revert to Grantor. Such automatic cancellation shall be in addition to any

other remedies m law or in equity which Grantor may have for Grantee's default. Grantee shall be liable for

all costs and fees incurred by Grantor in seeking enforcement of this Agreement or in seeking daraages for

Grantee's default.

it. relinquishment Grantee may relinquish this Agreement upon 30-days written notice to Grantor at any

time provided Grantee is then current on all paymtnts due Grantor and is in full compliance with all terms

of this Agreement. No refund of rental or other consideration paid shall be due to Grantee upon such

rclinquishment. Any such relinquishmient shall be made upon written application to Grantor aecompanied

by such relinquishment fee as is then established by tile Contmissioner.

s. eomptlianee with laws Grantee shall fully comply wvith all laws, whether statutory or court-nitade,

regulations, rules, ordinances and requirements, including but not limited to, all current NvMSLO ltiles and

Regulations arid those that may be hereafter promutlgated. Governmental agencies promtlgatiig such laws,

regulations, ruiles, ordinances and requirements shall not be deemed third party beneficiaries under this

Agreement. Grantee's compliance shall be at its own expense and shall not be considered an offset to the

rent oir other consideralion due under this Agreement.

o. hold harmless Grantee shall be solely liable for any liability that may arise due to Grantee's acts or

omissions tinder or in connection with this Agreement, and Grantee shall save and hold harmless the State

of New Mexico, Grantor and Grantor's employees, agents and contractors, in both their official and

individual capacities, from any and all liabilities, claims, losses, damages, or expenses, including but not

limited to reasonable attorneys' fees, third party claims, costs or penalties for removal, remedial or

restoration arising out of, alleged to arise out of, or indirectly connected with Grantee's use of Grantor's

water rights.

r. miscellaneous

8. This Agreement incorporates all the agreements, covenants and understandings between

Grantor and Grantee, and all such agreenseits, covenants arid understandings are merged into this written

Agreement. No prior agreement or understanding between Grantor and Grantee shall be valid or

enforceable unless expressly emtbodied in this Agrecitent.

2. This Agreement shall not be altered, changed or amended except by an instrument executed

by both Grantor arid Grantee.

3. In the event Lessee is aggrieved by any dlecision of Grantor relating to this Agreement

including any decision to terminate this Agreement, Grantee shall titisely file an administrative contest

pursuant to N.ISA 1978, § 19-7-64 and Land OfficeRule 15 (19.2.15 NMAC). Grantee shall initiate no court action regarding this Agreement except to appeal a final decision of the Commissioner of Public

Lands rendered pursuant to such a contest proceeding, and as provided by NMvfSA 1978, § 19-7-67.

3. This Agreement shall be governed by the laws of the State ofNew Mexico, without giving

effect to the conflict of law provisions of the State of New Mexico. Any disputes arising under or in

connection with this Agreement nmst be resolved pursuant to administrative contest under Land Office

Rule 15 (19.2.15 NMIAC). For purposes of appeals therefrom Grantee consents to venue andjurisdiction in

the First Judicial District Court of County of Santa Fe, New Mexico, and to service of process under the

3

Environmental Report Request for Additional Information (RAI 17) Page 129
Official Responses to Environmental Report RAls

laws of the State of New Mexico in any action relating to this Agreement or its subject matter.

4. All terms, conditions, and covenants of this Agreentent, and all amendments shall extend to

and bind the heirs, successors, and assigns of Grantee and Grantor.

5. Tinme is of the essence in the performance of this Agreement. Grantee's failure to perform any

or all of its obligations under this Agreement in a timely manner shall be grounds for Grantor to cancel this

Agreement.

6. In the event that any provision of this Agreement is held invalid or unenforceable under

applicable law, the Agreement shall be deemed not to include that provision arid all other provisions.shnll

-_remain in full force and effect.

GRANTEE LeaCount ,

li & sr-Lro f_0 date: --Ts I 

adrs orKtvseso~oie

approved by State Land Office counsel:

DATED:

S

E

A

L PATRICK H, LYONS

COMMISSIONER OF PUBLIC LANDS

Environmental Report Request for Additional Information (RAI 17) Page 130
Official Responses to Environmental Report RAIs

EXHIBIT A

Year rate per thousand gallons

1-5 10s

6-10 12¢

11-20 14¢

21-25 16¢

26-30 18¢

31-35 20¢

36-40 240

Environmental Report Request for Additional Information (RAI 17) Page 131
Official Responses to Environmental Report RAIs

RA118

Provide status of the radiological monitoring plan described in the "Radiological Monitoring" Section

6.1 of the ER.

Provide any updates which have been implemented to the facilities radiological monitoring requirements

as a result of discussions with State and local officials. This information is necessary to address public

comments in the EIS.

RESPONSE:

No updates have been implemented to the facilities radiological monitoring requirements as a result of

discussions with State and local officials. However, soil and vegetation samples have been taken and

analyzed as part of the pre-operational baseline. The 2010 Characterization Report completed by GL

Environmental, Inc. (GLEI, 2010e) is attached. Results of the baseline characterization will be included in

the appropriate sections of the Environmental Report, Chapter 6.

Environmental Report Documentation Impact: Two new paragraphs and Figure 6-2 will be added

after the 7th paragraph of Section 6.1.2.1, "Sampling Program," of the Environmental Report to present

the radiological results from the baseline soil and vegetation sampling. The new paragraphs will read as

follows:

On October 15, 2010, two soil and two vegetation samples were collected and shipped to analytical

laboratories for analysis (GLEI1 2010e). Soil and vegetation sampling location 1 was on the IIFP

"controlled area". Soil and vegetation sampling location 2 was in the "owner-controlled area." downwind

and north of the proposed "controlled area." See Figure 6-2 for locations ofthose samples. The

predominant wind direction was determined using wind rose data shown in Figure 3-57. Radiological

analysis for gamma spectroscopy was perfbrined by contract analytical laboratory. Gamma spectroscopy

included isotopes of uranium, actinium, bismuth, cobalt, cesium, potassium, protactinium, lead, thorium,

and thallium. The contract analytical laboratory holds National Environmental Laboratory Accreditation

Program (NELAP)-recognized certifications in numerous states, DOE Consolidated Audit Program

(DOECAP) approval. USACE approval, U.S. Department of Agriculture (LUSDOA) approval, and

Department of Defense through the US Army. These certifications satisfy the 1IFP ER quality control

requirements in section 6.1.2.2 for contract analytical laboratories.

Results for soil analysis had U-234 values ranging from 4.42E-07 to 5.95E-07 tiCi/g. U-235/236 ranged

from 5.58E-09 to 2.60E-08 [tCi/g. U-238 results ranged from 5.86E-07 to 5.95E-07 ýtCiig. Results from

vegetation tissue samples for isotopic uranium results for sampling location I were all less than minimum

detectable concentrations (MDC). Sanipling location 2 had a positive result of 1.04E-08ttCi/g for J-238.

All other isotopic uranium results were less than MDC (GLEI, 2010e).

Environmental Report Documentation Impact: The 2nd paragraph of Section 6.2.3, "Effluent

Monitoring," of the Environmental Report will be revised to present the chemical analyses of the baseline

sampling conduction in October 2010. The 2"d paragraph of Section 6.2.3 will read as follows:

Parameters for continuing environmental performance will be developed from the baseline data collected

during preoperational sampling. On October 15, 2010, two soil and two vegetation samples were

collected and shipped to analytical laboratories for analysis. See Figure 6-2 for locations of those samples.

Environmental Report Request for Additional Information (RAI 18) Page 132
Official Responses to Environmental Report RAIs

RCRA metal concentrations in the soil samples for barium ranged fr-omn 88.5 to 109 mng/kg. cadmium

fr-om 0.27 to 0.42 mgi/k,. chromium florn 10.0 to 12.2 mg/ka. and lead from I I 7 to 14.7 ma/ka. All other

International Isotopes Fluorine Products N

Site Map with Sampling Locations

..... en " / P d/ e i, c wr, I oar•/oed Area

I WP P •aOua .dFV / Cor•,lole d Ar•e

0 Por and Vegetati on anpl I L e rO 4 ai C "30 1rA F el

Figure 6- 2 Site Map with Sampling Locations

RCRA metals were less than laboratory' minimum detectable levels (MDL), There were no positive

results for organics in soil samples taken on October 15, 2010. For vegetation samples, barium results

ranged from 10.6 to 10.9 mg/kg, and all other RCRA metal results were less than MDL values.

Laboratorv analysis indicated trace amounts of benzoic acid, phenol, and bis(2-ethylhexvl) phthalate in

soil samples. Benzoic acid was present in sampling locations I and 2 at 0.48 and 0.46 mg/kg,

respectively. Bis(2-ethvlhexvl) phthalate was found in vegetation samplel at 0.26 mg/kg, and in sample 2

at 0.19 mg/kg. Phenol was found in sample location 1 at a. concentration of 0.40 mg/kg (GI,El, 201 Oe).

Operational monitoring surveys will also be conducted using sampling sites and at frequencies established

from baseline sampling data and as determined based on requirements. Operational monitoring surveys

are determined based on requirements contained in EPA Region 6 NPDES General Discharge Permits as

well as the NMED/GWQB Ground Wwater Discharge Permit/Plan.

Environmental Report Request for Additional Information (RAI 18) Page 133
Official Responses to Environmental Report RAIs

RA119

Provide full citations of references listed in the "Ecological Resources" Section 3.5 of the ER but not

identified in the "List of References" Chapter 9 of the ER.

The following references are called in Section 3.5, "Ecological Resources ", but not cited in Section 9,

"List of References ", of the ER (IIFP, 2009a)." Painter (2004), CBD (2002), CBD (2009), and USFWS

(2008). Therefore, provide either the reference itself or the complete citation for these references. If any

references in Section 3.5 are extraneous and not needed, then please indicate this fact.

RESPONSE:

A review of the references, particularly in Section 3.5 has been completed, and several references will be

added to Chapter 9, "List of References".

Environmental Report Documentation Impact: Chapter 9 will be revised to add references indicated

above as well as references added as a result of these responses to the RAls. The following references will

be added with the rationale for the addition of the reference:

ATTRA, 2007. ATTRA -. National Sustainable Agriculture Information Service. Publication fl1 P3 10.

"Conserving Fuel on the Farm, National Center for Appropriate Technology, Butte. MT. 2007. (Added as

a response to RAI 8-c revising Section 4.6.1, "Air Quality Impacts from Construction.")

BDD. 2010. Buckman Direct Diversion Project, "Protecting Endangered Species, New Mexico

Burrowing Owl." Santa Fe. NM, 2010. (Added to show the source for Figure 3-48.)

BEA, 1997. Bureau of E...n.mic. Anl.si. Regional, "A U-er Handbook f.r the Re ional Input O,.utput

Modeling S,,, (RIMS II)," U.S. Department o. Commer.e, Washington, D.Cr., 1997. (Reference not

used in Environmental Report.)

CBD. 2002. Center for Biological Diversity, "Petition to List the Sand Dune Lizard Sceloporus

arenicolus as a Threatened or Endangered Species under the U.S. Endangered Species Act." New

Mexico, May 2002. (Added as a response to this RAI and added to show the source of Figure 3-39.)

CBD. 2009. Center for Biological Diversity, "Endangered Species Act Works, Arctic Peregrine Falcon."

New Mexico. May 2009. (Added as a response to this RAI.)

CCI. 2006. Center for Conservation Incentives, "Aldo Leopold's Land Ethic Inspires An IncentivesBased Conservation Partnership," New York. 2006. (Added to show the source of Figure 3-41.)

