Environmental Impact 

Statement for the Proposed 

Fluorine Extraction Process 

and Depleted Uranium 

Deconversion Plant in Lea 

County, New Mexico

Draft Report for Comment

Office of Federal and State Materials and 

Environmental Management Programs

NUREG-2113
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Environmental Impact 

Statement for the Proposed 

Fluorine Extraction Process 

and Depleted Uranium 

Deconversion Plant in Lea 

County, New Mexico

Draft Report for Comment

Manuscript Completed: November 2011

Date Published: December 2011

Office of Federal and State Materials and

 Environmental Management Programs

NUREG-2113
 

Comments on Draft Report 

Any interested party may submit comments on this report for consideration by the NRC staff. 

Comments may be accompanied by additional relevant information or supporting data. Please 

specify the report number NUREG-2113, draft, in your comments, and send them by 

February 27, 2012, to the following address: 

Chief, Rules, Announcements and Directives Branch 

Division of Administrative Services 

U.S. Nuclear Regulatory Commission 

Mail Stop TWB-05-B01M 

Washington, D.C. 20555-0001 

Electronic comments may be submitted to the NRC by email to INIS_EIS.Resource@nrc.gov 

For any questions about the material in this report please contact: 

Asimios Malliakos 

U.S. Nuclear Regulatory Commission 

Mail Stop T-8D30 

Washington, DC 20555-0001 

Telephone (301) 415-6458 

Email: asimios.malliakos@nrc.gov 

NUREG-2113 has been reproduced from the best available copy 

 
iii 

1 ABSTRACT 

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

3 Isotopes, Inc., has submitted a license application to the U.S. Nuclear Regulatory Commission 

4 (NRC) to construct, operate, and decommission Phase 1 of a fluorine extraction and depleted 

5 uranium deconversion facility in Lea County, New Mexico. The proposed facility would provide 

6 services to the uranium enrichment industry, which makes fuel for nuclear power reactors. The 

7 IIFP facility would deconvert depleted uranium hexafluoride (DUF6) into fluoride products for 

8 commercial resale, and depleted uranium oxides for disposal. The license application for 

9 Phase 1 requests NRC to license the possession of up to 750,000 kilograms (827 tons) of 

10 depleted uranium under Title 10 “Energy” of the U.S. Code of Federal Regulations (10 CFR) 

11 Part 40, “Domestic Licensing of Source Material” in accordance with the Atomic Energy Act of 

12 1954. 

13 This draft Environmental Impact Statement (EIS) was prepared in compliance with the National 

14 Environmental Policy Act (NEPA) and the NRC regulations for implementing NEPA 

15 (10 CFR 51). This draft EIS evaluates the potential environmental impacts of the proposed 

16 action, which is to construct, operate, and decommission Phase 1 of the fluorine extraction and 

17 depleted uranium deconversion facility, and its reasonable alternatives, and describes IIFP’s 

18 monitoring program and proposed mitigation measures. 

19 Paperwork Reduction Act Statement 

20 This NUREG contains and references information collection requirements that are subject to the 

21 Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collection 

22 requirements were approved by the Office of Management and Budget, approval numbers 

23 3150-0014, 3150-0026, 3150-0021, 3150-0135, 3150-0009, 3150-0008, 3150-0002, and 3150-

24 0123. 

25 Public Protection Notification 

26 The NRC may not conduct or sponsor, and a person is not required to respond to, a request for 

27 information or an information collection requirement unless the requesting document displays a 

28 currently valid OMB control number. 

 v 

TABLE OF CONTENTS 

1 Section Page

2 

3 ABSTRACT ........................................................................................................................ iii 

4 LIST OF TABLES ............................................................................................................... xii 

5 LIST OF FIGURES ............................................................................................................. xvi 

6 EXECUTIVE SUMMARY .................................................................................................... xvii 

7 ACRONYMS AND ABBREVIATIONS ............................................................................... xxv 

8 1.0 INTRODUCTION ..................................................................................................... 1-1 

9 1.1 Background ............................................................................................................. 1-1 

10 1.2 Proposed Action ...................................................................................................... 1-2

11 1.3 Purpose and Need for the Proposed Action ............................................................ 1-3 

12 1.4 Scope of this Environmental Analysis ..................................................................... 1-4 

13 1.4.1 Scoping Process and Public Participation Activities ................................. 1-5 

14 1.4.2 Issues Studied in Detail ............................................................................ 1-6 

15 1.4.3 Issues Beyond the Scope of the EIS ........................................................ 1-7 

16 1.5 Applicable Statutory and Regulatory Requirements ............................................... 1-7 

17 1.5.1 State of New Mexico Laws and Regulations ............................................ 1-7 

18 1.5.2 Lea County and Local Laws and Regulations .......................................... 1-11 

19 1.5.3 Permit and Approval Status ...................................................................... 1-12 

20 1.5.3.1 Permits, Licenses, Authorizations, Approvals, and 

21 Consultations Required for Preconstruction and Construction . 1-12 

22 1.5.3.2 Permits, Authorizations, Approvals and Consultations 

23 Required for Operations ........................................................... 1-12 

24 1.6 Cooperating Agencies ............................................................................................. 1-12 

25 1.7 National Historic Preservation Act of 1966 and the Endangered Species Act 

26 of 1973 Consultations ............................................................................................. 1-12 

27 1.7.1 National Historic Preservation Act of 1966 Section 106 Consultation ...... 1-12 

28 1.7.2 Endangered Species Act of 1973 Section 7 Consultation ........................ 1-18 

29 1.8 References .............................................................................................................. 1-19 

30 

31 2.0 ALTERNATIVES ..................................................................................................... 2-1 

32 2.1 Proposed Action ...................................................................................................... 2-1

33 2.1.1 Site Location and Description ................................................................... 2-2 

34 2.1.2 IIFP Deconversion Process ...................................................................... 2-2 

35 2.1.2.1 Deconversion of DUF6 to DUF4 ................................................ 2-2 

36 2.1.2.2 SiF4 Production ........................................................................ 2-6 

37 2.1.2.3 BF3 Production ......................................................................... 2-6 

38 2.1.3 Description of the Proposed Facility ......................................................... 2-6 

39 2.1.4 Preconstruction and Construction ............................................................ 2-11 

40 2.1.5 Utilities and Other Services ...................................................................... 2-12 

41 2.1.5.1 Electrical Power ........................................................................ 2-13 

42 2.1.5.2 Water ........................................................................................ 2-13 

43 2.1.5.3 Natural Gas .............................................................................. 2-13 

44 2.1.5.4 Internal Utilities ......................................................................... 2-13 
 vi 

TABLE OF CONTENTS (CONTINUED) 

1 Section Page

2 2.1.6 Facility Operations .................................................................................... 2-14 

3 2.1.6.1 Workforce ................................................................................. 2-14 

4 2.1.6.2 Feedstocks ............................................................................... 2-14 

5 2.1.6.3 Products ................................................................................... 2-14 

6 2.1.6.4 Waste Streams ......................................................................... 2-14 

7 2.1.6.5 Product and Byproduct Packaging and Shipping ..................... 2-22 

8 2.1.7 Decommissioning ..................................................................................... 2-23 

9 2.1.8 Depleted Uranium Disposition Options ..................................................... 2-24 

10 2.2 Alternatives to the Proposed Action ........................................................................ 2-25 

11 2.2.1 No-Action Alternative ................................................................................ 2-25 

12 2.2.2 Alternatives Considered But Eliminated ................................................... 2-30 

13 2.2.2.1 Alternative Sites ....................................................................... 2-30 

14 2.2.2.2 Alternative Technologies .......................................................... 2-33 

15 2.2.2.3 Overseas Shipment of DUF6 for Deconversion ........................ 2-35 

16 2.2.2.4 Indefinite Storage of DUF6........................................................ 2-36 

17 2.2.2.5 Commercial Enrichment Plant Deconversion of DUF6 at 

18 Uranium Enrichment Facilities .................................................. 2-36 

19 2.3 Comparison of Predicted Environmental Impacts ................................................... 2-36 

20 2.4 Staff Recommendation Regarding the Proposed Action ......................................... 2-37 

21 2.5 References .............................................................................................................. 2-37 

22 

23 3.0 AFFECTED ENVIRONMENT ................................................................................. 3-1 

24 3.1 Site Location ........................................................................................................... 3-1 

25 3.2 Land Use ................................................................................................................. 3-1 

26 3.3 Historic and Cultural Resources .............................................................................. 3-4 

27 3.3.1 Prehistoric Occupation ............................................................................. 3-5 

28 3.3.2 Historic Indian Tribes ................................................................................ 3-5 

29 3.3.3 Historic Euro-American Exploration and Settlement ................................ 3-6 

30 3.3.4 Archaeological and Historic Resources at the Proposed IIFP Site ........... 3-7 

31 3.4 Visual Resources .................................................................................................... 3-8 

32 3.5 Climatology, Meteorology, and Air Quality .............................................................. 3-9 

33 3.5.1 Climatology ............................................................................................... 3-9 

34 3.5.2 Greenhouse Gases .................................................................................. 3-10 

35 3.5.2.1 Greenhouse Gas Emissions and Sinks in the United States ... 3-11 

36 3.5.2.2 Greenhouse Gas Emissions and Sinks in New Mexico ........... 3-12 

37 3.5.2.3 Projected Impacts from Construction and Operation of the 

38 Proposed IIFP Facility on Carbon Dioxide and Other 

39 Greenhouse Gases .................................................................. 3-14 

40 3.5.3 Meteorology .............................................................................................. 3-14 

41 3.5.4 Air Quality ................................................................................................. 3-17 

42 3.5.4.1 Regulatory Setting .................................................................... 3-17 

43 3.5.4.2 Existing Conditions ................................................................... 3-21 

 
 vii 

TABLE OF CONTENTS (CONTINUED) 

1 Section Page

2 3.6 Geology, Minerals, and Soil .................................................................................... 3-22 

3 3.6.1 Regional and Site Near-surface Geology ................................................. 3-22 

4 3.6.2 Seismicity and Volcanism ......................................................................... 3-23 

5 3.6.3 Minerals .................................................................................................... 3-23 

6 3.6.4 Soil............................................................................................................ 3-27 

7 3.7 Water Resources .................................................................................................... 3-31 

8 3.7.1 Groundwater ............................................................................................. 3-31 

9 3.7.1.1 Regional Groundwater ............................................................. 3-31 

10 3.7.1.2 Local Groundwater ................................................................... 3-32 

11 3.7.1.3 Groundwater Use ..................................................................... 3-43 

12 3.7.1.4 Groundwater Quality ................................................................ 3-43 

13 3.7.2 Surface Water ........................................................................................... 3-44 

14 3.8 Ecological Resources .............................................................................................. 3-49 

15 3.8.1 Ecosystems in the Proposed Facility ........................................................ 3-49 

16 3.8.1.1 Western Great Plains Shortgrass Prairie ................................. 3-49 

17 3.8.1.2 Apacherian-Chihuahuan Mesquite Upland Scrub .................... 3-49 

18 3.8.1.3 Wetland and Riparian Habitat .................................................. 3-51 

19 3.8.2 Vegetation of the Proposed Facility .......................................................... 3-51 

20 3.8.3 Wildlife that Could Occur on the Site and Proposed Facility .................... 3-51 

21 3.8.4 Wildlife Travel Corridors for Resident and Migratory Species .................. 3-55 

22 3.8.4.1 Migratory Species ..................................................................... 3-55 

23 3.8.4.2 Resident Species ..................................................................... 3-55 

24 3.8.5 Critical Habitats ........................................................................................ 3-55 

25 3.8.6 Wildlife Sanctuaries, Wildlife Management Areas, Refuges, 

26 and Preserves .......................................................................................... 3-55 

27 3.8.6.1 Green Meadow Lake ................................................................ 3-55 

28 3.8.6.2 Prairie Chicken Wildlife Area .................................................... 3-56 

29 3.8.6.3 Lesser Prairie-Chicken Habitat Preservation Area of Critical 

30 Environmental Concern and Proposed Lesser 

31 Prairie-Chicken Expansion Corridor ......................................... 3-56 

32 3.8.7 Special-Status Species ............................................................................. 3-56 

33 3.8.7.1 Federally Endangered Species ................................................ 3-59 

34 3.8.7.2 Federally Proposed Endangered Species ................................ 3-59 

35 3.8.7.3 Federal Candidate Species ...................................................... 3-60 

36 3.8.7.4 Federal Species of Concern ..................................................... 3-60 

37 3.8.7.5 New Mexico Threatened Species ............................................. 3-61 

38 3.9 Socioeconomics and Environmental Justice ........................................................... 3-61 

39 3.9.1 Demography ............................................................................................. 3-62 

40 3.9.1.1 Populations within the Socioeconomic ROI .............................. 3-62 

41 3.9.1.2 Environmental Justice: Minority and Low Income Populations 3-66 

42 3.9.2 Employment and Income .......................................................................... 3-73 

43 3.9.2.1 Employment ............................................................................. 3-73 

44 3.9.2.2 Income ...................................................................................... 3-73 
 viii 

TABLE OF CONTENTS (CONTINUED) 

1 Section Page

2 3.9.3 Taxes ........................................................................................................ 3-73 

3 3.9.3.1 Income Taxes ........................................................................... 3-73 