Envirocare. 2003. Envirocare of Utah, "Envirocare of Utah: Expanding Waste Acceptance Criteria to

provide Low-Level and Mixed Waste Disposal Options'" Utah State University, St. I.ake City, Utah,

February 2003. (Added as a response to new Section 4.13.3.2, "Environmental Impacts of Off-site

Disposal of Depleted Uranium Oxide in a Licensed Disposal Facility." See Environmental Report

Documentation Impact for RAI 2-b.)

EPA. 2002. U.S. Environmental Protection Agency, Emissions by Categorv Report- Criteria Air

Pollutants. Lea County. New Mexico for Volatile Organic Comoounds for 2002.

Environmental Report Request for Additional Information (RAI 19) Page 134
Official Responses to Environmental Report RAls

http://www/e!)a/gov/airidata/geosel.htiil. (Added as a response to RAI 8-c revising Section 4.6.1, "Air

Quality Impacts from Construction.")

EPA. 2010. EPA-420-R- 10-018. NR-009d. Exhaust and Crankcase Emission Factors for Nonroad Engine

Modeling - Compression-Ignition. July. Available online at

http://www.cpa.gov/oms/rnodels/nonrdcldl/nonrdmdld2010/420r 100 18.pd f (Added as a response to RAI

8-a revising Section 4.6.1, "Air Quality Impacts from Construction.")

GAO, 2004. U.S. General Accounting Office, Report to the Chairnan, Committee on Energy and Natural

Resources. U.S. Senate. Low-Level Radioactive Waste, Disposal Availability Adequate in the Short

Term, but Oversight Needed to identify Any Future Shortfalls (GAO-04-604). Washington, D.C. June

2004. (Added as a response to new Section 4.13.3.2, "Environmental Impacts of Off-site Disposal of

Depleted Uranium Oxide in a Licensed Disposal Facility." See Environmental Report Documentation

Impact for RAI 2-b.)

GLE1, 201 0a. GL Environmental, Inc.. "2010 Vegetation Survey Report," las Vegas. NM, November 29.

2010. (Added as a response to ER RAI 14 revising Sections 3.5.3, "Major Vegetation Characteristics' and

Section 3.5.4, "Habitat Importance.")

GLEI, 20 1Ob. GL Environmental, Inc., "Status and Habitat of the Dunes Sagebrush Lizard at the

Proposed Site for the International Isotopes Fluorine Products Facility in Lea County, New Mexico." Las

Vegas, NM. November 29, 2010. (Added as a response to ER RAI 14 revising Section 3.5.7.2, Habitat

subsection.

GLEI, 2010c. GL Environmental. Inc., Letter to Department of the Army. Albuquerque District Corp of

Engineers, "RE: Waters of the U.S. Determination." Las Vegas. NM, November 29, 2010. (Added as a

response to ER RAI 15 revising Sections 3.1.1, "Land Use Status" and Section 3.4.9, "Description of

Wetlands.")

GLEI, 201 Ocd. G(L Environmental. Inc.. "Existing Groundwater Conditions in Section 27. Range 18 South,

Township 36 East," Las Vegas, NM. December 8, 2010. (Added as a response to RAI 11 revising Section

3.4.15.7, "Historical and Current Data from Site Wells.")

GL.,El, 2010e. GL Environmental, Inc., "2010 Soil and Vegetation Characterization Report," Ias Vegas.

NM, December 8.2010. (Added as a response to ER RAI 18 revising Sections 6.1.2.1, "Sampling

Program" and Section 6.2.3, "Effluent Monitoring.")

National Geographic. 2010. National Geographic, "Peregrine Falcon [Falco peregrines." Washington,

D.C. 2010. (Added to show the source of Figure 3-44.)

NN'IED. 2011. New Mexico Environment Department, Ground Water Quality Bureau, Letter from Clint Marshall,

"Preliminary Description of Monitoring Requirements for the Proposed International Isotopes Uranium DeConversion Facility near Hobbs, New Mexico." Santa Fe. New Mexico, February 9, 2011. (Added as a result of ER

RAI II from revised Section 3.4.15.7.)

Painter, 2004. Charles W. Painter. "Conservation of the Sand Dune Lizard in New Mexico,

Recommendations Based on the Management Plan for the Sand Dune Lizard." New Mexico Department

of Game and Fish, New Mexico, February 2004. (Added as a response to this RAI.)

Environmental Report Request for Additional Information (RAI 19) Page 135
Official Responses to Environmental Report RAIs

RMBO, 2010. Rocky Mountain Bird Observatory, "Conserving Birds and their Habitats," Brighton,

Colorado. 2010. (Added to show the source of Figure 3-45.)

SBAI, 2010. Small Business Assistance Program. Colorado Department of Public Health and

Environment, "A Guide to Air Regulations for Gasoline and Diesel Fuel Dispensing Stations," Denver,

Colorado, 2010. (Added as a response to RAI 8-c revising Section 4.6.1, "Air Quality Impacts from

Construction.")

USACE, 2011. U.S. Army Corps of Engineers, Letter to G.L. Environmental, inc.. Subject: Action No.

SPA-2011-00030-LCO, International Isotopes Fluorine Products Facility, January 26, 2011. (Added as a

response to RAI 15 revising Section 3.4.9, "Description of Wetlands" and added letter to Appendix B,

"Consultation Letters.)

USFWS, 2008 reference (Cited in this RAI) from Section 3.5.7.5, "American Peregrine Falcon," revised

to show the reference as USFWS, 2006.

Environmental Report Request for Additional Information (RAI 19) Page 136
Official Responses to Environmental Report RAts

RAI 20

Provide additional information on construction wastes and operations wastes.

a. Provide estimated quantities for construction wastes separately for Phase 1 and Phase 2. Section

3.12.2.1, "Construction Wastes, " of the ER (JIFP, 2009a) provides a non-quantitative description

of construction wastes. Include in the estimates the annual waste generation for each waste type

and the total amount of construction waste by type for each phase. Section 4.2.4.2,

"Construction, " of the ER (IIFP, 2009a) provides an estimate for the number of roundtrips due

to construction materials deliveries and waste shipments. This implies that detailed estimates for

waste generation are available.

Additional detailed information on waste volumes, as described above, is necessary to fully evaluate

potential environmental impacts associated with waste generation and disposal. Also, clarification is

necessary in Table 3-55, as described above, because for the upper range limit of RCRA waste quantities,

the Table shows more waste for Phase ] than for "Totalfor Phase I and Phase 2."

RESPONSE:

Construction wastes have been estimated for Phase 1 and Phase 2. The quantities of each type of wastes

expected to be generated at the IIFP Facility during each phase of operations will be added to the

Environmental Report.

Environmental Report Documentation Impact: Section 3.12 will be revised to refer to a listing of the

type of waste generated during Phase 1 and Phase 2. A new Table 3-58 "Listing of Waste Streams from

the Operation of the IIFP Facility" with the new data will be added. Table 3-55, "Estimated Annual

Quantities of Waste Generated at the IIFP Facility," from Section 3.12.2, "Solid Waste Management,"

will be deleted and replaced with a table having a more detailed listing of wastes. The table will also be

renumbered Table 3-59.

3.12 Waste Manaaement

Waste Management for the IIFP facility is divided into gaseous-] iquids and solid wastes. Liquid process

wastes are not discharged from the IIFP production facilities as shown in Table 3-58. After tertiary

treatment. sanitary water would be discharged to a tree farm. If needed after heavy rainfall events,

stormwater would be discharged from the retention basins to the tree farm after the stormwater was

analyzed and met all groundwater discharge limits. The types of wastes are tabulated in Table 3-58.

Descriptions of the generation, management, and disposal of various wastes from construction and

operations are discussed in this section. Disposal plans, waste minimization, and environmental impacts

are discussed in ER Section 4.13, "Waste Management Impacts."

Environmental Report Request for Additional Information (RAI 20) Page 137
Official Responses to Environmental Report RAls

Table 3- 58 Listing of Waste Streams from the Operation of the IIFP Facility

Ail Linissions

Process Scrubber Stack Process Scrubber Stack

LJUF. Dust Collector Stack LjI:l1 Dust Collector Stack

U.F4 lTransfer Dust Collector Stack UF'.4.'ransfer l)ust Collector Stack

Boiler Stack Boiler Stack

Diesel Generator/Fire Pump Stack Diesel Generator/Fire Pump Stack

FEP Oxide Dust Collector Stack FEP Oxide Dust Collector Stack

Lime Unloading Dust Collector Stack Lime Unloading Dust Collector Stack

t_2-3 Unloading [)ust Collector Stack B20.3 Unloading [Dust Collector Stack

Future Oxide Dust Collector Stack

CaF' Dust Collector Stack Cal, Dust Collector Stack

CaF2 Drjer Combustion Stack CaF-, DrLer Combustion Stack

Laboratory Hood Stack Laboratory Hood Stack

Eqvaporator Stack Evaporator Stack

Hydrogen Generator Vent Stack Hydrogen Generator Vent Stack

Decon Dust Collector Stack Decon 1Dust Collector Stack

Building Air Vents Building Air Vents

Solid Waste >'2~~~~U

Carbon Carbon

a.rbont Filters Carbon Filters

Coke Coke

Drums Drums

Iog fExchange Resi n-Softeners Ion Exchange Resin-Softeners

Dust Collector Bags Dust Collector Bags

SFT4 Clinkers UIT' Clinkers

Oil Sorb, Dirt Oil Sorb. Dirt

Oxide and Drums Oxide and Drums

Radioactive Waste Trash Radioactive Waste Trash

Sintered Tubes Sintered Tubes

Wood Trash Wood Trash

Aerosol Cans/Paint Cans/Bulbs Aerosol Cans/Paint Cans/Bulbs

Molecular Sieve Molecular Sieve

Municipal Trash Waste Munllicipal Trash Waste

Satfety Gear Safety Gear

Waste Glass Waste Glass

Calcium Fluoride Calcium Fluoride

Oily Rags, Solvents Oily Rags. Solvents

Activated Alumina And NaF Activated Alumina And NaF

Lab Chemical Waste Lab Chemical Waste

Sanitary Waste Biomass Sanitary Waste Biomass

Maintenance Trash Maintenance Trash

Food Waste Food Waste

'.trash Metal Trash Metal

Ion Exchange Resin-Decon lon Exchange Resin-Decon

Medical Waste Medical Waste

HEPA Filters HEPA Filters

Grit Blast Material Grit Blast Material

Environmental Report Request for Additional Information (RAI 20) Page 138
Official Responses to Environmental Report RAIs

Ph::ase I Phase 2

Boiler Blow-down/Not Discharaed Boiler Blow-down/Not Discharged

Softener Resin Back Flush/Not Discharged Softener Resin Back Flush/Not )ischarged

Laundry Waste,/Not Discharged Laundry Waste/Not Discharged

Lab Liguids/Not Dischar-ed Lab Liquids/Not Discharued

Decon ShowerhNot Dischareed Decon Shower/Not Dischared

Stormwateri Discharged if Needed after Stormwater/ Dischar ed if Needed after

Analysis to Tree Farm Analysis to Tree Farm

Sanitai Water/Tertiary Treated/Sent To Tree Sanitary WateriTertiary Treated/Sent To Tree