4 3.9.3.2 Sales Tax/Gross Receipts Tax ................................................. 3-76 

5 3.9.3.3 Property Taxes ......................................................................... 3-77 

6 3.9.4 Housing .................................................................................................... 3-78 

7 3.9.5 Public Utilities ........................................................................................... 3-79 

8 3.9.5.1 Major Public Water Suppliers ................................................... 3-79 

9 3.9.5.2 Major Public Wastewater Treatment Facilities ......................... 3-79 

10 3.9.6 Community Services ................................................................................. 3-80 

11 3.9.6.1 Education ................................................................................. 3-80 

12 3.9.6.2 Fire Protection .......................................................................... 3-80 

13 3.9.6.3 Law Enforcement ..................................................................... 3-81 

14 3.9.6.4 Hospitals and Physicians ......................................................... 3-81 

15 3.10 Traffic and Transportation ....................................................................................... 3-82 

16 3.10.1 Roadways ................................................................................................. 3-82 

17 3.10.2 Railroads .................................................................................................. 3-82 

18 3.10.3 Airports ..................................................................................................... 3-84 

19 3.11 Noise ....................................................................................................................... 3-84 

20 3.11.1 Noise Level Standards ............................................................................. 3-84 

21 3.11.2 Noise Receptors in the Vicinity of the Proposed Facility .......................... 3-85 

22 3.11.3 Noise in the Vicinity of the Proposed Facility ............................................ 3-85 

23 3.12 Public and Occupational Health .............................................................................. 3-85 

24 3.12.1 Background Radiological Exposure .......................................................... 3-85 

25 3.12.2 Background Chemical Characteristics ...................................................... 3-86 

26 3.13 References .............................................................................................................. 3-87 

27 

28 4.0 ENVIRONMENTAL IMPACTS ................................................................................ 4-1 

29 4.1 Proposed Action ...................................................................................................... 4-1

30 4.1.1 Environmental Impacts of Construction .................................................... 4-1 

31 4.1.1.1 Land Use .................................................................................. 4-1 

32 4.1.1.2 Historic and Cultural Resources ............................................... 4-2 

33 4.1.1.3 Visual Resources ..................................................................... 4-3 

34 4.1.1.4 Climatology, Meteorology, and Air Quality ............................... 4-3 

35 4.1.1.5 Geology, Minerals, and Soil ..................................................... 4-9 

36 4.1.1.6 Water Resources ...................................................................... 4-9 

37 4.1.1.7 Ecological Resources ............................................................... 4-12 

38 4.1.1.8 Socioeconomic Resources and Environmental Justice ............ 4-13 

39 4.1.1.9 Traffic and Transportation ........................................................ 4-20 

40 4.1.1.10 Noise ........................................................................................ 4-21 

41 4.1.1.11 Public and Occupational Health Impacts .................................. 4-21 

42 4.1.1.12 Waste Management ................................................................. 4-22 
 ix 

TABLE OF CONTENTS (CONTINUED) 

1 Section Page

2 4.1.2 Environmental Impacts of Operation ........................................................ 4-24 

3 4.1.2.1 Land Use .................................................................................. 4-24 

4 4.1.2.2 Historic and Cultural Resources ............................................... 4-25 

5 4.1.2.3 Visual Resources ..................................................................... 4-25 

6 4.1.2.4 Climate, Meteorology and Air Quality ....................................... 4-25 

7 4.1.2.5 Geology, Minerals, and Soil ..................................................... 4-30 

8 4.1.2.6 Water Resources ...................................................................... 4-31 

9 4.1.2.7 Ecological Resources ............................................................... 4-34 

10 4.1.2.8 Socioeconomic Resources and Environmental Justice ............ 4-34 

11 4.1.2.9 Traffic and Transportation ........................................................ 4-40 

12 4.1.2.10 Noise Impacts ........................................................................... 4-44 

13 4.1.2.11 Public and Occupational Health Impacts .................................. 4-44 

14 4.1.2.12 Waste Management Impacts .................................................... 4-53 

15 4.1.2.13 Impacts of Postulated Accidents .............................................. 4-57 

16 4.1.3 Decommissioning Impacts ........................................................................ 4-63 

17 4.2 Cumulative Impacts ................................................................................................. 4-67 

18 4.2.1 Past, Present, and Reasonably Foreseeable Future Actions ................... 4-68 

19 4.2.1.1 Proposed IIFP Facility Preconstruction Activities ..................... 4-68 

20 4.2.1.2 Proposed Phase 2 of the IIFP Facility ...................................... 4-69 

21 4.2.1.3 URENCO USA/LES Uranium Enrichment Facility .................... 4-70 

22 4.2.1.4 DOE Waste Isolation Pilot Plant (WIPP) .................................. 4-71 

23 4.2.1.5 Regional Energy Production Facilities ...................................... 4-71 

24 4.2.2 Cumulative Impacts to Environmental Resources .................................... 4-71 

25 4.2.2.1 Land Use .................................................................................. 4-71 

26 4.2.2.2 Historic and Cultural Resources ............................................... 4-72 

27 4.2.2.3 Visual Resources ..................................................................... 4-72 

28 4.2.2.4 Climatology/Meteorology/Air Quality ........................................ 4-72 

29 4.2.2.5 Geology, Minerals, and Soil ..................................................... 4-75 

30 4.2.2.6 Water Resources ...................................................................... 4-76 

31 4.2.2.7 Ecological Resources ............................................................... 4-77 

32 4.2.2.8 Socioeconomic Resources ....................................................... 4-78 

33 4.2.2.9 Traffic and Transportation ........................................................ 4-78 

34 4.2.2.10 Noise ........................................................................................ 4-80 

35 4.2.2.11 Public and Occupational Health ............................................... 4-80 

36 4.2.2.12 Waste Management ................................................................. 4-81 

37 4.3 No-Action Alternative .............................................................................................. 4-86 

38 4.4 References .............................................................................................................. 4-88 

39 

40 5.0 MITIGATION MEASURES AND COMMITMENTS ................................................. 5-1 

41 5.1 References .............................................................................................................. 5-10 

42 
 x 

TABLE OF CONTENTS (CONTINUED) 

1 Section Page

2 6.0 ENVIRONMENTAL MEASUREMENTS AND MONITORING PROGRAMS .......... 6-1 

3 6.1 Radiological Monitoring Program ............................................................................ 6-1 

4 6.1.1 Effluent Monitoring Program ..................................................................... 6-1 

5 6.1.1.1 Gaseous Effluent Monitoring .................................................... 6-3 

6 6.1.1.2 Liquid Effluent Monitoring ......................................................... 6-4 

7 6.1.2 Radiological Environmental Monitoring Program ..................................... 6-4 

8 6.1.2.1 Sampling Program .................................................................... 6-4 

9 6.1.2.2 Procedures ............................................................................... 6-6 

10 6.1.2.3 Reporting .................................................................................. 6-7 

11 6.2 Physicochemical Monitoring .................................................................................... 6-7 

12 6.2.1 Introduction ............................................................................................... 6-7 

13 6.2.2 Evaluation and Analysis of Samples ........................................................ 6-8 

14 6.2.3 Quality Assurance .................................................................................... 6-9 

15 6.2.4 Lower Limits of Detection ......................................................................... 6-9 

16 6.2.5 Effluent Monitoring .................................................................................... 6-9 

17 6.2.6 Stormwater Monitoring Program ............................................................... 6-10 

18 6.2.7 Environmental Monitoring ......................................................................... 6-11 

19 6.2.8 Meteorological Monitoring ........................................................................ 6-12 

20 6.3 Ecological Monitoring .............................................................................................. 6-12 

21 6.3.1 General Ecological Conditions of the Site ................................................ 6-12 

22 6.3.2 Monitoring Program Elements .................................................................. 6-13 

23 6.3.3 Observations and Sampling Design ......................................................... 6-13 

24 6.3.3.1 Vegetation ................................................................................ 6-13 

25 6.3.3.2 Birds ......................................................................................... 6-14 

26 6.3.3.3 Mammals .................................................................................. 6-14 

27 6.3.3.4 Reptiles and Amphibians .......................................................... 6-14 

28 6.4 References .............................................................................................................. 6-15 

29 

30 7.0 COST-BENEFIT ANALYSIS SUMMARY ............................................................... 7-1 

31 7.1 Costs and Benefits of the No-Action Alternative ..................................................... 7-1 

32 7.2 Costs of the Proposed Action .................................................................................. 7-2 

33 7.2.1 Construction Costs ................................................................................... 7-2 

34 7.2.1.1 Internal Costs ........................................................................... 7-2 

35 7.2.1.2 External Costs .......................................................................... 7-3 

36 7.2.2 Operations Costs ...................................................................................... 7-4 

37 7.2.2.1 Internal Costs ........................................................................... 7-4 

38 7.2.2.2 External Costs .......................................................................... 7-6 

39 7.3 Benefits of the Proposed Action .............................................................................. 7-7 

40 7.3.1 Construction ............................................................................................. 7-7 

41 7.3.2 Operations ................................................................................................ 7-8 

42 7.4 Evaluation Summary of the Proposed IIFP Facility ................................................. 7-9 

43 7.5 References .............................................................................................................. 7-10 
 xi 

TABLE OF CONTENTS (CONTINUED) 

1 Section Page

2 8.0 SUMMARY OF ENVIRONMENTAL CONSEQUENCES ........................................ 8-1 

3 8.1 Unavoidable Adverse Environmental Impacts ........................................................ 8-2 

4 8.2 Irreversible and Irretrievable Commitments of Resources ...................................... 8-3 

5 8.3 Relationship between Local Short-Term Uses of the Environment and the 

6 Maintenance and Enhancement of Long-Term Productivity ................................... 8-4 

7 8.4 References .............................................................................................................. 8-5 

8 

9 9.0 LIST OF PREPARERS ........................................................................................... 9-1 

10 9.1 U.S. Nuclear Regulatory Commission Contributors ................................................ 9-1 

11 9.2 Straughan Environmental and Tetra Tech Contributors .......................................... 9-2 

12 

13 10.0 GLOSSARY ............................................................................................................ 10-1 

14 

15 APPENDICES 

16 APPENDIX A SCOPING SUMMARY .................................................................. A-1 

17 APPENDIX B CONSULTATION/CORRESPONDENCE ..................................... B-1 

18 APPENDIX C AIR EMISSIONS .......................................................................... C-1 

19 APPENDIX D SOCIOECONOMIC INFORMATION ............................................ D-1 

20 APPENDIX E TRANSPORTATION OF RADIOACTIVE MATERIALS ................ E-1 
 xii 

LIST OF TABLES 

1 Table Page

2 1-1 Applicable State of New Mexico Laws, Regulations, and Agreements . 1-8 

3 1-2 Legal/Regulatory Requirements and Authorizations for Site Preparation 

4 and Construction of the Proposed IIFP Facility ..................................... 1-13 

5 1-3 Legal/Regulatory Requirements and Authorizations for Operation of 

6 the Proposed IIFP Facility ..................................................................... 1-15 

7 2-1 Facility Design Basis Inventories ........................................................... 2-15 

8 2-2 Projected Annual Gaseous Emissions to the Atmosphere from Phase 1 

9 Facility Operations ................................................................................. 2-15 

10 2-3 Phase 1 Estimated Annual Solid Waste Generation - Operations ........ 2-22 

11 2-4 Comparison of Impacts between Proposed Action and No-Action 

12 Alternatives ............................................................................................ 2-26 

13 2-5 IIFP’s Evaluation Criteria for Fine Screening ......................................... 2-30 

14 3-1 New Mexico GHG Emissions, by Sector ............................................... 3-13 

15 3-2 Comparison of New Mexico vs. U.S GHG Emissions (Percent) 

16 by Sector ............................................................................................... 3-14 

17 3-3 Monthly Temperature in Hobbs, New Mexico, 1912 to 2010 ................. 3-15 

18 3-4 Monthly Precipitation in Hobbs, New Mexico, from 1912 to 2010 ......... 3-16 

19 3-5 Weather Stations Located Near the Proposed IIFP Site ....................... 3-17 

20 3-6 Federal and New Mexico Ambient Air Quality Standards ...................... 3-19 

21 3-7 Allowable Prevention of Significant Deterioration Increments ............... 3-20 

22 3-8 Ambient Levels of Criteria Pollutants in Nearby Counties ..................... 3-21 

23 3-9 Lea County Criteria Pollutant Emissions in 2002 .................................. 3-22 

24 3-10 Summary of Active Mines, Mills, Pits and Quarries in Lea County ........ 3-27 

25 3-11 Oil and Gas Wells within 1.6 km (1 mi) of the Site ................................ 3-29 

26 3-12 Site Soil Characteristics ......................................................................... 3-29 

27 3-13 Summary of Potential Deep-Aquifer Groundwater Sources for 

28 Lea County ............................................................................................ 3-38 

29 3-14 Summary of Supply Wells within 1.6 km (1 mi) of the Site .................... 3-40 

30 3-15 Summary of Groundwater Use in Lea County, 2005 ............................. 3-43 

31 3-16 Summary of City of Hobbs Municipal Water System Groundwater 

32 Water Quality, 2005 – 2009 ................................................................... 3-45 

33 3-17 Mammal, Bird, Amphibian, and Reptile Species Likely to be Present 

34 at the Proposed Site and Vicinity. .......................................................... 3-52 