Farm Farm

Table 3-59 Estimated Annual Quantities of Waste Generated at the lIIFP Facility

Rhase1 * hase 2

~Tp onstruction Operations C onstruction prtm

Wa ste(1b) (Ib) WasteM( (b( Operaýtins

Adhesives. Resins, Caulking RCRA 100-200 120-240

Residues

Aerosol Cans/Paint RCRA 1,000-3,000 2,000-

Cans/Bulbs 4,000

Calcium Fluoride* RCRA 200,000- 60,000-

300,000 90,000

Lab Chemicals RCRA 200-400 200-400

Lead (Batteries) RCRA 100-250 100-250

Oil Filters RCRA 100-200 100-200

Oil Sorb (Dirt Removal) RCRA 2,000-5,000 3,000- _7.000

Paint. Thinners, Solvents, RCRA 100-500 100-500

Organic Residues

Pesticides RCRA 100-150 100-150

Petroleum Products. Oils, RCRA 100-500 100-500

Lubricants Residues

Total 4RCRA :600 Waste CRA 1.e'00 20 o,; 2 00020- 1840 6 5

4002,000-

Activated Alumina LLW 2,000-4,000 2,000-

4,000

Air Ventilation Filters LLW 50-100 65-100

25.000- 25,000- 30,000 .35,000

DUF 4 Clinkers LLW 5.000- 5,000-

10,000 10.000

Coke LLW 8,000- 8,000- 12,000 12,000

Environmental Report Request for Additional Information (RAI 20) Page 139
Official Responses to Environmental Report RAls

Phase I Phase 2

'Mateial TYp1)e Construction Operations Construction 11 vgIated

Waste (1b) (i Waste (Ib) Operations

Crushed Drums L LW 1,000-3,000 2.000-

1,000- Dust Collector Bags LLW 500-3,000 3,000

2,000- Ion Exchange Resin LLW 1 ,000-2,000 4,000- 4,000

2,800,000- 8,700,000-

Oxide for Burial plus Drums LLW 6,800.000 8,70,__ ,000-

0350.000- 70),()0.00-

Radioactive Waste Trash LLW 35,000- 70,000- 55,000 100.000

Scrap Metal LLW 4,000-6,000 4,000-8,000 4,000-6,000 12,000-

2,000-

Sintered Metal Tubes LLW 1,000-2,000 3,000

2,000-

Sodium Fluoride LLW 2,000-4,000 2,000

4,000

Spent Blasting Sand L LW 100 100-200 100 100-200

3,000- Wood Trash (Pallets) LLW 1,000-1,500 1,000-4,000 1,000-1,500 12,000

Total LLW LLW 5,100-7,600 2,885,650- 5,100-7,600 8,834J65-

S_6337.300- 20,211,300

Air Filters-Vehicles SW 50-100 50-100

CardboarcL'Packing SW 300-500 300-500

Clothing SW 100-200 150-300

Fiber Drums SW 300-500 300-700

Molecular Sieve SW 300-500 3300-500

Municipal Trash Waste SW 60,000- 72,000-

(Misc. and Sanitary) 90,000 108,000

Safety Gear SW 200-400 400-800

Waste Glass SW 50-200 75-300

Total Other Solid Wastes SW 650-1.100 60,650- 650-1,300 72,925-

• _91.300 109.900

Total Solid Waste WRCRA,. 6,350-10500 3,149,500- 6,370-10,740 8,972,290- TotaSWlolid7700 20,422.600

*Less CaF2 is generated from the operations in Phase 2 than in Phase I.

Environmental Report Request for Additional Information (RAI 20) Page 140
Official Responses to Environmental Report RAls

RAI 20

Provide additional information on construction wastes and operations wastes.

b. Clarify the total Phase ] and Phase 2 column entry for Resource Conservation and Recovery Act

(RCRA) operation waste in Table 3-55, "Estimated Annual Quantities of Waste Generated at the

IIFP Facility," of the ER (IIFP, 2009a). The range of RCRA waste reported for both phases is

45,500 lb to 174,000 lb, which is less than the range reported for Phase ] which is 32,300 lb to

361,500 lb. Please clarify.

Additional detailed information on waste volumes, as described above, is necessary to fully evaluate

potential environmental impacts associated with waste generation and disposal. Also, clarification is

necessary in Table 3-55, as described above, because for the upper range limit of RCRA waste quantities,

the Table shows more waste for Phase ] than for "Total for Phase ] and Phase 2."

RESPONSE:

The major portion of the RCRA waste is the potential waste CaF2. The production of CaF2 is much less in

Phase 2 than Phase 1. This is a result of using water on certain process scrubbers for capturing HF as

aqueous HF (versus KF with KOH) and transferring this liquid to the Phase 2 oxide process to react with

DUF 6.The HF solution after reacting with DUF 6 is eventually distilled and separated as anhydrous

hydrofluoric acid. Updated estimates for Phase 1 and Phase 2 RCRA wastes are provided in Table 3-59

shown in the Environmental Report Documentation Impact for RAI 20-a. Note the asterisk for the CaF2 in

Table 3-59 which reads "Less CaF2 is generated from the operations in Phase 2 than in Phase 1."

Environmental Report Documentation Impact: Paragraph six of Section 3.12.2, "Solid Waste

Management," will be revised to clarify the negative differential in the RCRA waste from Phase 1 to

Phase 2 operations. Section 3.12.2 will read as follows:

Resource Conservation and Recovery Act (RCRA) hazardous wastes will be collected and packaged in

approved containers and shipped by a licensed RCRA transporter and sent to licensed RCRA disposal

facility. Under New Mexico regulations, a facility that generates more than 1,000 kg (2,200 lb) per month

is a large quantity generator of RCRA wastes. In New Mexico, hazardous waste generators are classified

by the actual monthly generation rate, not the annual average. The major portion of the RCRA waste is

the potential waste CaF2 . As shown in Table 3-59. ,the production o tCaFV is much less in Phase 2 than

Phase 1. This is a result of usine water on certain process scrubbers for capturing HF as aqueous HF

(versus KF with KOH) and transf'errin.4 this liquid to the Phase 2 oxide process to react with DUF6. The

HF solution after reacting, with DUF(, is eventually distilled and semirated as anhydrous hydrofluoric acid.

Environmental Report Request for Additional Information (RAI 20) Page 141
Official Responses to Environmental Report RAIs

RAI21

Provide additional information regarding past land use of the project area that may have already been

collected by IIFP.

a. Provide any information that has been collected on non-developmental human use such as cattle

grazing. Include, if available, property research results and informant interview memoranda.

This information is necessary in order to document past land uses/activities that have taken place in the

project area and also to evaluate the potential for historic and cultural resources within the project area.

The Phase I Environmental Site Assessment documents past development through historic aerial

photographs. These photographs document that the project area has been largely undeveloped, but do not

document human use that would not be considered "development, "such as extensive use of the area as

rangeland for cattle. Although it is not required in the negative survey report that was prepared by the

archaeological consultant, this information may have been gathered through property research or

informant interviews.

RESPONSE:

The 4th paragraph of Section 1.4.7, "Surveys Conducted," of the Environmental Report provides a listing

of various governmental agency databases that were reviewed as part of the Phase 1 Environmental Site

Assessment conducted in 2009 by BBC International, Inc. on the subject property. The results of those

reviews are provided in Section 1.4.7. Additionally, a real estate title search was conducted as part of the

Phase 1 Environmental Site Assessment. The title search is included below.

Environmental Report Request for Additional Information (RAI 21) Page 142
Official Responses to Environmental Report RAls

NO. 09-231-C

TITLE REPORT & 1IMITED CiR1I'IFICAT' OF SIACH

The undersigned, ELLIOTT & WALDRON TITLE & ABSTRACT CO., INC., a corporation

duly bonded and qualified under the laws of the State of New Mexico, and engaged in the business

of making and certifying to abstract of title to real estate in the State aforesaid, does hereby certify

that with reference to the following described real estate:

SURFACE TITLE ONLY:

ALL OF SECTION 27, TOWNSHIP 18 SOUTH, RANGE 36 EAST, N.M.P.m., LEA

COUNTY, NEW MEXICO.

a search of the records of the office of the County Clerk of Lea County, New Mexico, with the

exception of'financing statements or other documents reflecting security interest or possible security

interests in crops, fixtures or other personal property filed in the records of the County Clerk,

pursuant to the Unifomi Commercial Code, discloses the following:

1, RIGHT OF WAY: dated 06-18-51, filed 06-23-51, Book 141, Page 25, Deeds Records, Lea

County, New Mexico, Executed by Hobbs Houses, Inc. to New Mexico Electric Service

Corp.

2. RIGHT OF WAY: dated 07-03-58, filed 08-04-58, Book 225, Page 173, Deed Records, Lea

County, New Mexico. Executed by State of New Mexico to Lea County Board of

Commissioners.

3. RIGHT OF WAY: dated 08-25-64, tiled 09-18-64, Book 285, Page 439, Deed Records, Lea

County, New Mexico. Executed by State of New Mexico to Southwestern Public Service

Co.

4-. RIGHT OF WAY: dated 03-15-65, filed 04-29-65, Book 29 I, Page 317, Deed Records, Lea

County, New Mexico. Executed by State of New Mexico to Northern Natural Oas Company.

S. RIGHT OF WAY: dated 05-17-72, filed 06-15-72, Book 329, Page 527, Deed Records, Lea

County, New Mexico, Executed by State of New Mexico to Santa Fe Pipeline Co.

6. RIGIHT OF WAY: dated 09-18-72, filed 09-22-72, Book 331, Page 58, Deed Records, Lea

County, New Mexico, Executed by State of New Mexico to Southwestern Public Service

Company.

7. NOTICE: dated -, filed 01-05-78, Book 346, Page 329, Miscellaneous Records, Lea

County, New Mexico, Executed by Llano, Inc. to Ex Parte. RE: RW from State to Llano,

[inc,

8. RIGHT OF WAY: dated 10-30-78, filed 10-03-79, Book 376, Page 776, Deed Records, Lea

County, New-Mexico. Executed by State o fNew Mexico to Northern Natural Gas Company.

9. NOTICE: dated -, tiled 08-25-80, Book 374, Page 496, Miscellaneous Records, Lea

County, New Mexico. Executed by Llano, Inc. to Ex Parte. RE: RW

10. NOTICE: dated -. filed 05-11-82, Book 400, Page 711, Miscellaneous Records, lea

County, New Mexico, Executed by Llano, Inc. to Ex Parte. RE: RW from State.

Environmental Report Request for Additional Information (RAI 21) Page 143
Official Responses to Environmental Report RAls

TuITm. EiuPORT & LIM'IITEID CERTIFICATE '01F SYARCH PAGE NO. 2

II. RIGHTOF WAY: dated 10-17-83,filed 12-19-83, Book 409, Page 338, Deed Records, Lea

County, New Mexico. Executed by State of New Mexico to Southwestern Public Service

Company.

12. NOTICE: dated 03-01-85, filed 03-06-85, Book 443, Page 286, Miscellaneous Records, Lea

County, New Mexico. Executed by Llano, Inc. to Ex Parte. RE: RW

13. RIGHT OF WAY: dated 09-04-86, filed 09-18-86, Book 430, Page 287, Deed Records, Lea

County, New Mexico. Executed by State of New Mexico to General Telephone Company

of the Southwest.

14. RIGHT OF WAY: dated 06-10-87, filed 07-07-87, Book 436, Page 632, Deed Records, Lea

County, New Mexico. Executed by State of New Mexico to Southwestern Public Service

Company.

15. EASEMENT / RIGHT OF WAY: dated 06-19-89, filed 08-10-89, Book 455, Page 312,

Deed Records, Lea County, New Mexico. Executed by Broadmoor Properties, Ltd. to

Southwestern Public Service Company.

16. CONVEYANCE ASSIGNMENT: dated 12-31-90, filed 01-02-91, Book 536, Page 273,

Miscellaneous Records, Lea County, New Mexico. Executed by Enron Corp. I1.1

a Northern

Natural Gas Company to Northern Natural Gas Company. RE: RW 376-776

17. CONVEYANCE ASSIGNMENT AND BILL OF SALE: dated 3-31-92, filed 4-9-92,

Book 555, Page 287, Miscellaneous Records, Lea County, New Mexico. Executed by The

Maple Gas Corporation, The Maple Gathering Corporation to Picor Pipeline Company. RE:

RW

18. CONVEYANCE ASSIGNMENT AND BILL OF SALE: dated 3-31-92, filed 4-9-92,

Book 555, Page 413, Miscellaneous Records, Lea County, New Mexico, Executed by The

Maple Gas Corporation, The Maple Gathering Corporation to Picor Pipeline Company. RE:

RW

19, RIGHT OF WAY: dated -, filed 09-23-94, Book 505, Page 92, Deed Records, Lea County,

New Mexico. Executed by State of New Mexico to Pinnacle Natural Gas Company.