35 3-18 Rare, Threatened or Endangered Species Listed for Lea County, 

36 New Mexico. .......................................................................................... 3-58 

37 3-19 Select Population Characteristics of Counties within the ROI and the 

38 State of New Mexico .............................................................................. 3-64 

39 3-20 Population Estimates of ROI Counties and Incorporated 

40 Municipalities, 2009 ............................................................................... 3-65 

41 3-21 Historic Population in the ROI, 1990 to 2009 ........................................ 3-65 

42 3-22 Projected Population in the ROI, 2005 to 2035 ..................................... 3-65 

43 3-23 Block Groups within 80 km (50 mi) of the Proposed IIFP Site with 

44 Significant Minority or Low-Income Populations (Meeting 50 Percent 

45 Criteria or Exceeding Respective County or State Percentages by 

46 20 Percent) ............................................................................................ 3-71 

47 3-24 Employment in ROI, by Industry, 2001 to 2008 ..................................... 3-74 

48 3-25 Labor Statistics, ROI and New Mexico, 2001 to 2010 ........................... 3-76 
 xiii 

LIST OF TABLES (CONTINUED) 

1 Table Page

2 3-26 Income Statistics, ROI Counties and Population Centers, and 

3 New Mexico, 2008 ................................................................................. 3-76 

4 3-27 Gross Receipts Tax Rates in the ROI, as of July, 2010 ........................ 3-77 

5 3-28 IIFP Annual Property Tax Information ................................................... 3-78 

6 3-29 Housing Characteristics in ROI Counties and Population Centers, 2008 3-78 

7 3-30 Major Public Water Suppliers in ROI, 2007 – 2009 ............................... 3-79 

8 3-31 Major Wastewater Treatment Facilities in ROI ...................................... 3-79 

9 3-32 Public School Districts in the ROI, 2008 ................................................ 3-80 

10 3-33 Fire Protection in the ROI, 2010 ............................................................ 3-80 

11 3-34 Law Enforcement in ROI Counties and Incorporated Places, 2009 ...... 3-81 

12 3-35 AADT Volumes for Roadways that Access the Proposed IIFP Site ...... 3-82 

13 4-1 CO2 Emissions from Construction Equipment ....................................... 4-4 

14 4-2 Emissions from Workforce Commuting and Delivery Activities During 

15 Construction .......................................................................................... 4-4 

16 4-3 Construction Equipment and Hours of Operation by Type and Month .. 4-6 

17 4-4 Estimated Maximum Annual Emissions from Construction of the 

18 IIFP Facility ............................................................................................ 4-7 

19 4-5 Comparison of Maximum Annual Emissions from Construction of 

20 the IIFP Facility to Lea County Baseline Conditions .............................. 4-8 

21 4-6 Comparison of Predicted Maximum Downwind Concentrations Due 

22 to Construction Activities to NAAQS ...................................................... 4-8 

23 4-7 Assumptions for Workforce Characterization during Peak 

24 Construction Period ............................................................................... 4-15 

25 4-8 Direct and Indirect Employment ............................................................ 4-15 

26 4-9 Nonfatal/Fatal Occupational Injuries Projected for IIFP Facility 

27 Construction .......................................................................................... 4-21 

28 4-10 Solid Waste Generation - Construction ................................................. 4-23 

29 4-11 Hazardous Waste Generation - Construction ........................................ 4-23 

30 4-12 Low Level Radioactive Waste Generation - Construction ..................... 4-23 

31 4-13 Annual Transportation-Related CO2 Emissions During IIFP Facility 

32 Operations ............................................................................................. 4-26 

33 4-14 Estimated Maximum Annual Criteria Pollutant Emissions from 

34 Phase 1 Operation of the IIFP Facility ................................................... 4-28 

35 4-15 Estimated Maximum Annual Criteria Pollutant Emissions from 

36 Highway Vehicles during Phase 1 Operation of the IIFP Facility .......... 4-28 

37 4-16 Comparison of Maximum Annual Emissions from Phase 1 

38 Operations to Lea County Baseline Conditions ..................................... 4-28 

39 4-17 Predicted Property Boundary Concentrations Due to Phase 1 

40 Operations, NAAQS and Allowable Class II PSD Increments ............... 4-29 

41 4-18 Annual Nonradioactive Gaseous Emissions from the Operation of the 

42 Proposed IIFP Facility ........................................................................... 4-30 

43 4-19 Assumptions for Workforce Characterization During Phase 1 

44 Operation ............................................................................................... 4-35 

45 4-20 Direct and Indirect Employment during IIFP Phase 1 Operation ........... 4-36 

46 4-21 Estimated Gross Receipts and Income Tax Payments to New Mexico 

47 and Lea County for the Phase 1 Operation Period, 2009 Dollars ......... 4-37 
 xiv 

LIST OF TABLES (CONTINUED) 

1 Table Page

2 4-22 Annual Collective Doses to Various Receptors from Radiological 

3 Transportation ....................................................................................... 4-43 

4 4-23 Estimated and Bounding Radiological Releases from the Stacks ......... 4-45 

5 4-24 Annual and Committed Dose Equivalents for Exposures to the 

6 MEI from Gaseous Effluents .................................................................. 4-47 

7 4-25 Annual and Committed Dose Equivalents for Exposure to the Nearest 

8 Resident from Gaseous Effluents .......................................................... 4-47 

9 4-26 Collective Dose Equivalents to All Ages Population (person-Sv) 

10 (gas release pathways) ......................................................................... 4-49 

11 4-27 Collective Dose Equivalents to All Ages Population (person-rem) 

12 (gas release pathways). ........................................................................ 4-50 

13 4-28 Estimated Annual Nonradiological Gaseous Fluoride Emissions .......... 4-52 

14 4-29 Annual Nonfatal and Fatal Occupational Injuries Projected for 

15 Operation of the IIFP Facility ................................................................. 4-53 

16 4-30 Solid Waste Generation – Operations ................................................... 4-55 

17 4-31 Hazardous Waste Generation – Operations .......................................... 4-55 

18 4-32 Low Level Radioactive Waste Generation – Operations ....................... 4-55 

19 4-33 Accident Consequence Categories ....................................................... 4-59 

20 4-34 Chemical Consequence Exposure Thresholds ..................................... 4-59 

21 4-35 Summary of Accident Analysis Results ................................................. 4-60 

22 4-36 Summary of Annual Radiological Transportation Shipments ................ 4-62 

23 4-37 Annual Accident Dose-Risk and LCF-Risk from Radiological 

24 Transportation ....................................................................................... 4-62 

25 4-38 Phase 2 Construction Solid Waste Generation ..................................... 4-82 

26 4-39 Phase 2 Construction Hazardous Waste Generation ............................ 4-82 

27 4-40 Phase 2 Construction Radioactive Waste Generation .......................... 4-82 

28 4-41 Cumulative Solid Waste Generation – Phase 1 and 2 IIFP Facility ....... 4-84 

29 4-42 Cumulative Hazardous Waste Generation -– Phase 1 and 2 

30 IIFP Facility ............................................................................................ 4-85 

31 4-43 Cumulative Radioactive Waste Generation – Phase 1 and 2 

32 IIFP Facility ............................................................................................ 4-85 

33 5-1 Summary of Potential Mitigation Measures Proposed by IIFP for 

34 Construction (including preconstruction activities) ................................ 5-2 

35 5-2 Summary of Potential Mitigation Measures Proposed by IIFP for 

36 Operations ............................................................................................. 5-6 

37 6-1 Guidance Documents Applicable to Radiological Monitoring Program . 6-2 

38 6-2 Gaseous Effluent Sampling Program .................................................... 6-3 

39 6-3 Radiological Sampling and Analysis Program ....................................... 6-5 

40 6-4 Baseline Radiological Soil and Vegetation Samples ............................. 6-6 

41 6-5 Physicochemical Sampling .................................................................... 6-8 

42 6-6 Required Minimum Detectable Concentrations for Environmental 

43 Sample Analyses ................................................................................... 6-9 

44 6-7 Stormwater Monitoring Program ............................................................ 6-10 

45 6-8 Baseline Physicochemical Soil Sample Results .................................... 6-11 

46 6-9 Baseline Physicochemical Vegetation Sample Results ......................... 6-12 

47 7-1 Construction Capital and Labor Costs for the IIFP Facility 

48 (millions of 2009 dollars) ........................................................................ 7-2 
 xv 

LIST OF TABLES (CONTINUED) 

1 Table Page

2 7-2 Estimated Annual Waste Disposal Costs (millions of 2009 dollars) ...... 7-5 

3 7-3 Estimated Replacement Capital Expenditures (millions of 2009 dollars) 7-6 

4 7-4 Total Annual Internal Operations Costs (millions of 2009 dollars) ......... 7-6 
 xvi 

LIST OF FIGURES 

1 Figure Page

2 2-1 General Site Location Map. ................................................................... 2-3 

3 2-2 Proposed IIFP Facility Boundary. .......................................................... 2-4 

4 2-3 Plant Throughput for the DUF6 Deconversion Process. ........................ 2-5 

5 2-4 Process Flow Chart for Deconversion of DUF6 to DUF4. ....................... 2-7 

6 2-5 Process Flow Chart for SiF4 Production. ............................................... 2-8 

7 2-6 Process Flow Chart for BF3 Production. ................................................ 2-9 

8 2-7 Plant KOH Scrubbing System Process Flow. ........................................ 2-17 

9 2-8 EPP HF Neutralization and KOH Regeneration Processes. ................. 2-20 

10 3-1 80-km (50-mi) Radius Map .................................................................... 3-2 

11 3-2 10-km (6-mi) Radius Map ...................................................................... 3-3 

12 3-3 Wind Roses For Midland-Odessa, Roswell, Hobbs, and 

13 Eunice for 1993 ..................................................................................... 3-18 

14 3-4 Physiography of New Mexico ................................................................ 3-24 

15 3-5 PGA 10% for New Mexico ..................................................................... 3-25 

16 3-6 Mineral Resource Map .......................................................................... 3-26 

17 3-7 Oil and Gas Well Map ............................................................................ 3-28 

18 3-8 Section 27 Soils Map ............................................................................. 3-30 

19 3-9 Underground Water Basins of NM ......................................................... 3-33 

20 3-10 Geologic Cross-section Showing the Deep Aquifers of Lea County ..... 3-34 

21 3-11 Groundwater Flow Map ......................................................................... 3-35 

22 3-12 Depth to Groundwater Map ................................................................... 3-36 

23 3-13 Critical Management Areas Lea County Basin ...................................... 3-39 

24 3-14 1-Mile Radius Groundwater Well Map ................................................... 3-41 

25 3-15 6-Mile Radius Groundwater Well Map ................................................... 3-42 

26 3-16 Ephemeral Stream Map ......................................................................... 3-46 

27 3-17 Water Distances Map ............................................................................ 3-47 

28 3-18 FEMA Map ............................................................................................. 3-48 

29 3-19 Vegetation Communities Map ............................................................... 3-50 

30 3-20 Proposed Lesser Prairie-Chicken Corridor Map .................................... 3-57 

31 3-21 Region of Influence Map ........................................................................ 3-63 

32 3-22 African American Map ........................................................................... 3-68 

33 3-23 Some Other Race Map .......................................................................... 3-69 

34 3-24 Hispanic Ethnicity Map .......................................................................... 3-70 

35 3-25 Low-Income Household Map ................................................................. 3-72 

36 3-26 AADT Location Map .............................................................................. 3-83 

37 3-27 Major Sources and Levels in the Vicinity of the Proposed FEP/DUP 

38 Background Radiation Exposure ........................................................... 3-87 

39 4-1 50-Mile Sectors ...................................................................................... 4-48 

40 
 xvii 

1 EXECUTIVE SUMMARY 

2 Background 

3 Under the provisions of the Atomic Energy Act and pursuant to Title 10 of the U.S. Code of 

4 Federal Regulations Part 40 (10 CFR 40), the U.S. Nuclear Regulatory Commission (NRC) is 

5 considering whether to issue a license that would allow International Isotopes Fluorine Products, 

6 Incorporated (IIFP) to possess, use, transfer, or deliver source and byproduct materials at a 

7 proposed fluorine extraction and depleted uranium deconversion facility near Hobbs in Lea 

8 County, New Mexico. The scope of activities to be conducted under the license would include 

9 the construction, operation, and decommissioning of the proposed IIFP facility. The facility 

10 would deconvert commercially generated depleted uranium hexafluoride (DUF6) into depleted 

11 uranium dioxide (DUO2) for long-term stable disposal, and into fluorine products for resale. 

12 DUF6 is the by-product of uranium enrichment. The application for the license was filed with the 

13 NRC by IIFP, on December 30, 2009. To support its licensing decision on IIFP’s proposed 

14 facility, the NRC determined that the NRC’s implementing regulations in 10 CFR 51 for the 

15 National Environmental Policy Act require the preparation of an Environmental Impact 

16 Statement (EIS). The EIS is used to examine the potential environmental impacts of the 

17 proposed IIFP facility and reasonable alternatives. Based on the EIS and other information, the 

18 NRC will determine whether to issue a license to IIFP for the construction, operation, and 

19 decommissioning of the proposed IIFP facility. 

20 The Proposed Action 

21 The proposed action considered in this draft EIS is for NRC to grant IIFP a license to construct, 

22 operate, and decommission a fluorine extraction and depleted uranium deconversion facility. 