20. ASSIGNMENT AND CONVEYANCE: dated 10-27-94, filed 11-15-94, Book 506, Page

340, Deed Records, Lea County, New Mexico. Executed by Llano, Inc. to Minerals, Inc.

21. PARTIAL ASSIGNMENT OF RIGHT OF WAY, EASEMENTS AND PERMITS:

dated 12-29-94, tiled 03-01-95, Book 509, Page 378, Deed Records, Lea County, New

Mexico. Executed by Northern Natural Gas Company to Hobbs Processing Company. RE:

RW 376-776

22. RIGHT OF WAY: dated 05-22-95, filed 06-20-95, Book 512, Page 481, Deed Records, Lea

County, New Mexico. Executed by State ol'New Mexico to GPM Gas Corporation.

23. RIGHT OF WAY: dated 01-23-96, filed 03-28-96. Book 717, Page 422, Lea County

Records, Lea County, New Mexico. Executed by State of New Mexico Commissioner of

Public Lands to GPM Gas Corporation.

24. PIPELINE DEED AND ASSIGNMENT: dated 08-20-96, filed 09-04-96, Book 747, Page

689, Lea County Records, Lea County, New Mexico. Executed by Chevron U.S.A. Inc.,

l;'k/a Gulf Oil Corporation to Midstream Combination Corp. RE: RW from NM State Hvwy

Dept to Gulf Oil Corp.

Environmental Report Request for Additional Information (RAI 21) Page 144
Official Responses to Environmental Report RAIs

1TITLE REPORT & LIMITED) CERTIIFICAlI i OF1 SEARCHI PAGE NO. 3

25, DEED ASSIGN M ENT A ND CONVEYANCE: dated 08-29-96, tiled 09-05-96, Book 748,

Page 506, Lea County Records, Lea County, New Mexico, ExcCuted by NGC Corp., NGC

Holding Company, Inc., Warren Petroleum G.P. to WPC LP, Inc., Warren Petroleum

Company, Limited Partnership. RE: 747-689 RW from NM State Hýwy Dept to Gulf Oil

Corp.

26. RIGHT OF WAY: dated 02-27-80, filed 03-25-98, Book 865, Page 216, Lea County

Records, Lea County, New Mexico. Executed by State of New Mexico to Gulf Oil

Corporation.

27. ASSIGNMENT AND CONVEYANCE: dated 08-31-98, filed 01-11.99, Book 929, Page

618, Lea County Records, Lea County, New Mexico. Executed by Koch Pipcline Company,

LP to Koch D-K 11, Itic. RE: RW 329-527

28. ASSIGNMENT AND CONVEYANCE: dated 09-01-98, filed 01-1 1-99, Book 929, Page

629, Lea County Records, Lea County, New Mexico. Executed by Koch D-K 11, Inc, to

Diamond-Koch, LP, RE: RW 329-527

29. ASSIGNMENT AND CONVEYANCE: dated 09-01-98, filed 01- 11-99, Book 929, Page

640, Lea County Records, Lea County, New Mexico. Executed by Diamond-Koch, LP to

Diamond-Koch 11, LP. RE: RW 329-527

30. ASSIGNMENT AND BILL OF SALE: dated 09-01-98., filed 04-02-99, Book 946, Page

1, Lea County Records, Lea County, New Mexico. Executed by Dynegy Midstream

Services, Limited Partnership to Versado Gas Processors, LLC RE: RW from State to Gulf

dated 3-19-80

31. CONVEYANCE ASSIGNMENT AND BIIIL OF SALE: dated 05-01-99, filed07-01-99,

Book 964, Page 1, Lea County Records, Lea County, New Mexico. Executed by Texas-New

Mexico Pipe Line Company to Eott Energy Pipeline Limited Partnership. RE: RW fronm State

to Gulf dated 3-19-80

32. ASSIGNMENT OF EASEMENTS: dated 12-30-97, filed 07-20-99, Book 967,Page 597,

Lea County Records, Lea County, New Mexico. Executed by AOG Gas Transmission

Company. LP to Transwestern Pipeline Company. RE: RW from State of NM to Gulf dated

6-24-77

33. CONVEYANCE ASSIGNMENT ANOBILL OF SA LE: dated 05-01-99, filed 07-20-99,

Book 968, Page 1, Lea County Records, Lea County, New Mexico. Executed by Texas-New

Mexico Pipe tine Company to Eott Energy Pipeline Limited Partnership. RE: 964-1

34. ORDINANCE: dated 11-02-99, filed 11-02-99, Book 2, Page 300, Lea County Records, Lea

County, New Mexico. Executed by Lea County Board of Commissioners to Ex Parte.

35. ORDINANCE: dated I 1-02-99, filed 11-02-99, Book 2, Page 3 10, Lea County Records, Lea

County, New Mexico. Executed by Lea County Board of Commissioners to Ex Parte.

36. NOTICE: dated -, filed 11-29-00, Blook 1049, Page 777, Lea County Records, Lea County.

New Mexico, Executed by Llano, Inc. to LG&E Natural Pipeline, LLC.

37. ASSIGNMENT: dated 06-29-01, filed 08-02-01, Book 1093, Page 151, Lea County

Records, Lea County, New Mexico. Executed byRaptor Natural Pipeline, LLC, f/k/a LG&E

Natural Pipeline, LLC, Successor by merger of LG&E Natural Pipeline CO & LG&E

Storage, LLC to Raptor Natural Pipeline, LLC. RE: RW 346-329

38. ORDINANCE: dated 05-07-02, tiled 05-07-02, Book 2, Page 411, Lea County Records, Lea

County, New Mexico. Executed by Lea County Board of Commissioners to Ex Parle.

Environmental Report Request for Additional Information (RAI 21) Page 145
Official Responses to Environmental Report RAIs

TITLE REIORT I & LIMI ltED C(FtI FlII I F0 S]AAR( "O H P( ,; NO. 4

39. CONVEYANCE ASSIGNMENT AND BILL OF SALE: dated--, filcd 05-22-02, Book

1148, Page 282, Lea County Records, Lea County, New Mefxico. Executed by DiarimondKoch [1 LP to Chaparral Pipeline Company, LP.

40. CONFIRMATORY CONVEYANCE AND ASSIGNMENT: dated 06.10-03, filed 06-

25-03, Book 1233, Page 843, Lea Courty Records, Lea County, Newx Mexico. Executed by

Pinnacle Natural Gas Company to Markwest Pinnacle, ILP RI; RW 5(05-92

41. AMENDMENT AND CORRECTION TO CONVEYANCE ASSIGNMENT ANI)

BILL OF SALE: dated -, filed 08-12-03, 11nk 1245, Page 550, Lea County Records, Lea

County, New Mexico, Executed by Diamond-Koch 1I, LIT to Chaparral Pipeline Company.

l.P. RE: Amends 1 148-282

42. AMENDMENT TO CONVEYANCE ASSIGNMIENT AN)D •tL L OF SALE: dated

3-31-04, filed 04-13-04, Book 1295, Page 558, Lea County Records, Lea County, New

Mexico. Executed by Texas-New Mexico Pipe Line Company to Link Energy Pipeline LP,

f/k.a Eott Energy Pipeline LP, RE; 968-1 and 964-1

43. CONVEYANCE ASSIGNMENTANDIBILL OF SALE: dated04-30-04, filcd05-14-04,

Book 1304, Page 172, Lea County Records, Lea County, New Mexico. Executed by Raptor

Cas Tan1mission IC to Duke Energy Field Services, LP. RE: RW 346-329

44, CONVEYANCE ASSIGNNIINT AND BILL OF SALE: dated 04-30-04, filed 05-14-04,

Book 1304, Page 262, Lea County Records, Lea County. New Mexico. Executed by Raptor

Natural Pipeline LLC to DEFS Raptor Pipeline, I,LC, RE: RW 400-711

45. AFFIDAVIT: dated -, filed 5-6-05, Book 1372. Page 393, Lea County Records, Lea County,

New Mexico. Executed by Raptor Natural Pipeline, L.LC successor to LG&E Natural

Pipeline LLC to Ex Parne. RE: Notice 1049-777,

This Title Report and Limited Certificate of Search covers a period of time from:

JUNE 23, 1951 AT 7:00 A.M. TO JUNE. 1, 2009 AT 7:00 A.M.

This Title Reporit and Limited Certificate of Search is intended to reflect only those

documents that appear to convey title to said real estate. We have made no attempt to show any

other documents or court proceedings of'record affecting said real estate, a complete listing will he

furnished upon request.

Since retfcrcce to the documents above must be made to determine their validity, no liability

is assumed for any defects or errors which may appear thereoa, nor for failure to show District Court

matters which do not aftlct title to real estate, Copies of these documients can be obtained upon

request at an additional charge,

This is not an abstract, and the liability of Elliott & Waldron Title & Abstract Co., Inc., issuer

taider this Limited Certificate. is limited to a refund of the consideration paid for this Limited

Certificate and is to run only in favor of the person paying such consideration in the first instance.

Issuer expressly disclaims any and all other liabilities, warranties, or responsibilities hereunder to

any and all other persons.

Environmental Report Request for Additional Information (RAI 21) Page 146
Official Responses to Environmental Report RAIs

TITLE REPORT & LIMITEI) C!TRTIFICATE OF SEARCH PAGE NO. 5

IN WITNESS WHEREOF, the said Ellioti & wakdron Title & Abstract Co,, Inc.,, has

caused this Certificate to be signed by its proper officer on this l0" day of June, 2009.

ELLIOTT & WALDRON TITLE & ABSTRACT CO., INC.

BySecky *Saval, Assistant Secretary

Scarcher-Bjs

NO. 09-23 1-C

Environmental Report Documentation Impact: None

Environmental Report Request for Additional Information (RAI 21) Page 147
Official Responses to Environmental Report RAls

RAI 21

Provide additional information regarding past land use of the project area that may have already been

collected by IIFP.

b. Provide available information concerning previous development for oil/gas and other energy

infrastructure such as exploratory wells, abandoned oil/gas exploration infrastructure, and gas

and power line rights-of-ways.

This information is necessary in order to document past land uses/activities that have taken place in the

project area and also to evaluate the potential for historic and cultural resources within the project area.

The Phase I Environmental Site Assessment documents past development through historic aerial

photographs. These photographs document that the project area has been largely undeveloped, but do not

document human use that would not be considered "development, "such as extensive use of the area as

rangeland for cattle. Although it is not required in the negative survey report that was prepared by the

archaeological consultant, this information may have been gathered through property research or

informant interviews.

RESPONSE:

No oil/gas drilling has been conducted on the site. However, numerous transmission lines and pipelines as

well as miscellaneous oil/gas facilities are located on the site. The 2 nd and 3rd paragraphs of Section 1.4.7,

"Surveys Conducted," of the Environmental Report provide a listing of the lines and miscellaneous

facilities on the site. Figure 1-6 of the Environmental Report depicts the easements on the IIFP Site.

Figure RAI 2 l-b-1 below provides a map of the 640-acre IIFP Site showing the right-of-ways to the gas

and electric companies in relation to the IIFP Facility. Figure RAI-b-2 provides a listing of those right-ofways.

Environmental Report Documentation Impact: None.