23 The IIFP facility would include a commercial plant to produce specialty fluoride gas products for 

24 sale and DUO2 for disposal. IIFP would own the facility and be responsible for its operation and 

25 performance. The proposed facility, if licensed, would be 22.5 kilometers (km) (14 miles [mi]) 

26 west of Hobbs, New Mexico. The proposed tract of land (IIFP site) occupies 259 ha (640 ac), 

27 and the proposed facility would occupy an estimated 16 ha (40 ac) of the tract, not including 

28 roadways and other infrastructure improvements. 

29 If the license is approved, facility construction activities would begin in the second quarter of 

30 2012 and operations would begin in the fourth quarter of 2013. The proposed facility is 

31 designed to be capable of deconverting up to 3.4 million kilograms (kg) (7.5 million pounds, or 

32 3,750 tons) per year of DUF6. The annual capacity of approximately 3.4 million kg (3,750 tons) 

33 per year equates to about 9,300 kg/day (10.3 tons/day) on average. Following operations the 

34 facility is expected to be decommissioned following termination of the license. 

35 Preconstruction Activities 

36 The applicant’s license application states that IIFP anticipates commencement of certain 

37 preconstruction activities on the proposed IIFP site prior to the NRC’s decision on whether to 

38 issue a license for the construction, operation, and decommissioning of the proposed facility. 

39 The preconstruction activities would be considered by the NRC as a cumulative effect and not a 

40 part of the proposed action. Preconstruction could include the following activities and facilities: 

41 land clearing; site grading (excavating and/or blasting); erosion control and stormwater control 

42 measures installation; access road and parking facilities construction; and others. 
 xviii 

1 Purpose and Need for the Proposed Action 

2 Detailed information on the purpose and need for action is described in Chapter 1 of this draft 

3 EIS. The proposed action is intended to satisfy the need for a facility that would deconvert 

4 DUF6 into DUO2 for disposal. An added goal of IIFP would be to produce fluoride products for 

5 commercial resale. Without a facility such as the proposed IIFP facility, DUF6 would continue to 

6 be stored, typically in 12.7-metric ton (14-ton) cylinders, at commercial uranium enrichment 

7 facilities in the United States. Although DUF6 could be transferred to the U.S. Department of 

8 Energy (DOE) for a fee, DOE’s existing inventory of DUF6 is not projected to be deconverted for 

9 approximately 25 years. Further, long-term storage of DUF6 represents a potential chemical 

10 hazard if the material is not properly managed, and deconversion to DUO2 is preferable. The 

11 fluoride products are potentially valuable for applications in the electronic, solar panel, and 

12 semi-conductor markets, among others. In addition, anhydrous hydrogen fluoride (AHF) is a by13 product of the deconversion process and is an important chemical in various industrial 

14 applications. 

15 Alternatives 

16 A detailed analysis of alternatives is included in Chapter 2 of this draft EIS. The no-action 

17 alternative is considered in this draft EIS as a baseline for comparison. Under the no-action 

18 alternative, NRC would not grant a license to IIFP to construct, operate, and decommission the 

19 proposed facility near Hobbs, New Mexico, to receive and process source material, and to ship 

20 products and low-level radioactive waste (LLW). However, impacts from preconstruction 

21 activities could occur under the no-action alternative. The proposed site would remain in its 

22 current or preconstruction condition. The regional economy would not be changed either 

23 positively or negatively, except by preconstruction. LLW would not be shipped to licensed 

24 disposal facilities for disposal. Fluoride products would not be manufactured and sold to end 

25 users. Planned or existing commercial enrichment facilities would not be able to send their 

26 DUF6 to the IIFP facility for deconversion. 

27 Four options would be open to these commercial facilities, in the event of the no-action 

28 alternative: (1) ship the DUF6 to DOE facilities, (2) ship the DUF6 to facilities overseas, 

29 (3) indefinitely store the DUF6, or (4) construct their own deconversion facilities. DOE has 

30 constructed two facilities to deconvert DUF6 to uranium oxides (different compounds than that 

31 which would be produced by IIFP’s proposed facility) and hydrofluoric acid: one in Paducah, 

32 Kentucky and one in Piketon (Portsmouth), Ohio. Therefore, shipment to these DOE facilities is 

33 a viable option under the no-action alternative. Given that DOE has a backlog of 700,000 metric 

34 tons (771,618 tons) of DUF6 (stored in approximately 57,000 cylinders) to deconvert, it may take 

35 DOE approximately 25 years to complete its mission before beginning to deconvert privately 

36 generated DUF6. The DOE process does not produce the fluoride products, and it produces a 

37 hydrofluoric acid solution rather than the anhydrous hydrogen fluoride, which is an important 

38 chemical in various industrial applications. 

39 IIFP conducted a site selection process to determine the best location, by IIFP criteria, for the 

40 proposed site. The NRC staff reviewed the IIFP site selection process and determined that the 

41 process was rational and objective. Accordingly, no alternate sites are evaluated in the draft 

42 EIS. 

43 The NRC staff evaluated several alternative technologies, including: (1) a direct deconversion 

44 process; (2) the DOE deconversion process that is used at Paducah, Kentucky, and Piketon 

45 (Portsmouth), Ohio; and (3) a foreign (European) process. The direct deconversion, DOE 
 xix 

Determining the Significance of 

Potential Environmental Impacts

NRC has established a standard of 

significance for assessing environmental 

impacts. Each impact is assigned one of 

the following three significance levels: 

• SMALL: The environmental effects are 

not detectable or are so minor that they 

would neither destabilize nor noticeably 

alter any important attribute of the 

resource. 

• MODERATE: The environmental 

effects are sufficient to noticeably alter 

but not destabilize important attributes of 

the resource. 

• LARGE: The environmental effects are 

clearly noticeable and are sufficient to 

destabilize important attributes of the 

resource. 

1 deconversion, and foreign conversion alternative processes were eliminated from analysis in the 

2 draft EIS because (1) the applicant owns and has expertise in a competing technology, (2) the 

3 impacts of implementing these technologies would be sufficiently similar to the proposed action, 

4 and (3) none of these processes would satisfy the goal to produce marketable fluoride by5 products. 

6 The NRC staff also considered an alternative that would ship the U.S.-generated DUF6 to 

7 overseas facilities for deconversion. However, because of prohibitive cost of such shipments, 

8 this alternative was eliminated from consideration in the draft EIS. An alternative that would 

9 indefinitely store the DUF6 was also eliminated from consideration because long-term storage of 

10 DUF6 represents a potential chemical hazard if not properly managed, and such an alternative 

11 would not meet the underlying need for deconversion of the DUF6. Lastly, the NRC staff 

12 considered an alternative in which the four U.S.-based enrichment companies could construct 

13 and operate their own deconversion facilities. However, because none of these firms has 

14 expressed an interest in constructing such a facility, NRC staff concluded that this alternative 

15 should be eliminated from consideration in this draft EIS. 

16 Potential Environmental Impacts of the Proposed Action 

17 In this draft EIS, NRC staff evaluates the existing 

18 conditions (Chapter 3) and potential environmental 

19 impacts of the proposed action (Chapter 4). A 

20 standard of significance, (see text box), has been 

21 established for assessing environmental impacts. 

22 The NRC staff has assigned each impact one of 

23 the three significance levels described in the 

24 textbox. The environmental impacts from the 

25 proposed action are SMALL or MODERATE and 

26 could be mitigated by the methods described in 

27 Chapter 5. Environmental monitoring methods are 

28 described in Chapter 6. 

29 Summarized below are the potential environmental 

30 impacts of the proposed action on each of the 

31 resource areas considered in this draft EIS. Each 

32 summary is preceded by the impact significance 

33 level for the respective resource areas. 

34 Land Use 

35 SMALL. Construction activities would occur on 

36 about 16 ha (40 ac) within the 259-ha (640-ac) site. 

37 Construction of the proposed facility would alter the current land use of the entire IIFP site, a 

38 tract known as Section 27 of Township 18 South, Range 36 East, which is primarily used for 

39 cattle grazing. The transfer and conversion of the land for the facility would not conflict with any 

40 existing Federal, State, local, or Tribal Nation land use plans, or restrict current or planned 

41 mineral resource exploitation. The operation of the proposed facility would be consistent with 

42 the existing land use of the neighboring tracts, which support industrial facilities, natural gas and 

43 oil extraction and transmission infrastructure, and agriculture and open land. 
 xx 

1 Historical and Cultural Resources 

2 SMALL. An archaeological survey of the entire 259-ha (640-ac) site failed to identify any 

3 archeological resources other than several isolated artifacts that were not considered to be 

4 eligible for the National Register of Historic Places. Consultation with Federally recognized 

5 Tribal Nations and the New Mexico State Historic Preservation Division (which serves as the 

6 State Historic Preservation Officer) did not identify any additional information on historically or 

7 culturally significant resources within the area potentially affected by the proposed facility. The 

8 preconstruction, construction, and operation of the proposed facility would not adversely affect 

9 historic resources or other cultural resources (e.g., significant archaeology sites). 

10 Visual and Scenic Resources 

11 SMALL. The proposed 259-ha (640-ac) site is flat and sparsely developed with a few 

12 irregularly-spaced structures for natural gas and oil extraction, and overhead transmission lines. 

13 The proposed IIFP facility would be approximately 22.5 km (14 mi) west of the nearest 

14 population center, Hobbs, New Mexico and would not be visible from Hobbs. The proposed site 

15 received the lowest scenic-quality rating using the U.S. Bureau of Land Management visual 

16 resource inventory process. 

17 Climatology, Meteorology, and Air Quality 

18 SMALL to MODERATE. Air concentrations of (1) criteria pollutants predicted for vehicle 

19 emissions and (2) emissions of particulate matter of less than 10 microns (PM10) from fugitive 

20 dust during construction would be below the National Ambient Air Quality Standards (NAAQS) 

21 for carbon monoxide (CO) and sulfur dioxide (SO2) emissions, and above NAAQS for nitrogen 

22 dioxide (NO2), and particulate matter (PM2.5 and PM10) emissions. Fugitive dust emissions 

23 would be temporary and localized. During construction of the IIFP facility, carbon dioxide (CO2) 

24 emissions are projected to be 2,110 metric tons (2,326 tons) or 0.003 percent of New Mexico’s 

25 statewide output and 0.00003 percent of the projected nationwide CO2 emissions for the same 

26 period. A National Emissions Standards for Hazardous Air Pollutants Title V permit would not 

27 be required for operations due to the low levels of estimated emissions. All stack emissions 

28 would be monitored. During any typical year of IIFP facility operation, CO2 emissions are 

29 projected to be 5,774 metric tons (6,373 tons), approximately 0.009 percent of the New Mexico 

30 statewide output or 0.0009 percent of the nationwide emissions for calendar year 2000. 

31 Geology, Minerals, and Soils 

32 SMALL. Construction-related impacts on the geology, minerals, and soils would occur within 

33 the 16 ha (40 ac) of the 259-ha (640-ac) site on which the proposed facility would be built, and 

34 for the construction of the access road, which would extend roughly 1 kilometer (1/2 mi) from 

35 Arkansas Junction Road (NM 483) to the entrance of the proposed facility. The site has no 

36 prime farmland, as defined by the U.S. Department of Agriculture. The site has been explored 

37 for oil and gas and mined for caliche and, thus, it has very limited leasable, locatable, or 

38 marketable mineral resources. Therefore, the proposed facility construction activities would not 

39 result in loss of mineral resources. No impact to the underlying bedrock, mineral resources, or 

40 soils is expected during the facility operations. The site is in an area of limited seismic activity 

41 and operation of the IIFP facility is not expected to cause seismic or fault-related impacts. Any 

42 seismic risk would be mitigated by incorporation of seismic criteria in the facility design. 
 xxi 

1 Water Resources 

2 SMALL. The site has no permanent surface water and no jurisdictional wetlands. The closest 

3 source of a named ephemeral stream is more than 5 km (3 mi) from the property, and the 

4 nearest permanent surface water is more than 32 km (20 mi) from the site. The site, which 

5 overlies the Lea County Underground Water Basin, would utilize water from the Ogallala Aquifer 

6 to support construction and operation. Groundwater demand on the Ogallala Aquifer during 

7 construction would be relatively low, mainly for dust suppression. During operations, 

8 groundwater use for potable water and process water needs is estimated to be less than 38,000 

9 liters (10,000 gallons [gal]) per day peak, averaging an estimated 13,000 liters (3,000 gal) per 

10 day. The proposed facility would use approximately 0.5 percent of the estimated additional 

11 annual 40-year planning period groundwater demand for Lea County and only 0.15 percent of 

12 the unappropriated water rights that have been assigned to Lea County. 

13 Ecological Resources 

14 SMALL. Approximately 16 ha (40 ac) of land would be disturbed, which represents 

15 approximately 6 percent of the site’s 259 ha (640 ac). There are no wetlands or unique 

16 habitats, and no threatened or endangered species on the proposed site. Fencing around the 

17 proposed IIFP facility would restrict wildlife access to the facility. Mitigation measures proposed 

18 by the New Mexico Department of Game and Fish (Appendix B - Consultation/Correspondence) 

19 would be considered to lessen impacts. 