Environmental Report Request for Additional Information (RAI 2 1) Page 148
Official Responses to Environmental Report RAIs

Figure RAI 21-b-I Right-of Ways on IIFP 640-Ac site

Environmental Report Request for Additional Information (RAI 21) Page 149
Official Responses to Environmental Report RAIs

PIP~IINF FjVIJFN!rCCN I 1 r]P1 I Vqý': NO, _______________ A(: flvdýN."I~ A/ l I'-"F $ I/__________

KEN t;.2E W, ; 19 C1 N1,4TR'* (ýA3 AC' ,IW P_~Y 9

__________________________ ; ~FRu~~i'~~ ________20__

NAC) [,-,;%LN CA5 ~ I;I

_____________________________________00 1_________ , 'AT JR___-__1,___

_____________________________ __________ MATU PA , ',A, S

_____________________________4_j__CotI __________ AT I~ P"1 #, C .4 ', 1A

~rw r;t A.i~ ~'i;.~v___,_____9__ NfATORI,4 4M~v I 2i P________

MARKW."i 1 P, HA I OWL~: 1'A!, AZ I VI- ________ .

I U H II. NIi A?(Q~PArNIJ S kir WUIL tl 4 b~O jljitlf INC4I (-IC lIII C N 2C3 G A l 1\J N'CA COP &11 - 1 Ný

P AIN .' PIP EL:,rj 4 Nn C

1KV CI3

Figure RAI 21-b-2 Listing of the Right of Ways on the IIFP 640-Acre Site

Environmental Report Request for Additional Information (RAI 21) Page 150
Official Responses to Environmental Report RAIs

RAI 22

Provide support for the ER claim of better than industry average occupational safety statistics.

For example IIFP could provide the last 5 years of Occupational Safety and Health Administration

reports for an 11FP facility that does comparable work.

The discussion of worker safety in Section 3.11.2.1 of the ER (IIFP, 2009a) does not provide details to

support the claim of better than industry average.

RESPONSE:

The first sentence of Section 3.11.2.1 claiming that occupational injuries rates are expected to be better

than industry average occupational safety statistics has been deleted. The manufacturing industry and the

private industry safety statistics are compared for the years 2005 through 2009 in Table RAI 22-1 with

those of INIS (the parent company of LIFP). Since the total number of employees for INIS is generally

below 30 for those years, comparisons with the private industry and manufacturing industry would not be

valid. Section 3.11.2.1 will be revised to reflect the 5-year data instead of the 2007 data supplied initially

in the ER.

Table RAI 22-1 Comparison of INIS Occupational Safety Statistics with the Manufacturing and

Private Industries

industry. Year Average Total Recordable ,,Wo Employment Cases Total DAFW_ DJTR,

....... (Thousands) _ ...... ,

Manufacturing 2009 12,696.5 4.3 2.3 1.0 1.3 2.0

Manufacturing 2008 13,735.0 5.0 2.7 1.2 1.5 2.3

Manufacturing 2007 14,071.4 5.6 3.0 1.3 1.7 2.5

Manufacturing 2006 14,150.0 6.0 3.3 1.4 1.9 2.7

Manufacturing 2005 14,212.8 6.3 3.5 1.5 2.0 2.8

-Manufacturing (2005-- . .. 5.4 3.0 1.3 1.7 2.5

Average 2009)

Private Industry 2009 111,469.1 3.6 1.8 1.1 .8 2.0

Private Industry 2008 115,352.6 3.9 2.0 1.1 .9 1.9

Private Industry 2007 114,833.4 4.2 2.1 1.2 0.9 2.1

Private Industry 2006 111,273.1 4.4 2.3 1.3 1.0 2.1

Private Industry 2005 109,127.0 4.6 2.4 1.4 1.0 2.2

Private industry (2005- l12411.0

Aveag 2009) 4.1 2.1. 1.2 0.9 2.1

INIS 2009 26.7 (actual) 0 0 0 0 0

INIS 2008 30.6 (actual) 2 1 0 1 1

INIS 2007 25.36 (actual) I 1 0 0 1

INIS 2006 25.53 (actual) 0 0 0 0 0

INIS 2005 18.32 (actual) 0 0 0 0 0

INIS Average (2005- 25.3 (actual) 0.6 0.4 0 0.2 . .4

________________ 2009) ________ ________ __________ _____ _____

RtrIcd - Oays Cway s iers WORK, JOth I rardsler, or asCestrlcte Cases; Uk\ W Restricted Only Cases; ORC - Other Recordable Cases Days Away trorn Work Cases; DJTR - Days ot Job Transfer or

Environmental Report Documentation Impact: Section 3.11.2.1, "Occupational Injury Rates," will be

revised to delete the claim that occupational injury rates at the I1FP Facility are expected to be better that

Environmental Report Request for Additional Information (RAI 22) Page 151
Official Responses to Environmental Report RAls

the industry average and to use the 2005-2009 average industry rates for calculating the expected

occupational injury rates for the construction of IIFP Facility and for the operations of the facility. Former

Table 3-54 will be updated and renumbered to Table 3-57.

3.11.2.1 Occupational Injury Rates

Occupational injur:,' rates at the IIPP faeility) ar-e expected to be better than the industiry aveag oingto

the eommiitment that IIEP is making in a safe design basis for facilities and pr-ogr-ams, 'he safety cul~ture.

and adherence .SMS to the pr..gram and procedbires. IIFP senior management commitment to safety is

evident by its safety experience at its Idaho Falls facility and the OSHA Safety and Health Achievement

Recogznition Protram (SHARP) recognitions it has received. Common occupational accidents at uranium

plants similar to the proposed IIFP f3a1-•Facilitvytypically involve hand and finger injuries, tripping

accidents, minor burns and impacts due to striking objects or falling objects. Table 3-M-5457 shows

incidence rates representative of the nonfatal occupational injuries from the construction and operation for

Total Private Industry. This representative calculation is based on the Bureau of Labor Statistics of the

U.S. Department of Labor (2005-2009-). The representative number of injuries would be that number for

the Total Private Industry rate if the industry had an average of 200 workers during the construction of the

facility for 18 months and 150 average workers during the operations of the facility.

Table 3- ,5457_ Nonfatal Occupational Injuries Projected for Construction and Operations-of the

IIFP Facility

Construction (18 months) Operations (Yearly)

Case Type Incidence - Number Incidence Number

Rate' Rate'

Total Recordable Cases (TRC) 4.l2 12.36 4.12- 6.2a

Days Away from Work, Job Transfer, or 2.1 6.3 2.1 3.15

Restriction Cases (DART)

Days Away From Work Cases (DAFW) 1.2 3.6 1.2 1.8

Days of Job Transfer or Restricted Only Cases 0.9 2.7 0.9 1.35 (DJTR) 092709]3

Other Recordable Cases (ORC) 2.1 6.3 2.1 3.15

ITRC by Elmploymenit Size 4-g_9 ___5__4

Source: Bureau of Labor Statistics, U.S. Department of Labor (BLS, 2005-2009,)

'2005-20097 Incidence Rate per 100 full-time workers for Total Private Industry

Environmental Report Request for Additional Information (RAI 22) Page 152
Official Responses to Environmental Report RAIs

RAI 23

Provide clariflcations on mitigation measures.

Separate the mitigation measures proposed in Sections 5.2.3, "Geology and Soils, " 5.2.4, "Water

Resources, " 5.2.5, "Ecological Resources, " and 5.2.6, "Air Impacts, " into those that would be

implemented during the project's pre-construction/construction and during operations. The text in these

sections describes the mitigation measures listed as being in place to minimize impacts during

construction or operations. However, it is not always clear at which time a specific mitigation will be

implemented. For example, in Section 5.2.3, one mitigation measure that "will be in place during prelicensing and general construction, operations, and decommissioning" is described as "Berms will be

utilized and Spill Prevention Control and Countermeasures Plan will be implemented. "

It is reasonable that a Spill Prevention Control and Countermeasures (SPCC) Plan will be implemented

during construction to mitigate fuel or similar liquid spills; however, in Section 5.2.13, "Waste

Management, "IIFP states that "a Spill Prevention Control and Countermeasures Plan will be prepared

prior to the start of operation of the facility or prior to the storage of oil on site.... " It is not clear when

reading Section 5.2.3 and 5.2.13 if the SPCC Plan will be in place during pre-construction and

construction as well as during operations. As written in the ER, the proposed mitigations cannot always

be associated with a specific project activity.

RESPONSE:

Sections 5.2.3, 5.2.4, 5.2.5, and 5.2.13 will be revised to list separately the mitigation measures to be

taken during construction activities and operations.

Environmental Report Documentation Impact: Sections 5.2.3, 5.2.4, 5.2.5, and 5.2.13 will be revised

to separate the mitigation measures to be taken during construction activities from the mitigation

measures to be taken during operations. Revised Sections 5.2.3, 5.2.4, 5.2.5, and 5.2.13 will read as

follows:

5.2.3 Geology and Soils (Revised section.)

Mitigation measures will be in place during preconstruction licensing and general constructionT

.pe.atiof.s. and dee..mnissifnin•, .. to minimize impact to geology and soils.These measur. .

includefErosional impacts due to site clearing and grading will be mitigated by utilization of construction

and erosion control BMPs, some of which are further described below:-.

* The construction footprint will be minimized to the extent possible.

* Disturbed soils will be stabilized by acceptable means as part of the construction work.

* Earthen berms, dikes and sediment fences will be utilized as necessary during construction phases

sgesto limit suspended solids in runoff.

" Cleared areas not covered by structures or pavement will be stabilized by acceptable means as

soon as practical.

• Watering may be used to control fugitive dust.

* Collect surface runoff in temporary sdetention basins (during construction) anl, permanent

i-eteniicin/eNapotratien basins (dur-ing oper-ations).

Environmental Report Request for Additional Information (RAI 23) Page 153
Official Responses to Environmental Report RAIs

* Standard drilling and blasting techniques, if required, will be used to minimize impact to bedrock;

reducing the potential for over excavation thereby minimizing damage to the surrounding rock.

* Drainage culverts and ditches will be stabilized and lined with rock aggregate to reduce flow

velocity.

* Soil stockpiles generated during construction will be placed in a manner to reduce erosion.

* Excavated materials will be reused whenever possible.

* Berms will be utilized and Spill Prevention Control and Countermeasures Plan will be

implemented.

Mitigation measures will be in place during the operations of the I1FP to minimize impact to geology and

soils. These measures include:

* Routine visual inspections and preventive maintenance will be conducted.

• Above ground storage tanks of appropriate materials will be constructed.

* Secondary containment for tanks storing petroleum products and hazardous chemicals will be

used.

- Be1rms will be utilized -and Spill Prevention Control and Crunterneasures; Plan will be

" Spill cleanup materials in the areas of fuel line and tank hose connections will be maintained.

* Contaminated soils will be sampled, analyzed, and managed in accordance with NRC, State, and

other Federal requirements.

* Ai; aplNroved Deeomisonn Plan for- ultimate NRC releas ofthe site f4r unriestricted use and

licnseterintio wil e esalished and implemiented.

5.2.4 Water Resources (Revised 1st paragraph resulting in 2 paragraphs.)

Mitigation measures will be in place to minimize potential impact on water resources during

preconstruction licensi-ng and general construction-, oper-ation:;, and de.ommissioning of the I1FP

Ffacility. As discussed in ER Section 4.4.7, "Control of Impacts to Water Quality," there is little impact

on any groundwater or surface water resources. These mitigation measures also prevent soil

contamination. These include employing BMPs and the control of hazardous materials and fuels. In

addition, the following controls are also implemented:

* Construction equipment will be in good repair without visible leaks of oil, greases, or hydraulic

fluids.

* Control of spills during construction will be in conformance with the Spill Prevention Control and

Countermeasures Plan procedures.

* Use of BMPs will assure storm-water runoff related to these activities will not release runoff into

nearby sensitive areas.

* BMPs will also be used for dust control associated with excavation and fill operations during

construction. Water conservation will be considered when deciding how often dust suppression

sprays will be applied.

• Silt fencing and sediment traps will be used.

* Stone construction pads will be placed at entrance/exit if unpaved construction access adjoins a

state road.

* Basins are arranged to provide for the prompt, systematic sampling of runoff in the event of any

special needs.

Environmental Report Request for Additional Information (RAI 23) Page 154
Official Responses to Environmental Report RAls

* Water quality impacts will be controlled during construction phaee&gges-by compliance with

the National Pollution Discharge Elimination System General Permit requirements and by

applying BMPs as detailed in the Stormwater Pollution Prevention Plan.

* A Spill Prevention Control and Countermeasure Plan will be implemented for the facility to

identify potential spill substances, sources and responsibilities.

MIitigation measures will be in place to minimize potential impact on water resources during operations of

the IIFP facility. These include:

* All above ground petroleum storage tanks will be bermed.

" Conduct routine visual inspections and preventive maintenance.

• Any hazardous materials will be handled by approved methods and shipped off site to approved

disposal sites. Sanitary wastes generated during site construction will be handled by portable

systems; until such time that the plant sanitary waste treatment facility is available for use.

* The facilities liquid effluent collection and treatment system provides a means to control liquid

waste with the plant including the collection, evaporation, and minimization of liquid wastes for

disposal.

" Liquid effluent concentration releases to the evaporative tank will be below 10 CFR 20

uncontrolled release limits.

* Control of surface water runoff will be required for activities as covered by the NPDES General

Permit. As a result, no impacts are expected to surface or groundwater bodies.

* Stormwater and effluent sampling wo-+14-will be conducted as necessary by the NPDES permit to

protect surface water quality. In addition, site-wide groundwater levels wotld-will continue to be

monitored routinely, and the groundwater monitoring-well and pumping-well networks we+44

will continue to be analyzed to confirm that the changes in groundwater levels associated with the

PfIpIFsed-kea441117P Facility are minimal.

5.2.5 Ecological Resources (Revised section.)

Mitigation measures will be in place to minimize the potential impact on ecological resources during

construction activities7 opei'ations, and deconmiis,4ion4tg-of the facility. These include:

* Use of BMPs recommended by the State of New Mexico or various federal agencies;

* No herbicides will be used during construction.; but may be us. d in l4iited amounts, acordi..4

to government regulation.; and mnanufactufrr'ms; istru-tions to ceont'rol unwanted noxious

.. getatiOn during oper'ation of the faoi4ity;

* Minimize the construction footprint to the extent possible; and

" The uise of retention (evaporation) basins, to avoid direct dischar-ge of stormiwater r~unoffffrom

process areas to any water-s of the Uinited States; and

" Implement site stabilization practices to reduce the potential for erosion and deposition of

sediment. After construction is complete, the site will be stabilized with native grass species,

pavement, and crushed stone to control erosion. Ditches, unless excavated in rock, will be lined

with riprap, vegetation, or other suitable material as dictated by water velocity to control erosion.

Furthermore, any eroded areas that may develop will be repaired and stabilized.

Mitigation measures will be in place to minimize the potential impact on ecological resources during

operations of the facility. The measures and other proposed practices to minimize impact to wildlife

incluide the lfollowinrg:

Environmental Report Request for Additional Information (RAI 23) Page 155
Official Responses to Environmental Report RAIs

* The use of retention (evaporation) basins to avoid direct discharge of stormwater runoff from

process areas to any waters of the United States;

1 lerbicides may be used in limited amounts according to government regulations and

manufacturer's instructions to control unwanted noxious vegetation during operation of the

facility. Proposed pr'actice; t', minimhize impact to wildlife include:

" Placement of a raptor perch in an unused open area;

* Install bird feeders at the visitor's center;

" Placement of quail feeders in the unused open areas away from buildings;

• The management of unused open areas, including areas of native grasses and shrubs for the

benefit of wildlife;

" Use native plant species (i.e., low-water consuming plants) to vegetate disturbed areas and to

enhance wildlife habitat;

" Use netting, or other suitable material, to ensure migratory birds are excluded from retention

(evaporation) basins that do not meet New Mexico Water Quality Control Commission surface

water standards for wildlife usage;

• Use animal friendly fencing within the Site so that wildlife cannot be injured or entangled;

* Minimize the amount of open trenches at any given time; and

* Treat or recycle of process air-scrubbers system liquids.

In addition to proposed wildlife management practices above, IIFP will consider recommendations from

appropriate state and federal agencies, including the United States Fish and Wildlife Service and the New

Mexico Department of Game and Fish.

5.2.13 Waste Management (Revised 3 rd paragraph only.)

IIFP will implement a spill control program for accidental oil spills. A Spill Prevention Control and

Countermeasure (SPCC) Plan will be prepared prior to the start of apefatieo-construction of the facility or

prior to the storage of oil on site in excess of de minimis quantities and will contain the following

information:

* Identification of potential significant sources of spills and a prediction of the direction and

quantity of flow that would result from a spill from~each source.

" Identification of the use of containment-type or diversionary structures such as dikes, berms,

culverts, booms, sumps, and diversion basins used at the facility to prevent discharged oil from

reaching the surrounding environment.

* Procedures for inspection of potential sources of spills and spill containment/diversion structures.

" Assigned responsibilities for implementing the plan, inspections, and reporting.

* As part of the SPCC Plan, other measures will include control of drainage of rain water from dike

areas, containment of oil and diesel fuel in bulk storage tanks, above-ground tank integrity

testing, and oil and diesel fuel transfer operational safeguards.

Environmental Report Request for Additional Information (RAI 23) Page 156
Official Responses to Environmental Report RAIs

RAI 24

Verify the distance to the nearest residence from the proposed 1FP facility.

The ER (IIFP, 2009a) in Section 1.3.3, "The Proposed Site, "states that the nearest residence is 8.5 km

(5.3 mi) from the northern boundary of the site. Local maps appear to indicate the nearest residence

could be approximately 1 mifrom the northwest corner of the site (see attached map). Accurate

information about the distance to residences is needed to fully assess potential impacts to those

residences.

RESPONSE:

The nearest residence is indeed closer than that indicated in Rev. A of the ER. The nearest neighbor is 1.6

miles west northwest of the site. The various sections of the ER will be revised to reflect the correct

distance of the nearest residence. Those sections showing exposure data to the nearest resident were also

revised to reflect the corrected distance.

Environmental Report Documentation Impact: Remove Chapter 4 of the ER, Revision A in its

entirety and replace with rewrite of Chapter 4 provided as a separate attachment. Exposure data to the

nearest resident are shown in Section 4.12.2.2.2, Public and Occupational Exposure Impacts." Various

sections of the ER will be revised to show that the nearest neighbor at 1.6 miles from the site and the

impact from that distance as shown below:

1.3.3 The Proposed Site (Revised 8th paragraph)

Surrounding property consists of vacant land and the industrial Xcel Energy Cunningham Station on the

west boundary (NM 483) of the IIFP proposed property line, Xcel Energy Maddox Station on the east

southeast side, aid-Colorado Energy I Iobbs Generatinl Station on the east northeast of the site and DCP

Midstream - Linam Ranch Plant is southeast of the site. Cattle grazing, on nearby sites, occurs throughout

the year. Land around the proposed site has been mostly developed by the oil and gas industry. The

nearest residence is situated at the west northwestea4 of the Site approximately 8-=52.6 km (54,-1.6 mi)

from the northern boundary. There are no known public recreational areas within 8 km (5 mi) of the Site.

3.1.2 Description of Off-site Areas (Revised 5th paragraph.)

The nearest known residence to IIFP is situated west northwesteast of the site 2.6&.84' km (1.64- mi) from

the northern boundary fence. There are no known public recreational areas within 8 km (5 mi) of the site.

Transportation corridors are discussed in ER Section 3.2, "Transportation." A discussion of schools and

hospitals is included in ER Section 3.10, "Socioeconomic."

3.7.2 Community Distribution (Revised 1st paragraph)

The proposed IIFP 259-ha 640-acfe) Section is located in a sparely populated area of southeastern New

Mexico that is used primarily for intermittent cattle grazing. The nearest commercial noise receptors are

Xcel Energy Cunningham Gerai4ig Station on the west property line of the site, the Xcel Energy

Maddox G....t.. Station on the east southeast side, and the Colorado Energy Hobbs Generating

Station on the east northeast of the site. The nearest known residential noise receptor is approximately 8-

2.6 km (5-4•1.6 mi) west northwesteast of the site.

Environmental Report Request for Additional Information (RAI 24) Page 157
Official Responses to Environmental Report RAls

4.7.1.1 Construction Impacts (revised 5 th paragraph)

Due to the temporary and episodic nature of construction and because of the significant distance to the

nearest residence approximately 2.68-5 km (1.65..-3 mi) to the west northwestnetheast of the site, and

since construction activities largely will be during weekday daylight hours, actual construction noise at

the site is not expected have a significant effect on the closest resident. The noise level is not expected to

exceed 50 dBA at the nearest residence. Vehicle traffic will be the most noticeable cause of construction

noise. There are no sensitiv. r .............. i.als, Ho.ols. . residences) is a cafd located close to the

intersection of U.S. 62/180 and NM 483 at Arkansas c-n.Junction. Personnel at the caf6 wh4 will have

been the most aware of the increase in noise firom the traffic or from the construction not expected to

exceed 48 dBAdue to p...imitl t.. t,, sro.. Noise impacts from preconstruction or general construction

are anticipated to be SMALL.

4.7.1.2 Operational Impacts (Revised 3 d paragraph.)

Since the nearest residence is located west northwesteast of the IIFP Ssite at a distance of approximately

2.6%f km (1_.64.4 mi), the resultant sound level exposure will be below the perception of the human ear.

This is because a noise source over such a g!reat distance will be dispersed in air and absorbed by natural

landscape, vegetation, and buildings to the point of being masked by background ambient noise at the

receptor. Noise impacts from the Phase I or Phase 2 operation of the IIFP facility are anticipated to be

SMALL.

4.7.3.2 Operations (add new section and new 2 nd paragraph)

Since the nearest residence is located west northwest of the IIFP site at a distance of approximatelv 2.6

km (1.6 mi). the resultant sound level exposure will be below the perception of the human ear. This is

because a noise source over such a distance will be dispersed in air and absorbed by natural landscape,

vegetation, and buildings to the point of being masked by background ambient noise at the receptor.

Noise impacts from the integrated Phase 2 operation of the IIFP Facility are anticipated to be SMAIL...

4.7.4.14.7.6.1 Impacts to the Community (Revised 2nd paragraph.)

Potential impacts to local schools, churches, hospitals, and residences are not expected to be significant,

as supported by the information presented in ER Sections 4.7.1. 4.7.2 and 4.7.3. The nearest raneh

residence is located west northeastwest of the site at a distance of approximately S-42.6 km (-4-1.6 mi)

and due to its proximity is not expected to perceive an increase in noise levels due to construction or

operations. The nearest school, hospital, church and other sensitive noise receptors are beyond this

distance, thereby allowing the noise to dissipate and be absorbed, helping decrease the sound levels even

further. Xcel Energy Cunningham Station is located on NM 483 and Colorado Energy Station is located

east northeast of the site. Xcel Energy Maddox Station is located east of the facility. DCP Midstream gas

processing facility is located southeast of the facility. At the Arkansas Junction. tThere are no-two homes

and a caf6 located near-.2.9 km (1 .8 mi) past the con1stuction traffic off 1'N 1 .X,3 nor at the intersection of

U.S. 62/! 80 and N M 4183 flom the site to be affected by the vehicle noise; but due to existing heavy

tractor trailer vehicle traffic, the change will be minimal. No schools or hospitals are located at this

intersection.