20 Socioeconomics 

21 SMALL. Construction of the IIFP facility would employ approximately 140 people. Eighty 

22 percent of this staff is expected to be current residents in the socioeconomic region of influence 

23 (ROI): Lea and Eddy Counties, New Mexico. It is expected that the other 20 percent 

24 (28 workers) would migrate into the socioeconomic ROI. Including family members, the total 

25 increase in residents to the ROI is expected to be 72 people, which would result in a 

26 0.06 percent increase in the ROI population. During operation, the proposed IIFP facility would 

27 employ approximately 140 people, and 20 percent (28 individuals with their families) are 

28 expected to in-migrate, increasing the population in the socioeconomic ROI by 90 people, or 

29 less than 0.1 percent of the 2009 population. The impacts on the local unemployment rate, 

30 housing vacancies, schools, and public services and utilities would be minimal during operations 

31 and construction. 

32 Environmental Justice 

33 SMALL. The environmental justice analysis focused on census blocks and block groups in an 

34 area within 80 kilometers (50 miles) of the proposed IIFP site. The largest minority population 

35 within 80 kilometers (50 miles) of the proposed site is the Hispanic/Latino population. The 

36 nearest minority or low-income population as defined by NRC criteria is 22.5 km (14 mi) from 

37 the proposed site. The impacts of IIFP construction and operation on resources would be 

38 SMALL and, in most cases, localized. Therefore, because all impacts would be SMALL, and 

39 the identified minority and low-income populations are not in close proximity to the proposed 

40 site, impacts would not be disproportionately high and adverse for any populations in the region, 

41 including minority or low-income populations. 
 xxii 

1 Noise 

2 SMALL. Noise would come predominantly from construction equipment and traffic. 

3 Construction activities would be temporary and limited to daytime working hours. The nearest 

4 residence is approximately 2.6 km (1.6 mi) northwest of the site and there are no recreational 

5 areas within 8.0 km (5.0 mi) of the proposed site. Noise levels during operations would be 

6 within the U.S. Department of Housing and Urban Development guidelines. 

7 Traffic and Transportation 

8 SMALL. The potential maximum increase from construction workforce traffic would be 

9 280 round trips per weekday, and the potential maximum increase to traffic due to construction 

10 deliveries and waste removal would be 40 round trips per weekday. The majority of the 

11 construction worker trips would use US 62/180 to access NM 483. These trips would increase 

12 traffic on NM 483 by 33.5 percent daily, but the design capacities of NM 483 and US 62/180 

13 would not be exceeded. Statistically, the risk of an accident with injuries (risk of less than 

14 0.8 injury crashes per year) or fatality (risk of less than 0.03 fatal crashes per year) to the 

15 construction workforce is unlikely. 

16 The operational workforce could increase the traffic on NM 483 by 29 percent and on US 62/180 

17 by 8 percent daily. With the predicted increased traffic volumes, the design capacities of 

18 NM 483 and US 62/180 would not be exceeded. Statistically the risk of an accident with injuries 

19 (risk of less than 0.7 injury crashes per year) or a fatality (risk of less than 0.02 fatal crashes per 

20 year) for the operations traffic is unlikely. 

21 Operation of the IIFP facility would require shipment of full DUF6 cylinders from commercial 

22 enrichment facilities, empty DUF6 cylinders back to the commercial enrichment facilities, DUO to 

23 waste disposal facilities, and other miscellaneous process and LLW to waste disposal facilities. 

24 Approximately 730 radiological shipments would occur annually. The collective doses from 

25 shipments and accidents involving shipments would be comparatively low, versus natural 

26 sources of radiation (Appendix E - Transportation of Radioactive Materials). 

27 Public and Occupational Health and Safety 

28 SMALL. During construction, a fatality would be unlikely (the probability of fatality is less than 

29 one per year). During normal operations, based on statistical probabilities, there could be six 

30 industrial injuries per year and no fatalities. Worker radiological doses were conservatively 

31 estimated to be about 0.75 mSv/yr (75 millirem/yr) for those workers involved in the 

32 deconversion processing operations within the proposed facility. The average individual dose 

33 for workers at the cylinders yards was estimated to range from a low of 4.3 mSv/yr 

34 (430 millirem/yr) to a high of 6.9 mSv/yr (690 millirem/yr). All public radiological exposures 

35 would be significantly below the 10 CFR 20 regulatory limit of 1 mSv (100 millirem) per year. 

36 The maximally exposed member of the public would receive approximately 0.21 mSv/yr 

37 (21 millirem/yr) from the proposed facility operations. For comparison purposes, the average 

38 annual dose to a member of the public due to background radiation is estimated to be about 

39 3.1 mSv/yr (310 millirem/yr) (see details in the body of the draft EIS [Section 3.12]). 

40 The most significant possible accident consequences would be those associated with the 

41 rupture of a cylinder containing liquefied DUF6. However, the facility emergency plan addresses 

42 this type of event, and all other high- and intermediate-consequence events. The facility design 

43 and procedures would reduce the likelihood of this type of event by requiring a robust cylinder 
 xxiii 

1 design that maintains its integrity during credible drops, shocks, collisions, and thermal events. 

2 In addition, facility design features, which prevent release of liquid DUF6 or rupture of cylinders 

3 during processing cycles, would be implemented. Procedures would be instituted which would 

4 minimize the possibility of an accident scenario occurring, and would provide steps to take 

5 should an accident occur. The NRC staff concludes that through the combination of facilities 

6 design, engineered controls, and administrative controls, including procedures, accidents at the 

7 facility would pose a small risk to workers, the environment, and the public. 

8 Waste Management 

9 SMALL. Nonhazardous waste generated from the proposed construction activities would result 

10 in a negligible increase (less than 0.0007 percent) in the waste that the Lea County landfill 

11 receives annually from all sources. Less than 0.9 metric ton/yr (1 ton/yr) of hazardous wastes 

12 would be expected from construction of the proposed IIFP facility. This would represent less 

13 than 0.00009 percent of the overall hazardous waste generated in the State. 

14 During operations, industrial waste generated from the proposed facility would result in an 

15 increase of approximately 0.06 percent in the waste that the Lea County landfill receives 

16 annually from all sources. Hazardous waste generated during operations would also be small, 

17 resulting in an increase of less than 0.02 percent in the hazardous waste generated in the State 

18 of New Mexico. Up to 3,170 tons per year of LLW could be sent for disposal annually. There is 

19 enough existing national disposal capacity to accept the LLW that would be generated at the 

20 proposed facility. 

21 Summary of the Costs and Benefits of the Proposed Action 

22 The costs of construction activities is estimated to be between $100 million and $140 million (in 

23 2009 dollars), excluding escalation, contingencies, and interest. Construction-related activities, 

24 purchases, and workforce expenditures would incur several types of taxes, including individual 

25 income taxes, gross receipts taxes, and property taxes. Approximately $554,400 of fee in lieu 

26 of property tax would be paid to the Hobbs Municipal School District and the New Mexico Junior 

27 College during the construction period. 

28 During operations, about $56 million to $71 million (in 2009 dollars) in wages (wages account 

29 for $7.9 million to $9.1 million), benefits, goods and services would be spent annually. 

30 Construction and operation of the facility would have additional indirect economic impacts by 

31 creating additional employment and economic activity within the region of influence. Over the 

32 lifetime of operations, the low estimate of corporate income taxes and gross receipts taxes paid 

33 is $144,200,000 to the State of New Mexico. Over the lifetime of operations, the low estimate of 

34 gross receipts taxes is $6,500,000 (in 2009 dollars) to Lea County. 

35 Comparison of Alternatives 

36 Under the no-action alternative, NRC would not grant a license to IIFP to construct the proposed 

37 facility near Hobbs, New Mexico, to receive and process source material, and to ship products 

38 and LLW. The four planned or existing commercial enrichment facilities would not be able to 

39 send their DUF6 to the IIFP facility for deconversion. DOE has constructed two deconversion 

40 facilities to convert DUF6 to U3O8 and hydrofluoric acid: one in Paducah, Kentucky and one in 

41 Piketon (Portsmouth), Ohio. Therefore, shipment to these DOE facilities is a viable option under 

42 the no-action alternative, but the timeframe for deconversion would be much greater than what 

43 the proposed IIFP facility would provide, and goals to create commercial fluorine products would 
 xxiv 

1 not be realized. Under the no-action alternative, the proposed site would be impacted by 

2 preconstruction, but would not be impacted by operation of the proposed facility. The no-action 

3 alternative would have cumulative impacts due to preconstruction on current land use; 

4 visual/scenic and cultural resources; air; water; ecological resources; geology, minerals and 

5 soils; socioeconomics; environmental justice; traffic and transportation; public and occupational 

6 health; and waste management. These impacts would be SMALL for all resources except for 

7 air quality, for which they would be SMALL to MODERATE. 

8 In comparison to the no-action alternative, the proposed action would have SMALL impacts on 

9 land use; air; water; ecological resources; geology, minerals and soils; noise; traffic and 

10 transportation; public and occupational health; socioeconomics (these impacts would be SMALL 

11 and positive); environmental justice; and waste management. 
xxv 

1 ACRONYMS AND ABBREVIATIONS 

2 0 C degrees Celsius 

3 0 F degrees Fahrenheit 

4 AADT annual average daily traffic 

5 ac acre(s) 

6 ACEC area of critical environmental concern 

7 ACHP Advisory Council on Historic Preservation 

8 AEGL acute exposure guideline levels 

9 AHF anhydrous hydrogen fluoride 

10 ALARA as low as reasonably achievable 

11 APE area of potential effect 

12 API American Petroleum Institute 

13 AQCR Air Quality Control Region 

14 B2O3 boron oxide 

15 BEA Bureau of Economic Analysis 

16 BF3 boron trifluoride 

17 bgs below ground surface 

18 BLM Bureau of Land Management 

19 BMP best management practice 

20 Bq/L becquerel per liter 

21 CaCO3 calcium carbonate 

22 CaF2 calcium fluoride 

23 Ca(OH2) calcium hydroxide 

24 CCS Center for Climatic Strategies 

25 CEDE committed effective dose equivalent 

26 CEQ Council on Environmental Quality 

27 CERCLA Comprehensive Environmental Response Compensation and 

28 Liability Act 

29 CFR Code of Federal Regulations 

30 CH4 methane 

31 Ci curie 

32 cm centimeter 

33 CMA critical management areas 

34 
xxvi 

1 ACRONYMS AND ABBREVIATIONS 

2 (continued) 

3 CO carbon monoxide 

4 CO2 carbon dioxide 

5 CWA Clean Water Act 

6 dB decibel (sound pressure level) 

7 dB(A) decibel, A-weighted (humanly audible frequency) 

8 DNFSB Defense Nuclear Facilities Safety Board 

9 DOE U.S. Department of Energy 

10 DOT U.S. Department of Transportation 

11 DU depleted uranium 

12 DUF4 depleted uranium tetrafluoride 

13 DUF6 depleted uranium hexafluoride 

14 DUO2 depleted uranium dioxide 

15 DUO depleted uranium oxides (general term; not a compound that exists) 

16 DUO2F2 depleted uranyl dioxyfluoride 

17 DWB Drinking Water Bureau 

18 EDE effective dose equivalent 

19 EPP environmental protection process 

20 EIS environmental impact statement 

21 EPA U.S. Environmental Protection Agency 

22 Eq equivalents 

23 ER environmental report 

24 ERPG Emergency Response Planning Guideline 

25 ESA Endangered Species Act 

26 FD&C Federal Food, Drug and Cosmetic Act 

27 FEMA Federal Emergency Management Agency 

28 FEP/DUP Fluorine Extraction Process/Depleted Uranium Deconversion Plant 

29 ft foot or feet 

30 FR Federal Register 

31 g gravity 

32 gal gallon(s) 

33 GHG greenhouse gases 

34 gpd gallons per day 
xxvii 

1 ACRONYMS AND ABBREVIATIONS 

2 (continued) 

3 gpm gallons per minute 

4 GPS global positioning system 

5 GWP global warming potential 

6 H2 hydrogen 

7 ha hectare(s) 

8 HAP hazardous air pollutant 

9 HF hydrofluoric acid or hydrogen fluoride 

10 HFC hydrofluorcarbon 

11 HPD [New Mexico] Historic Preservation Division 

12 HS&E health, safety and environmental 

13 HUD U.S. Department of Housing and Urban Development 

14 IIFP International Isotopes Fluorine Products, Inc 

15 in inch 

16 IPCC Intergovernmental Panel on Climate Change 

17 IRB industrial revenue bond 

18 ISA integrated safety analysis 

19 kBq kilobecquerel 

20 KF potassium fluoride 

21 kg kilogram 

22 KOH potassium hydroxide 

23 km kilometer(s) 

24 km/hr kilometers per hour 

km2 25 square kilometer 

26 kV kilovolt 

27 L liter 

28 lb pound 

29 LCF latent cancer fatality 

30 LLD lower limit of detection 

31 LES Louisiana Energy Services 

32 LLRW low-level radioactive waste 

33 LLW low-level (radioactive) waste 

34 L/min liters per minute 
xxviii 

1 ACRONYMS AND ABBREVIATIONS 

2 (continued) 

3 m meter(s) 