Environmental Report Request for Additional Information (RAI 24) Page 158
Official Responses to Environmental Report RAIs

4.9.4.4.9.8.2 Structure Obstructing Existing Views (Revised section.)

The tallest proposed on-site building is projected to be approximately 21.3 m (70 ft). However, relatively

small-diameter emission stacks will be approximately 30.5 m (100 ft) tall. Due to the relative flatness of

the site and vicinity, the structures will be observable from U.S. 62/180 and NM 483 and from the nearest

neighbor at approximately 2,.6" km (1.644 mi) from the site. The IIFP buildings will partially obstruct

views of existing landscape. However, considering that there are no high quality viewing areas (see ER

Section 3.9.7, "High Quality View Areas") and the many existing, manmade structures (pump jacks, high

power lines, industrial buildings, above-ground tanks) near the IIFP Ffacility, the obstruction of existing

views due to proposed structures will not degrade current conditions. (Refer to ER Figures in Section

3.9.2.)

4.12.2.2 Site Operations of the I IFP Facility (text moved with new Section heading, revised paragraph

7 of this new section)

Discharges of gaseous effluent from the scrubbing systems from the DUF4 and FEP processes, and the

dust collector scrubbers are from the middle of the 16.2-ha. 40-acfej Site. Airborne concentrations of

uranium present in gaseous effluent continually decrease with distance from the release point. Therefore,

the greatest off-site radiological impacts are expected at or near the site boundaries. The nearest known

resident has been identified at a distance of approximately 2.69,.4 km (I.65 mi) northeast west northwest

of the site. The nearest businesses include Colorado Energy Hobbs Generating Station at a distance of

3.12g km (4-A-L.9 mi) ENE of the site, Xcel Energy Cunningham Station at a distance of 1.6 km (1.0 mi)

WSW-west of the site, and Xcel Energy Maddox Station is 3.54 km (2.2 mi) ESE of the site. Xcel Energy

Cunningham Station on the w•ct seetor. A natural gas processing station, DCP Midstream, is located 65.8

km (3.6 mi) southeast of the IIFP buildings. No other important receptor locations such as schools,

hospitals, etc., have been identified within an 8-km (5-mi) radius of the IIFP site (refer to ER Section

3.10). With respect to ingestion pathways, there is little in the way of food crops grown within an 8-km

(5-mi) radius due to semi-arid nature and minimal development of the local area for agriculture. Cattle

grazing across the open range has been observed in the vicinity of the site. The radiological impacts on

members of the public and the environment at these potential receptor locations are expected to be only

small fractions of the radiological impacts that have been estimated for the site boundary locations

because of the low concentrations in gaseous effluent and the high degree of dispersion that takes place as

the gaseous effluent is transported.

5.1.7 Noise (Revised section.)

The potential impacts related to noise generated during the preconstruction ,ieenshing and general

construction, operation, and decommissioning by the facility have been characterized in ER Section 4.7,

"Noise Impacts." SMALL impacts exist as related to the following activities:

* Traffic noise;

* Predicted noise levels at surrounding industrial facilities; and

* Impacts to sensitive receptors (i.e., residences and wildlife).

Noise levels will increase during the construction pha-se stag•es and due to operation of the IIFP plant, but

not to a level that will cause significant impact to nearby sensitive receptors. The nearest residence is

approximately 2.68&4- km (1.65-4 mi) from the site. Mitigation measures associated with noise impacts are

listed in ER Section 5.2.7, "Noise."

Environmental Report Request for Additional Information (RAI 24) Page 159
Official Responses to Environmental Report RAIs

5.2.7 Noise (Revised 1st paragraph.)

Noise from construction activities will have the highest sounds levels, but the nearest home is located

approximately 2.6"- km (1.64-.3 mi) from the site. Due to this distance, those residents will not perceive

an increase in noise levels. There are no sensitive receptors (hospitals-or schools, residences) located near

to the intersection of U.S. 62/180 and NM 483 at Arkansas Junction who would have been the most aware

of the increase in traffic due to proximity to the source. However for mitigation measures, heavy truck

and earth moving equipment usage will be restricted after twilight and during early morning hours. Noise

suppression systems on construction vehicles will be kept in proper operation.

8.3.7 Noise Impacts (Revised 2 nd, 5 th, and 6 th paragraph.)

The predicted noise level ranges from the construction of the IIFP Ffacility fall within acceptable sound

pressure levels as determined by the U.S. Department of Housing and Urban Development. U.S. 62/180 is

a main trucking thoroughfare for local industry on the south boundary and that there are no other sensitive

receptors at the JIFP south boundary. In addition, noise levels in the predicted ranges at the south

boundary and the west boundary would only be for a short duration and only during construction of the

facilities. Xcel Energy Cunningham G eati•-•iStation , is located on NM 483 on the western boundary of

the IIFP Ssite, while Xcel Energy Maddox Generatkion Station and Colorado Energy Hlobbs Generatilgo.n

Station are located east and cast northeast of the site, respectively. The DCP Midstream Linam Ranch

Plant gas facility is located on U.S. 62/180 southeast of the IIFP Ssite. Due to the temporary and episodic

nature of construction, and because of the significant distance to the nearest residence approximately

;2.68- km (1.6-. mi) to the west northwesteast of the site, and since construction activities largely would

be during weekday daylight hours, actual construction noise at the site is not expected to have a

significant effect on nearby residents.

Since the nearest known residence is located west northwesteast of the IIFP Ssite at a distance of

approximately 2.685 km (j.6L5- mi), the resultant sound level exposure will be below the perception of

the human ear. This is because a noise source over such a great distance will be dispersed in air and

absorbed by natural landscape, vegetation, and buildings to the point of being masked by background

ambient noise at the receptor.

For operational noise exposure to the nearest residence located west northwestea-s of the IIFP Ssite at a

distance of approximately 2.68- km (1.63- mi), the resultant sound level exposure w Id-will generally

be below the perception of the human ear. Certain phases of operation, weather, time of day, wind

direction, traffic patterns, season, and the location of the receptor will all impact perceived operational

noise levels. Although the noise from the plant-thcility and the additional traffic would generally be

noticeable, the operational noise is not expected to have a significant impact on nearby traffic or the

surrounding industries. Thus, noise impacts from the operation of the IIFP Efacility are SMALL.

Environmental Report Request for Additional Information (RAI 24) Page 160
Supplemental Information

Official Responses to Environmental Report RAls

NON-RADIOLOGICAL EMISSIONS AND IMPACTS FOR PHASE 1 AND PHASE 2

CONSTRUCTION ACTIVITIES

1.0 Introduction

The International Isotopes Fluorine Products (IIFP) project seeks to construct and operate a facility that

will (1) convert depleted uranium hexafluoride (DUF6) to uranium oxide and (2) produce marketable

fluorine chemicals. IIFP must obtain a license from the Nuclear Regulatory Commission (NRC) prior to

the start of construction. The license application to the NRC includes an Environmental Report (ER). This

calculation is prepared in support of the ER as part of the license application to the NRC.

The IIFP Project will be implemented in two separate phases. Phase 1 will include initial site preparation

activities, road and infrastructure construction, construction of support facilities, and construction of

several process buildings. Phase 2, which will include the construction of additional process buildings,

will be performed after Phase 1 is completed and has already begun operations.

2.0 Purpose

The purpose of this report is to quantify the non-radiological emissions attributable to IIFP construction

activities and to evaluate the impacts for comparison with regulatory standards.

3.0 Pollutants Generated By Construction

Site preparation and construction activities would generate criteria pollutants, hazardous air pollutants

(HAPs), and volatile organic compounds (VOCs). The criteria pollutants are carbon monoxide (CO),

nitrogen dioxide (NO 2), lead (Pb), ozone (03), particulate matter less than 10 microns in diameter (PM1 0),

particulate matter less than 2.5 microns in diameter (PM 2 5), and sulfur dioxide (SO 2) (40 CFR 40). HAPs

are compounds that are believed to cause serious adverse health effects or adverse environmental effects.

There are 188 pollutants designated as HAPs by the EPA. HAPs are generated by industrial processes and

fossil fuel combustion. VOCs are organic compounds of carbon that participate in atmospheric

photochemical reactions (carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or

carbonates, and ammonium carbonate are excluded). VOCs are primarily generated by solvents, industrial

processes, and fossil fuel combustion.

4.0 Regulations

The Environmental Protection Agency has established National Ambient Air Quality Standard (NAAQS)

for criteria pollutants. The NAAQS do not limit release quantities, but instead establish maximum

allowable pollutant concentrations in the ambient air. Ambient air pollutant concentrations are generally

measured in units of parts per million (ppm) or micrograms per cubic meter (Ptg/m 3). Relevant NAAQS

are illustrated below in Table 4.1 (40 CFR 50). The NAAQS for lead and ozone are omitted because these

pollutants will not be generated by site preparation or construction activities.

HAPs are regulated by the EPA under 40 CFR 61, National Emission Standards for Hazardous Air

Pollutants. Unlike the criteria pollutants, there are no ambient air concentration limits for HAPs. Instead,

HAPs are regulated through source controls. VOC emission levels are regulated by air permit programs.

Environmental Report Request for Additional Information (Supplemental Information) Page 161
Supplemental Information

Official Responses to Environmental Report RAIs

5.0 Emission Sources

Pollutants attributable to construction would include (1) tailpipe emissions (also known as combustion

emissions) from operation of diesel-fired equipment (2) fugitive dust emissions (PM 2 5 and PM 10) from

unpaved surfaces generated by wind erosion, soil or powder transfers, and the travel of heavy

Table 4.1 NAAQS

Criteria Maximum

Pollutant Average Concentration Conditions Pollutant_ (pg/mi3

)

1-hr 10,000 Not to be exceeded more than once per year 8-hr 40,000 Not to be exceeded more than once per year

NO2 1-hr 188 NA

Annual 100 Annual arithmetic average.

To attain this standard, the 3-year average of the 98th

24-hr 35 percentile of 24-hour concentrations at each populationoriented monitor within an area must not exceed 35 pg/m3

PM 2 .5 (effective December 17, 2006).

To attain this standard, the 3-year average of the weighted

Annual 15 annual mean PM 2.5 concentrations from single or multiple

community-oriented monitors must not exceed 15.0

_ _g/m

3

0 24-hr 150 Not to be exceeded more than once per year on average

over 3 years

1 -hr 200 NA

3-hr 1,300 Not to be exceeded more than once per year

SO 2 24-hr 365 Not to be exceeded more than once per year

To attain this standard, the 3-year average of the 99th

Annual 80 percentile of the daily maximum 1-hour average at each

monitor within an area must not exceed 0.075 ppm

Source: 40 CFR 50

construction equipment and (3) fugitive HAP emissions due to evaporative losses from diesel fuel tanks

and diesel fuel transfers. Separate calculations are applied to estimate these emissions.

6.0 Construction Area

Unlike an emissions stack, which is considered a point emission source, construction emissions will

originate as an area source. The dimensions of the 40 acre site are roughly 358 meters by 457 meters.

Area emissions for Phase 1 construction activities are based on 60 percent of the 40 acre area. Area

emissions for Phase 2 are based on 60 percent of a I acre area.

7.0 Tailpipe Emissions

EPA Report NR-009d describes pollutant emission factors for calculation of emissions attributable to

operation of non-road compression engine equipment (i.e., diesel-fired construction equipment). Emission

factors (grams of pollutant per horsepower-hour) are primarily a function equipment horsepower, load

factor, and age. Report NR-009d also identifies equipment fuel consumption factors in units of "grams of

Environmental Report Request for Additional Information (Supplemental Information) Page 162
Supplemental Information

Official Responses to Environmental Report RAIs

fuel burned per horsepower-hour." Small equipment tends to have larger emission factors than large

equipment (EPA, 2010).