4 MCL maximum contaminant levels 

5 MDC minimum detection concentrations 

6 MEI maximally exposed individual 

7 mg milligram 

8 MGD million gallons per day 

9 mg/kg micrograms per kilogram 

10 mg/L milligrams per liter 

mg/m3 11 milligrams per cubic meter 

12 mi mile(s) 

mi2 13 square mile 

14 MM modified Mercalli 

15 mpg miles per gallon 

16 mph miles per hour 

17 mrem millirem 

18 mSv millisievert 

19 MW megawatt 

20 N2O nitrous oxides 

21 NAAQS National Ambient Air Quality Standards 

22 NAGPRA Native American Graves Protection and Repatriation Act 

23 NCRP National Council on Radiation Protection 

24 NEPA National Environmental Policy Act 

25 NESHAP National Emissions Standards for Hazardous Air Pollutants 

26 NHPA National Historic Preservation Act 

27 NH3 ammonia 

28 NM New Mexico 

29 NMAAQS New Mexico Ambient Air Quality Standards 

30 NMAC New Mexico Administrative Code 

31 NMDOT New Mexico Department of Transportation 

32 NMED New Mexico Environment Department 

33 NMEDAQB New Mexico Environmental Department Air Quality Bureau 

34 NMEDHWB New Mexico Environmental Department Hazardous Waste Bureau 
xxix 

1 ACRONYMS AND ABBREVIATIONS 

2 (continued) 

3 NMEDRCB New Mexico Environmental Department Radiation Control Board 

4 NMEDWQB New Mexico Environmental Department Water Quality Bureau 

5 NMGF New Mexico Department of Game and Fish 

6 NMOSE New Mexico Office of the State Engineer 

7 NMRL/CID New Mexico Regulations and Licensing/Construction Industries 

8 Division 

9 NMRPR New Mexico Radiation Protection Regulations 

10 NMRPTC New Mexico Rare Plant Technical Council 

11 NMSA New Mexico Statutes Annotated 

12 NM SHPO New Mexico State Historic Preservation Office 

13 NMSLO New Mexico State Land Office 

14 NMSS Nuclear Materials Safety and Safeguards 

15 NMVOC non-methane volatile organic compound 

16 NO2 nitrogen dioxide 

17 NOx oxides of nitrogen 

18 NRC U.S. Nuclear Regulatory Commission 

19 NRHP National Register of Historic Places 

20 O&M operating and maintenance 

21 OSHA Occupational Safety and Health Administration 

pCi/L picocurie per liter (1 X 10-12 22 curie/liter) 

23 PFC perfluorocarbon 

24 PGA peak [horizontal] ground acceleration 

25 PILT payment in lieu of taxes 

26 PM2.5 particulate matter with a diameter less than 2.5 microns 

27 PM10 particulate matter with a diameter less than 10 microns 

28 PPE personal protective equipment 

29 ppm parts per million 

30 PSD prevention of significant deterioration 

31 psig pounds per square inch 

32 PSTB Petroleum Storage Tank Bureau 

33 QA quality assurance 

34 RAI Requests for Additional Information 
xxx 

1 ACRONYMS AND ABBREVIATIONS 

2 (continued) 

3 RCRA Resource Conservation and Recovery Act 

4 REMP Radiological Environmental Monitoring Program 

5 ROD record of decision 

6 ROI region of influence 

7 RMP resource management plan 

8 RMPA resource management plan amendment 

9 SARA Superfund Amendment and Reauthorization Act 

10 SF6 sulfur hexafluoride 

11 SiF4 silicon tetrafluoride 

12 SiO2 silicon dioxide 

13 SPCC Spill Prevention Control and Countermeasures 

14 SO2 sulfur dioxide 

15 SRP site redress plan 

16 s.u. standard units 

17 SVOC semivolatile organic compound 

18 SWPP Stormwater Pollution Prevention Plan 

19 SWU separative work unit 

20 TDS total dissolved solids 

21 TEDE total effective dose equivalent 

Tg teragram [1 x 1012 22 gram] 

23 TLD thermo luminescent dosimeters 

24 TSD treatment, storage, disposal 

25 TSP total suspended particulate 

26 U-234 a uranium isotope 

27 U-235 a uranium isotope 

28 U-236 a uranium isotope 

29 U3O8 variously known as uranium oxide, triuranium octoxide, or 

30 “yellowcake” 

31 UF4 uranium tetrafluoride 

32 UF6 uranium hexafluoride 

33 μCi/g microcuries per gram 

34 μg/L micrograms per liter 
xxxi 

1 ACRONYMS AND ABBREVIATIONS 

2 (continued) 

μg/m3 3 microgram per cubic meter 

4 UNFCCC United Nations Framework Convention on Climate Change 

5 UO2 uranium oxide or uranium dioxide 

6 UO2F2 uranyl oxyfluoride 

7 USACE U. S. Army Corps of Engineers 

8 USCB U.S. Census Bureau 

9 USEC U.S. Enrichment Corporation 

10 USFWS U.S. Fish and Wildlife Service 

11 USGS U.S. Geological Survey 

12 UWB underground water basin 

13 VA volt-ampere 

14 VOC volatile organic compound 

15 WCS Waste Control Specialists 

16 WIPP Waste Isolation Pilot Plant 

17 

 1-1 

1 1.0 INTRODUCTION 

2 1.1 Background 

3 Nuclear reactor fuel requires uranium with a higher proportion of the uranium-235 (U-235) 

4 isotope than is found in naturally occurring uranium (approximately 0.7 percent by weight). To 

5 increase the portion of U-235 isotopes in the fuel, an enrichment process is used. Uranium in 

6 the form of uranium hexafluoride (UF6) is the feed for the enrichment process, and depleted 

7 uranium hexafluoride (DUF6) is a byproduct of the process. During enrichment, the U-235 is 

8 extracted from a portion of the natural uranium in order to concentrate the U-235 into nuclear 

9 fuel. This lowers the concentration of U-235 in the remainder of the material so that its 

10 proportion is lower than the 0.7 percent by weight found in natural uranium (DOE, 2004). The 

11 UF6 with an increased concentration of U-235 is known as “enriched uranium”. The UF6 with a 

12 reduced concentration of U-235 is referred to as DUF6, which is primarily stored at the 

13 enrichment facilities. DUF6 is considered source material. Source material licensees are 

14 regulated under Title 10, Part 40, of the Code of Federal Regulations (10 CFR 40), in 

15 accordance with the Atomic Energy Act of 1954, as amended. 

16 Forecasts of operating nuclear-generating capacity suggest a continuing demand for uranium 

17 enrichment services both in the United States and abroad. Four new commercial enrichment 

18 plants in the U.S. are either in planning, construction, or start-up-phases, and the amounts of 

19 DUF6 are projected to increase. Although there are potential beneficial uses for depleted 

20 uranium (DU), the current need for DU is low compared to the existing inventory, and the 

21 potential for significant commercial demand is considered to be low. The Defense Nuclear 

22 Facilities Safety Board (DNFSB) has reported that long-term storage of DU in the UF6 form 

23 represents a potential chemical hazard if not properly managed, and conversion to more-stable 

24 DU oxides is preferable to continued long-term storage (NRC, 2005). Because significantly 

25 increased use of DU is not expected, this material will likely require disposal. DU can be 

26 disposed of as low level (radioactive) waste (LLW). 

27 In 1998, Congress directed the U.S. Department of Energy (DOE) to construct DU deconversion 

28 facilities next to the existing gaseous diffusion uranium enrichment plants in Piketon 

29 (Portsmouth), Ohio and Paducah, Kentucky. The Portsmouth, Ohio facility began operating in 

30 October, 2010. The Kentucky plant is expected to be operational in 2011. When both are fully 

31 operational, these plants will deconvert more than 700,000 metric tons (771,000 tons) of DUF6

32 currently stored by DOE. This inventory is projected to require 25 years to deconvert, once the 

33 facilities become operational. DOE plans to dispose of the 551,000 metric tons (607,200 tons) 

34 of deconverted DU as LLW (DOE, 2004). 

35 International Isotopes Fluorine Products, Inc. (IIFP) proposes to construct, operate, and 

36 decommission a facility for deconversion of DUF6 (IIFP, 2009a). The deconversion process is 

37 used to convert DU to more chemically stable uranium oxide compounds, such as triuranium 

38 octoxide (U3O8) or uranium dioxide (UO2), that are similar to the chemical form of natural 

39 uranium (DOE, 2004) and are generally suitable for disposal as LLW. 

40 High-purity silicon tetrafluoride (SiF4) and boron trifluoride (BF3) would be manufactured in the 

41 IIFP facility from the fluorine derived from the deconversion of DUF6. The fluoride gas products 

42 are valuable for applications in the electronic, solar panel, and semi-conductor markets. 

43 Anhydrous hydrogen fluoride (AHF), which is not produced by the DOE facilities described 
 1-2 

1 above, is another by-product of the deconversion process, which is used for various industrial 

2 applications (IIFP, 2009a). 

3 The U.S. Nuclear Regulatory Commission (NRC) staff has prepared this Draft Environmental 

4 Impact Statement (EIS) in response to an application submitted by IIFP for a license that would 

5 allow the construction, operation, and decommissioning of a commercial facility for 

6 deconversion of DUF6 in Lea County, New Mexico. 

7 The NRC’s Office of Federal and State Materials and Environmental Management Programs 

8 has prepared this draft EIS as required by 10 CFR 51, “Environmental Protection Regulations 

9 for Domestic Licensing and Related Regulatory Functions.” The NRC’s regulations under 

10 10 CFR 51 implement the requirements of the National Environmental Policy Act of 1969, as 

11 amended (NEPA) (Public Law 91-190). NEPA requires Federal agencies to prepare an EIS for 

12 every major federal action significantly affecting the quality of the human environment. 

13 Source material licenses, such as the one requested for the IIFP facility, are regulated under 

14 10 CFR 40. This licensing action is considered a major federal action because it may 

15 significantly affect the quality of the human environment consistent with 10 CFR 51, and must 

16 therefore meet the requirements of the NEPA for an EIS. The NRC staff has prepared this draft 

17 EIS to evaluate the potential environmental impacts 

18 of the proposed IIFP facility and reasonable 

19 alternatives to the proposed action. 

20 1.2 Proposed Action 

21 The proposed action is for the NRC to grant IIFP a 

22 license (under 10 CFR 40, “Domestic Licensing of 

23 Source Material”) to construct, operate, and 

24 decommission a facility to deconvert commercially 

25 generated DUF6 to depleted uranium dioxide 

26 (DUO2) and other deconversion products. IIFP 

27 would own the facility and be responsible for its 

28 operation and performance. If the NRC issues a 

29 license to IIFP under the provisions of the Atomic 

30 Energy Act of 1954, as amended, the license would 

31 authorize IIFP to possess and use special nuclear 

32 material, source material, and byproduct material at 

33 the proposed IIFP facility for a period of 40 years in 

34 accordance with the NRC’s regulations in 

35 10 CFR 40. The scope of activities to be conducted 

36 under the license would include the construction, 

37 operation, and decommissioning of the proposed 

38 IIFP facility. 

39 If issued a license by NRC, IIFP has proposed that 

40 the IIFP facility, comprising 16 hectares (ha) 

41 (40 acres [ac]) would be located within a 259-ha 

42 (640-ac) section in Lea County, near Hobbs, New 

43 Mexico. This parcel of land which was previously 

44 publicly-owned and comprises open range land 

45 used for grazing as well as overhead transmission 

Potential Beneficial Uses of DU 

• Further enrichment – DU can be used 

as feedstock for uranium enrichment. 

The low cost of uranium ore and 

postponed deployment of advanced 

enrichment technology have indefinitely 

delayed this application. 

• Nuclear reactor fuel – DU can be mixed 

with plutonium oxide from 

decommissioned nuclear weapons to 

make mixed oxide fuel (typically about 

6 percent plutonium oxide and 

94 percent depleted uranium oxide) for 

commercial power reactors. 

• Down-blending highly-enriched uranium 

– Nuclear disarmament treaties allow 

the down-blending of some weaponsgrade highly enriched uranium with DU 

to make commercial reactor fuel. 

• Munitions – DU metal can be used for 

tank armor and armor-piercing 

projectiles. 

• Biological shielding – DU metal has a 

high density, which makes it suitable for 

shielding from x-rays or gamma rays for 

radiation protection. 

• Counterweights – Because of its high 

density, DU has been used to make 

small but heavy counterweights. 

Source: NRC, 2005 
 1-3 

1 lines and underground petroleum pipelines, has been conveyed from the State of New Mexico 

2 to Lea County and, ultimately, to IIFP for construction and operation of the proposed facility. 

3 The IIFP initial (Phase 1) plant would include two main chemical processes that, when 

4 integrated, will comprise the Fluorine Extraction Process and Depleted Uranium Deconversion 

5 Plant (FEP/DUP). The potential future Phase 2 facility expansion would provide additional 

6 deconversion capability. 

7 Construction of the IIFP facility is expected to begin in 2012 and operations would begin in late 

8 2013. The construction for the Phase 2 expansion, which is not part of the current license 

9 application but is anticipated, is expected to begin in 2015 and full operations would begin in 

10 late 2016. At the end of its useful life, the IIFP FEP/DUP plant would be decommissioned 

11 consistent with the plan developed and submitted to NRC in the IIFP License Application. 

12 IIFP expects to capture beneficial byproducts as result of the deconversion process, including 

13 SiF4, BF3, and AHF. IIFP’s license application states that IIFP also intends to convert DUF6 to 

14 chemically stable compounds discussed in Section 1.1 above, for disposal. Additional details, 

15 including volumes of nuclear material, are discussed in Section 1.3. 

16 1.3 Purpose and Need for the Proposed Action 

17 The proposed action under consideration by the 

18 NRC is a license application to construct, operate, 

19 and decommission a facility to deconvert DUF6 into 

20 depleted uranium oxides for disposal. Additionally 

21 the process will recover fluoride products for 

22 commercial sale. With the existing inventory of 

23 stockpiled depleted uranium and four new 

24 commercial enrichment plants in the United States 

25 expected to be operating within the next few years, 

26 there is a need to deconvert the quantity of DUF6

27 that exists and would be produced at these 

28 enrichment facilities. Without a deconversion facility, 

29 DUF6 would continue to be stored, primarily at 

30 commercial uranium enrichment facilities in the 

31 United States, typically in 12.7-metric ton (14-ton) 

32 cylinders. Although DUF6 could be transferred to 

33 DOE for deconversion for a fee, DOE’s existing 

34 inventory of DUF6 is not projected to be deconverted 

35 for 25 years. The proposed IIFP facility should be 

36 capable of deconverting up to 3.4 million kilograms 

37 (kg) (7.5 million pounds, or 3,750 tons) per year of 

38 DUF6, (NRC, 2010a) which would be approximately 

39 one-tenth of the DUF6 that is projected to be 

40 produced annually in the United States by 

41 commercial enrichment facilities. The annual 

42 capacity of 3.4 million kg (3,750 tons) per year 

43 equates to about 9,340 kg/day (10.3 tons/day) on 

44 average. 

The NRC Environmental and Safety 

Reviews 

The focus of an EIS is a presentation of 

the potential environmental impacts of the 

proposed action and reasonable 

alternatives. In addition to meeting its 

responsibilities under NEPA, the NRC 

prepares a Safety Evaluation Report 

(SER) to analyze the safety of the 

proposed action and assess its 

compliance with applicable NRC 

regulations. 

The safety and environmental reviews are 

conducted in parallel. Although there is 

some overlap between the content of an 

SER and that of an EIS, the intent of the 

documents is different. To aid in the 

decision process, the EIS provides a 

summary of the more detailed analyses 

included in the SER. For example, the 

EIS does not address how accidents are 

prevented; rather, it addresses the 

environmental impacts that could result 

should an accident occur. Much of the 

information describing the affected 

environment in the EIS also is applicable 

to the SER (e.g., demographics, geology, 

and meteorology). 

Source: NRC, 2005 
 1-4 

1 IIFP is proposing to perform the following activities: 

2 • Construct, operate, maintain, and decommission the proposed facility. 

3 • Receive full and return empty DUF6 cylinders from various commercial enrichment 

4 facilities. 

5 • Transport marketable deconversion byproducts to end users. 

6 • Transport depleted UO2 for LLW disposal or other potential disposition. 

7 IIFP is planning, but has not formally submitted an application for, an expansion of the facility. 

8 Expansion and operation of the expanded facility (Phase 2) would be a reasonably foreseeable 

9 action and is evaluated as a cumulative impact in this draft EIS. 

10 Activities that do not constitute construction under 10 CFR 40 and 51 are those that do not have 

11 a reasonable nexus to radiological health and safety or the common defense and security, and 

12 could include clearing of the facility area, grading, installation of drainage and erosion control 

13 and other environmental mitigation measures, and construction of access roads. These 

14 “preconstruction” activities are evaluated in this draft EIS as cumulative impacts because they 

15 are expected to occur independently of the proposed licensing action by NRC. 

16 1.4 Scope of this Environmental Analysis 

17 On December 30, 2009, IIFP submitted an application to the NRC (IIFP, 2009b), seeking a 

18 license to construct, operate, and decommission a facility for deconversion of DUF6. As part of 

19 that license application, IIFP submitted an Environmental Report (ER) (IIFP, 2009a) for the 

20 proposed facility. 

21 On February 24, 2010, the NRC accepted the IIFP 

22 application for formal review (NRC, 2010b). A safety 

23 review team and an environmental review team are 

24 conducting both safety and environmental reviews of 

25 the license application. To fulfill its responsibilities 

26 under NEPA, the NRC staff has prepared this draft 

27 EIS to analyze the potential environmental impacts of 

28 the proposed IIFP facility, and of reasonable 

29 alternatives to the proposed action. The scope of this 

30 draft EIS includes consideration of both radiological 

31 and nonradiological (including chemical) impacts 

32 associated with the proposed action and the 

33 reasonable alternatives. The draft EIS also addresses 

34 the potential environmental impacts of transportation. 

35 It addresses cumulative impacts to physical, 

36 biological, and socioeconomic resources. In addition, 

37 it identifies monitoring and mitigation activities. This 

38 draft EIS is the result of the NRC staff’s review of the IIFP facility license application, the ER, 

39 information obtained from the NRC staff’s independent research, and IIFP’s responses to 

40 Requests for Additional Information (RAIs). This review has been closely coordinated with the 

41 NRC staff’s development of the Safety Evaluation Report (SER). 

Scoping 

Scoping is an early and open part of the 

NEPA process designed to help determine 

the range of actions, alternatives, and 

potential impacts to be considered in the 

EIS, and to identify significant issues 

related to the proposed action. In addition 

to the public scoping process, the NRC 

solicits input from State, local, and other 

Federal agencies, and potentially affected 

Native American Tribes in order to focus 

on issues of genuine concern. 
 1-5 

1 1.4.1 Scoping Process and Public Participation Activities 

2 The NRC regulations in 10 CFR 51 contain requirements for defining the scope of an EIS and 

3 identifying issues that should be addressed in depth. The scoping process was used to solicit 

4 public and agency input to identify those issues to be discussed in the EIS in detail, and to 

5 identify those issues that are either beyond the scope of this draft EIS or are not directly 

6 relevant to the assessment of potential impacts from the proposed action. 

7 As part of the NRC staff’s environmental review and in compliance with 10 CFR 51.26 and 

8 10 CFR 51.27, the scoping process was initiated on July 15, 2010, with the publication in the 

9 Federal Register (FR) of a Notice of Intent (NOI) to prepare an EIS (NRC, 2010a). The NOI 

10 summarized the NRC’s plans to prepare an EIS and presented background information on the 

11 proposed IIFP facility. The NOI also invited comments on the appropriate scope of issues to be 

12 considered and announced NRC’s plan to hold a public scoping meeting. The public scoping 

13 comment period ended on August 30, 2010. 

14 On July 29, 2010, the NRC staff held a public scoping meeting in Hobbs, New Mexico, to 

15 receive oral and written comments from interested parties. The public scoping meeting began 

16 with the NRC staff providing a description of the NRC’s roles, responsibilities, and mission. A 

17 brief overview of the licensing process was followed by a description of the environmental 

18 review process and a discussion of how the public can effectively participate. Most of the 

19 meeting was reserved for attendees to ask questions and make comments on the scope of the 

20 environmental review. Prior to the public scoping meeting, the NRC staff hosted an informal 

21 “open house” for those who wished to attend. The open house provided members of the public 

22 with an opportunity to speak informally with individual NRC staffers. 

23 Scoping meeting attendees submitted oral and written comments. Additional comments were 

24 received during the scoping period via electronic and postal mail. As a result of the scoping 

25 process, the following public comments were received: 

26 • Expressions of general support for the IIFP facility. 

27 • Opposition to locating the IIFP facility, or any facility that deals with nuclear byproducts, 

28 over an aquifer and in an area with a history of earthquakes. 

29 • Expressions of support for the project, specifically for the jobs that would be created by 

30 construction and operation of the facility and the positive economic impact it would have 

31 on the region. 

32 • Support for the project as a way to use depleted uranium that will be generated at the 

33 nearby URENCO USA uranium enrichment plant, which would otherwise have to be 

34 stored or disposed of as DUF6 waste. 

35 • Concern that a disposal path for waste from the IIFP facility to the Andrews County, 

36 Texas, nuclear waste disposal facility is an unsafe disposal path. 

37 • A statement that the EIS should include the aquifer map that has been prepared by 

38 Mesa Water Company. 

39 • A statement that the EIS should address the seismic hazards that have been indicated 

40 for Lea County by the U.S. Geological Survey. 
 1-6 

1 Appendix A (Scoping Summary) of this draft EIS includes the scoping summary report that 

2 summarizes the comments received during the scoping process as required in 

3 10 CFR 51.29(b). 

4 The NRC staff has requested information regarding the scope of its environmental review from 

5 the New Mexico State Historic Preservation Officer (NM SHPO) and Native American Tribes 

6 identified by the NM SHPO. The NRC staff has also asked for comment from the U.S. Fish and 

7 Wildlife Service (USFWS) and the New Mexico Department of Game and Fish (NMGF) 

8 regarding threatened and endangered species. The NRC staff also sought information from the 

9 New Mexico Energy, Minerals, and Natural Resources Department. The NRC staff has not 

10 identified any cooperating agencies for the preparation of this draft EIS. 

11 Information received from these agencies and potentially affected Native American Tribes was 

12 important in assessing impacts to cultural and ecological resources and determining if there 

13 were environmental justice concerns. Correspondence with the NM SHPO and potentially 

14 affected Native American Tribes (Apache Tribe of Oklahoma, Comanche Tribe of Oklahoma, 

15 Kiowa Tribe of Oklahoma, Mescalero Apache Tribe, Ysleta del Sur Pueblo, and Shawnee Tribe) 

16 is included in Appendix B (Consultation/Correspondence) of this draft EIS. Correspondence 

17 with the USFWS and the NMGF is also included in Appendix B of this draft EIS. 

18 1.4.2 Issues Studied in Detail 

19 In the (July 15, 2010) NOI, the NRC staff tentatively identified issues to be studied in detail as 

20 they relate to implementation of the proposed action. These issues were: 

21 • Land Use: plans, policies, and controls. 

22 • Historic and Cultural Resources: archaeological sites (historic and prehistoric 

23 archaeological artifacts/features and information), architectural historic resources 

24 (structures and districts), and historic properties of traditional religious significance to the 

25 Native American Tribes. 

26 • Visual Resources: the visual setting on and near the proposed site. 

27 • Transportation: transportation modes, routes, quantities, and risk estimates. 

28 • Geology and Soils: physical geography, topography, geology, and soil characteristics. 

29 • Water Resources: surface water and groundwater hydrology, water use and quality, and 

30 the potential for degradation. 

31 • Ecology: wetlands; aquatic, and terrestrial economically or recreationally important 

32 species; and threatened and endangered species. 

33 • Air Quality: meteorological conditions, ambient air quality, pollutant sources, and the 

34 potential for degradation. 

35 • Socioeconomics: demography, economic base, labor pool, housing, transportation, 

36 utilities, public services and facilities, and education. 

37 • Environmental Justice: potential disproportionately high and adverse impacts to minority 

38 or low-income populations. 

39 • Noise: noise receptors and potential noise impacts in the vicinity of the proposed facility. 
 1-7 

1 • Public and Occupational Health: potential public and occupational consequences from 

2 construction, routine operation, transportation, and credible accident scenarios (including 

3 natural events). 

4 • Waste Management: types of wastes expected to be generated, handled, and stored. 

5 • Cumulative Effects: impacts from past, present and reasonably foreseeable future 

6 actions at and near the site. 

7 After completion of the scoping process, the NRC staff determined that these issues are still 

8 appropriate for detailed study in the EIS, for the following reasons: (1) the fact that the 

9 resources identified for study are present and have the potential to be impacted by the action; 

10 and (2) the fact that participants in the scoping process raised many of the same issues, 

11 including perceived beneficial impacts, that were identified in the NOI. Therefore, the initial 

12 issues identified in the July 5, 2010, NOI for consideration were carried forward for further 

13 analysis. In addition, the NRC staff identified no new issues that require detailed study in the 

14 EIS. 

15 1.4.3 Issues Beyond the Scope of the EIS 

16 The purpose of an EIS is to assess the potential environmental impacts of a proposed federal 

17 action in order to assist in an agency’s decision-making process. In this case, the NRC’s 

18 decision is whether to grant the license. Some issues and concerns raised during the scoping 

19 process are not relevant to the EIS because they are not directly related to the environmental 

20 impact analysis or to the NRC’s decision. The lack of an in-depth discussion in the EIS, 

21 however, does not mean that an issue or concern lacks value. Issues beyond the scope of the 

22 EIS either may not yet be at the point where they can be resolved, or are more appropriately 

23 discussed and decided in other venues. Appendix A includes a discussion of issues identified 

24 during scoping that are beyond the scope of the EIS. 

25 Some of the issues raised during the public scoping process for the proposed facility are outside 

26 the scope of the EIS, but are analyzed in the SER. For example, health and safety issues are 

27 considered in detail in the SER prepared by the NRC staff for the proposed action and are 

28 summarized in the EIS. The EIS and the SER may cover some of the same topics and may 

29 contain similar information, but the analysis in the EIS is focused on the assessment of potential 

30 environmental impacts. In contrast, the SER deals primarily with safety evaluations and 

31 procedural requirements or license conditions to ensure the health and safety of workers and 

32 the general public. 