To calculate the peak annual tailpipe emissions for construction, a list of site preparation and construction

equipment was identified. For each month of the year, the quantity and average monthly hours of

operation for each equipment item was estimated. Based on the equipment horsepower, load factor,

Environmental Report Request for Additional Information (Supplemental Information) Page 163
Supplemental Information

Official Responses to Environmental Report RAIs

equipment quantities, hours of operation, and pollutant emission factors, the total monthly emissions for

each pollutant and each equipment item are calculated by Equation 01.

Tailpipe Emissions, (Emissions Factor, g/hp-hr) x (horsepower, hp) [EQN_01]

g/s/m2 = x (load factor) x (equipment quantity, each) x

(hours operated, hrs)

8.0 Fugitive Dust Emissions

Fugitive dust is solid particulate matter emitted from any source other than a stack or chimney. Fugitive

dust particulates occur over a wide range of particulate sizes. The term total suspended particulate (TSP)

describes the entire range of fugitive particulate emissions (all particle sizes). For initial site preparation

activities, EPA AP-42, Section 13.2.3.3, cites a TSP emission factor of 1.2 tons/acre/month (EPA 1995).

After site preparation activities have been completed, it is assumed that fugitive TSP emissions would

drop to 0.3 tons/acre/month. On average, PM 10 and PM 2 5 represent 15 percent and 7.5 percent of TSP

fugitive dust emissions (MRI 2006). For the purpose of evaluation, fugitive dust emissions are assumed to

occur over 60 percent of the total construction site at any given time.

9.0 Fugitive Hap Emissions

Fugitive HAP emissions are generated by evaporative losses from diesel storage tanks and diesel fuel

transfer operations. The total annual HAP fugitive emissions are calculated as a product of the diesel

consumption factors from AP-42, and an HAP fugitive emission rate of 0.000028 lb fugitive HAPs per lb

diesel (SBAP 2010).

10.0 Combined Emissions

Annual pollutant emission totals (tailpipe emissions + fugitive dust emissions + fugitive HAP emissions)

are summed and reported in the Environmental Report. Annual pollutant emission totals form the basis

for calculation of the average emission rate for input to SCREEN3. Similarly, monthly maximum criteria

pollutant emissions are summed, and the maximum sum is selected to calculate time-averaged area

emission rates for input to SCREEN3 (this is described further in Section 12).

11.0 Site-Specific Meteorology

Representative regional meteorological data was applied to determine regional air-quality impacts

attributable to IIFP construction activities. The data, provided by the State of New Mexico, includes 9408

hourly records that indicate the atmospheric stability and the direction speed of the wind. Because

construction activities would occur only in daylight hours, hourly records that occur at night were

ignored. The stability class / wind speed combinations illustrated in Table 11-1 represent more than 97

percent of all day time records for the southeastern New Mexico region.

12.0 Screen3

The SCREEN3 computer program is applied to estimate maximum regional criteria pollutant

concentrations attributable to area source construction emissions (i.e., air quality impacts). Air quality

impacts are not evaluated for HAPs or VOCs because there are no regulatory metrics for comparison

(HAP and VOC emissions are regulated by source controls and permit requirements). SCREEN3

calculates the one-hour average concentration for a range of downwind distances. Key inputs include the

pollutant emission rate (g/s/m3), release height (m), receptor height (m), stability class, and wind speed

(m/s). All construction emissions are conservatively assumed to originate at ground level.

Environmental Report Request for Additional Information (Supplemental Information) Page 164
Supplemental Information

Official Responses to Environmental Report RAIs

Environmental Report Request for Additional Information (Supplemental Information) Page 165
Supplemental Information

Official Responses to Environmental Report RAts

Table 11-1 Regional Daytime Atmospheric Conditions and Occurrence Frequency

Stability Class and Wind Speed Daytime Occurrence Freqtuency .

D02 2.95%

D03 9.00%

D04 9.50%

D05 12.15%

D06 11.78%

D07 7.25%

D08 4.06%

D09 2.37%

D1O 1.24%

DI 0.62%

E01 0.45%

E02 2.63%

E03 5.86%

E04 13.11%

E05 7.04%

F01 1.95%

F02 4.73%

F03 1.28%

Source: NMED 1998

For ground level releases, SCREEN3 results are scalable. Therefore, SCREEN3 is applied to determine

downwind pollutant concentrations based on a unit release rate of I g/s/m 2

. SCREEN3 results are

obtained for each of the stability class and wind speed combinations shown in Table 13-1. SCREEN3

results for each receptor location are then frequency weighted and the average is selected to represent the

concentration.

Table 13-1 SCREEN3 Scale Factors

Time verage ... M. ultiply SCREEN3 Result By

1-hr 1.00

3-hr 0.90

8-hr 0.70

24-hr 0.40

8,760-hr 0.08

Source: CDPHE 2005

SCREEN3 is designed to estimate impacts for steady releases. Because construction activities are

performed only in day time hours and for no more than 208 hours per month, to estimate an average

release rate for extended time spans, the area emission rates must be adjusted. One-hour, 3-hour, and 8-

hour impacts do not need to be adjusted, because these time spans are smaller than the standard 10 hour

construction day. The 24-hour and 8,760-hour (annual) impacts, however, must be adjusted to account for

intermittent pollutant releases. Equations to determine area release rates as input to SCREEN3 are listed

below:

Environmental Report Request for Additional Information (Supplemental Information) Page 166
Supplemental Information

Official Responses to Environmental Report RAls

Avg 1-hr Emission Rate, g/s/m2 = (Monthly Emissions, lb) / (Construction Work Time, [EQN_02]

hrs)

Avg 3-hr Emission Rate, g/s/m2 = (Monthly Emissions, lb) / (Construction Work Time, [EQN_03]

hrs)

Avg 8-hr Emission Rate, g/s/m2 = (Monthly Emissions, lb) / (Construction Work Time, [EQN_04]

hrs)

Avg 24-hr Emission Rate, g/s/m2 = (10 / 24) x (Monthly Emissions, lb) / (Construction [EQN_05]

Work Time, hrs)

Avg 8,760-hr Emission Rate, g/s/m2 = (Annual Emissions, lb) / (8,760 hrs) [EQN_06]

13.0 Impact Calculations

Frequency-weighted results from SCREEN3 are scaled to determine 1-hour impacts. For example, to

estimate the impact for a 1-hr concentration, SCREEN3 results are scaled based on the average 1-hr

emission rates as determined by EQN_02. Similarly, to estimate the impacts based on 3-hr, 8-hr, 24-hr,

and 8,760-hr average area release rates, SCREEN3 results are scaled based on the average emission rates

as determined by EQN_03, EQN_04, EQN_05, EQN_06, respectively. It is important to remember that

SCREEN3 will estimate only the I-hr average concentration - it does not reveal the average

concentration for other time spans, such as 3-hr, 8-hr, 24-hr, and 8,760-hr. However, EPA has identified a

set of scale factors that may be applied to estimate the 3-hr, 8-hr, 24-hr, and 8760-hr average

concentrations based on the I-hr average concentration. Table 13-1 illustrates these scale factors.

Additionally, an example is provided below to illustrate this process. Emissions and impacts are

determined separately for Construction Phase 1 and Construction Phase 2.

Example: Assume the maximum monthly SO2 emissions are 62 pounds; the annual SO 2 emissions

are 511 pounds; construction occurs 208 hours per month; and the dimensions of the area with active

construction at any given time are 274 meters by 354 meters (96,996 square meters). Further assume

that based on the site-specific meteorology and a unit area release rate (1 g/s/m2), the frequencyweighted SCREEN3 result at 200 meters is 8.28E+05 PIg/m 3.There are four NAAQS for SO2 (I-hr, 3-

hr, 8-hr, and 8,760-hr). Calculations are illustrated below to determine the project impact for

comparison with each SO2 NAAQS.

1-hr impact

As shown in Table 13-1, for a I-hr impact, the SCREEN3 scale factor is 1.

Release Rate = { (62 lb) / (208 hr) / (96996 M2 ) } × (453.59 g/lb) / (3600 s/hr) = 3.87E-7 g/s/m2

1-hr average impact at 200 meters = (SF) x (SCREEN3 1-hr concentration) x (SO 2 1-hr Release Rate) /

(Unit Release Rate)

1-hr average impact at 200 meters = (1) x (8.28E+05 jig/m3

) x (3.87E-7 g/s/m 2) / (1 g/s/m2) = 0.32 jag/m 3

3-hr impact

As shown in Table 13-1, for a I-hr impact, the SCREEN3 scale factor is 0.9. The average release rate

over a three hour span is the same as the release rate for a one hour span.

Release Rate = { (62 lb) / (208 hr) / (96996 in2 ) } x (453.59 g/lb) / (3600 s/hr) = 3.87E-7 g/s/m 2

3-hr average impact at 200 meters = (SF) x (SCREEN3 1-hr concentration) X (SO 2 3-hr Release Rate) /

(Unit Release Rate)

Environmental Report Request for Additional Information (Supplemental Information) Page 167
Supplemental Information

Official Responses to Environmental Report RAls

3-hr average impact at 200 meters = (0.9) x (8.28E+05 jig/r 3

) x (3.87E-7 g/s/m2

) / (1 g/s/m2) 0.29

jig/m3

8-hr impact

As shown in Table 13-1, for a 1-hr impact, the SCREEN3 scale factor is 0.7. The average release rate

over an 8-hour span is the same as the release rate for a one hour span.

8-hr Release Rate = { (62 lb) / (208 hr) / (96,996 mi2 ) } x (453.59 g/lb) / (3600 s/hr) = 3.87E-7 g/s/m 2

8-hr average impact at 200 meters = (SF) x (SCREEN3 1-hr concentration) x (SO 2 8-hr Release Rate) /

(Unit Release Rate)

8-hr average impact at 200 meters = (0.7) x (8.28E+05 jig/m 3

) x (3.87E-7 g/s/m 2) / (1 g/s/m 2 ) = 0.22

jig/m3

8,760-hr impact

As shown in Table 13-1, for a 1-hr impact, the SCREEN3 scale factor is 0.08. The average release rate

over an 8,760 hour span is determined based on annual release total and 8,760 hours.

Release Rate = { (511 lb) / (8760 hr) / (96996 M2

) } x (453.59 g/lb) / (3600 s/hr) = 7.57E-08 g/s/m 2

8,760-hr average impact at 200 meters = (SF) x (SCREEN3 1-hr concentration) x (SO 2 Annual Release

Rate ) / (Unit Release Rate)

8,760-hr average impact at 200 meters = (0.08) x (8.28E+05 jig/m3

) x (7.57E-08 g/s/m 2

) / (1 g/s/m 2

) =

0.005 jig/m3

14.0 References

40 CFR 50 National Ambient Air Quality Standards

40 CFR 61 National Emission Standards for Hazardous Air Pollutants

Available online at http://www.cdphe.state.co.us/ap/sbap/sbapgasolineguidance.pdf

CDPHE 2005 Colorado Department of Health and Environment, SCREEN3 Stationary Source

Modeling Guidance.

EPA, 2010 EPA-420-R-10-0 18, NR-009d, Exhaust and Crankcase Emission Factors for Nonroad

Engine Modeling - Compression-Ignition. July. Available online at

http://www.epa.gov/oms/models/nonrdmdl/nonrdmdl20l0/420r 1001 8.pdf

MRI 2006 Background Document for Revisions to Fine Fraction Ratios Used for AP-42 Fugitive

Dust Emission Factors.

NMED 1998 Air Quality Permit 126M4 for the ARCO Permian Empire Abo Gasoline Plant, March.

SBAP 2010 Colorado Department of Public Health and Environment. A Guide to Air Regulations for

Gasoline and Diesel Fuel Dispenser Stations.

Environmental Report Request for Additional Information (Supplemental Information) Page 168