33 1.5 Applicable Statutory and Regulatory Requirements 

34 This section summarizes compliance with legal/regulatory requirements, including permits, 

35 licenses, and other authorizations, and approvals at the Federal, State, and local level, which 

36 would be necessary for the proposed IIFP facility’s construction, operation, and 

37 decommissioning, should NRC grant the license. 

38 1.5.1 State of New Mexico Laws and Regulations 

39 Certain Federal environmental requirements, including some discussed earlier, have been 

40 delegated by the Federal agencies to State authorities for implementation, enforcement, or 

41 oversight. In addition, the State of New Mexico has its own state laws, and Lea County has its 

42 own local laws. Table 1-1 provides a list of applicable New Mexico laws, regulations, and 
 1-8 

1 Table 1-1. Applicable State of New Mexico Laws, Regulations, and Agreements 

Law, Regulation, or 

Agreement Citation Requirements 

New Mexico Wildlife 

Conservation Act 

NMSA, Chapter 17, Game and 

Fish and Outdoor Recreation, 

Article 2, Hunting and Fishing 

Regulations, and Part 3, 

Wildlife Conservation Act 

Requires a permit and coordination if 

a project may disturb habitat or 

otherwise affect threatened or 

endangered species. There are no 

known, or anticipated (other than 

transient), threatened or endangered 

species on the proposed site. 

New Mexico Raptor 

Protection Act 

NMSA, Chapter 17, Game and 

Fish and Outdoor Recreation, 

Article 2 Part 14, Hawks, 

Vultures, and Owls; taking, 

possessing, trapping, 

destroying, maiming, or selling 

prohibited except by permit; 

penalties 

The act makes it unlawful to take, 

attempt to take, possess, trap, 

ensnare, injure, maim, or destroy 

individuals of any species of hawk, 

owl, or vulture.

New Mexico Cultural 

Properties Act 

NMSA, Chapter 18, Libraries 

and Museums, Article 6, 

Cultural Properties 

The act defines the NM SHPO role 

and responsibilities, and establishes 

requirements to prepare an 

archaeological and historic survey 

and consult with NM SHPO. A 

cultural resources inventory was 

completed for the project. The survey 

for cultural resources consisted of a 

file search, field inventory, and 

inventory report. A negative 

declaration was prepared by the 

applicant and the NM SHPO 

concurred. NRC staff has not yet 

completed its consultation with the 

NM SHPO.

New Mexico Occupational 

Safety and Health 

NMSA, Chapter 50, 

Employment Law 

NMAC Title 11, Labor Workers 

Compensation, Chapter 5, 

Occupational Safety and 

Health 

The act and implementing regulations 

establish State requirements for 

assuring safe and healthful working 

conditions for every employee. 

These State regulations are being 

followed to ensure any additional 

requirements beyond the Federal 

Occupational Safety and Health 

Administration (OSHA) regulations 

are adequately addressed.

New Mexico Air Quality 

Control Act 

NMSA, Chapter 74, 

Environmental Improvement, 

Article 2, Air Pollution 

NMAC Title 20, Environmental 

Protection, Chapter 2, Air 

Quality 

The act and implementing regulations 

establish air quality standards and 

permit requirements that must be met 

prior to construction or modification of 

an emissions source. These 

regulations also define requirements 

for an operating permit for major 

producers of air pollutants and 

impose emission standards for 

hazardous air pollutants. 2 
 1-9 

Table 1-1. Applicable State of New Mexico Laws, Regulations, and Agreements 

(Continued) 

Law, Regulation, or 

Agreement Citation Requirements 

New Mexico Radiation 

Protection Act 

NMSA, Chapter 74, 

Environmental Improvement, 

Article 3, Radiation Control 

NMAC, Title 20, 

Environmental Protection, 

Chapter 3, Radiation 

Protection 

The act and implementing regulations 

establish State requirements for 

worker protection from radiation 

sources. Because the facilities would 

be privately owned, the State will 

require registration of security X-ray 

machines.

New Mexico Hazardous 

Waste Act (see note 

below) 

NMSA, Chapter 74, 

Environmental Improvement, 

Article 4, Hazardous Waste 

NMAC Title 20, Environmental 

Protection, Chapter 4, 

Hazardous Waste 

The act and implementing regulations 

establish State standards for the 

management of hazardous wastes. 

The New Mexico Environmental 

Development (NMED) regulations 

imposed on a generator or on a 

treatment, storage, or disposal (TSD) 

facility, vary according to the type and 

quality of material or waste 

generated, treated, stored, or 

disposed. The method of treatment, 

storage, or disposal also impacts the 

extent and complexity of the 

requirements. 

The IIFP plant may generate 

hazardous waste during construction 

and operation. These hazardous 

wastes will be temporarily stored and 

shipped off site for treatment and 

disposal in accordance with 

applicable NMAC and Resource 

Conservation and Recovery Act 

(RCRA) requirements. 

Note: Source, special nuclear, or by-product, material as defined by the Atomic Energy Act of 1954

is specifically excluded from the definition of a solid waste and therefore is not a hazardous waste 

regulated under RCRA or NMSA, Chapter 74, Article 9, Solid Waste Act and implementing 

regulations at NMAC Title 20, Chapter 9, Solid Waste. The IIFP facilities would not store (other than 

temporarily) or dispose of hazardous waste on site. IIFP may need a permit for operation of its 

Environmental Protection Process under the authority of RCRA or the New Mexico Hazardous 

Waste Act. 

New Mexico Radioactive 

and Hazardous Materials 

Act

NMSA, Chapter 74 

Environmental Improvement,, 

Article 4, Article 4A, 

Radioactive and Hazardous 

Materials

The act establishes a system of 

assuring public health and safety with 

regard to safe treatment, disposal, and 

transportation of radioactive and 

hazardous materials and coordinates 

efficient and timely emergency 

response to accidents and natural 

disasters with a centralized and 

coordinated source of information. 
 1-10 

Table 1-1. Applicable State of New Mexico Laws, Regulations, and Agreements 

(Continued) 

Law, Regulation, or 

Agreement Citation Requirements 

New Mexico Hazardous 

Chemicals Information 

Act 

NMSA, Chapter 74 

Environmental Improvement,, 

Article 4E-1, Hazardous 

Chemicals Information Act 

The act implements the hazardous 

chemicals information and toxic 

release reporting requirements of the 

Emergency Planning and Community 

Right-to-Know Act of 1986 (Superfund 

Amendment and Reauthorization Act

[SARA] Title III) for facilities such as 

the proposed IIFP plant. 

New Mexico Water 

Quality Act 

NMSA, Chapter 74, 

Environmental Improvement, 

Article 6, Water Quality 

NMAC Title 20, Environmental 

Protection, Chapter 6, Ground 

and Surface Water Protection 

The act and implementing regulations 

establish water quality standards and 

apply to permitting prior to 

construction, during operation, and 

decommissioning, if necessary. 

Generally, a permit is required for 

discharges that could affect surface or 

groundwater. Any impoundments for 

sewage treatment facilities, cooling 

water or other discharges that exceed 

the standards listed in 20.6.2.3103 

NMAC or contain toxic constituents 

require a permit. No site-specific 

issues have been identified which 

would preclude permitting of needed 

water control and treatment facilities at 

the IIFP Site. 

New Mexico Groundwater 

Protection Act 

NMSA, Chapter 

74,Environmental 

Improvement, Article 6B, 

Groundwater Protection 

NMAC Title 20, Environmental 

Protection, Chapter 5, 

Petroleum Storage Tanks 

The act and implementing regulations 

establish State standards for 

protection of groundwater from leaking 

underground and above-ground 

storage tanks. 

New Mexico Night Sky 

Protection Act 

NMSA Chapter 74, 

Environmental Improvement, 

Article 12, Night Sky 

Protection 

The act establishes requirements to 

preserve and enhance the State’s dark 

sky while promoting safety, conserving 

energy and preserving the 

environment for astronomy. These 

requirements will be addressed during 

detailed design of the IIFP facility. 

Exchanges of State Trust 

Lands 

NMAC Title 19, Natural 

Resources and Wildlife, 

Chapter 2 State Trust Lands, 

Part 21, Land Exchanges 

The act establishes State standards 

and procedures for exchanges of 

lands held in trust, including 

consideration of cultural resources, 

natural resources, and wildlife. 
 1-11 

Table 1-1. Applicable State of New Mexico Laws, Regulations, and Agreements 

(Continued) 

Law, Regulation, or 

Agreement Citation Requirements 

New Mexico Endangered 

Plant Species Act 

NMAC Title 19, Natural 

Resources and Wildlife, 

Chapter 21, Endangered 

Plants 

The act establishes an endangered 

plant species list and rules for 

collection. There are no threatened or 

endangered plant species on the 

proposed IIFP site. 

Registration of Tanks NMAC, Title 20, 

Environmental Protection, 

Chapter 5, Petroleum Storage 

Tanks, Part 2, Registration of 

Tanks 

The regulations establish the State 

standards for the regulation of 

petroleum storage tanks. If needed at 

the IIFP facility, storage tanks would 

be designed in accordance with State 

requirements and registration 

application made. 

Drinking Water 

Regulations 

NMSA, Chapter 74, 

Environmental Improvement, 

Article 1, General Provisions, 

Sections 1-8 and 1-13.1, and 

Article 6 Water Quality 

NMAC Title 20, Environmental 

Protection, Chapter 7, 

Wastewater and Water Supply 

Facilities, Part 10 Drinking 

Water 

The acts require the establishment of 

drinking water standards for New 

Mexico. These standards are found at 

20.7.10 NMAC. The proposed facility 

would use an on-site groundwater 

supply for all domestic water needs. 

Under the New Mexico drinking water 

regulations, the facility would be 

classified as a non-transient, noncommunity water supply system 

because it would regularly serve more 

than 25 people. 

Transportation and 

Highway 

NMAC Title 18, Transportation 

and Highways, Chapter 31, 

Classification and Design 

Standards, Part 6, State 

Highway Access Management 

Requirements 

The regulations establish State 

highway access management 

requirements that will protect the 

functional integrity of and investment 

in, the State highway system. 

Threatened and 

Endangered Species of 

New Mexico 

NMAC, Title 19, Natural 

Resources and Wildlife, 

Chapter 33, Endangered and 

Protected Species 

The regulations establish the State of 

New Mexico’s list of threatened and 

endangered wildlife species. There 

are no threatened or endangered 

species on the proposed plant site. 

Source: IIFP, 2009a 

1 

2 agreements, whereas Table 1-2, includes anticipated requirements of those agency laws, 

3 regulations, and policies where federal agencies have delegated authority to the state, and 

4 those laws, regulations and policies administered under autonomous state legal authority. New 

5 Mexico Statutes Annotated (NMSA) and implementing regulations in New Mexico Administrative 

6 Code (NMAC) are listed numerically by citation (primarily by NMSA statutory Chapter, Article, 

7 and Section; or secondarily by NMAC regulation Title, Chapter, and Part). 

8 1.5.2 Lea County and Local Laws and Regulations 

9 Lea County requires county permits for most major construction activity, but these permits are 

10 issued in accordance with subdivision ordinances at the time when parcel subdivision is 
 1-12 

1 approved; thus most other parcels where subdivision is not requested are not restricted by local 

2 subdivision ordinances and do not require county permits for construction activity. In other 

3 words, building permits for foundations, structures, electrical/mechanical systems, roadways, or 

4 temporary construction-related structures are not required by local ordinance, except where 

5 subdivision regulations apply. Because subdivision is not necessary for the IIFP facility, Article 

6 8 of Lea County’s subdivision regulations (or other local regulations) do not apply. 

7 1.5.3 Permit and Approval Status 

8 IIFP would prepare and submit several construction and operating permit applications, and 

9 regulatory approval and/or permits would be received prior to preconstruction, construction, or 

10 facility operation. It is IIFP’s responsibility to adhere to necessary permit application schedules 

11 and permit requirements prior to preconstruction, construction, or operation, as applicable. 

12 Tables 1-2 and 1-3 list the required Federal and State construction and operation permits and 

13 their status. 

14 1.5.3.1 Permits, Licenses, Authorizations, Approvals, and Consultations Required for 

15 Preconstruction and Construction 

16 Table 1-2 identifies the anticipated legal/regulatory requirements for site preparation and 

17 construction of the proposed IIFP facility. These include any permits, licenses, authorizations, 

18 approvals, or other regulatory entitlements required for constructing the proposed facility. 

19 Table 1-2 also identifies the status of these possible requirements. 

20 1.5.3.2 Permits, Authorizations, Approvals and Consultations Required for Operations 

21 Table 1-3 identifies the anticipated legal/regulatory requirements for operation of the proposed 

22 IIFP facility. Table 1-3 also identifies the status of these possible requirements. 

23 1.6 Cooperating Agencies 

24 No Federal, State, or local agencies or Native American Tribes have requested to be 

25 considered as cooperating agencies in the preparation of this draft EIS. 

26 1.7 National Historic Preservation Act of 1966 and the Endangered Species Act of 

27 1973 Consultations 

28 The consultation requirements of the National Historic Preservation Act (NHPA) and 

29 Endangered Species Act (ESA) apply to the NRC with regard to the proposed IIFP facility 

30 licensing action. Consultation correspondence is provided in Appendix B 

31 (Consultation/Correspondence). 

32 1.7.1 National Historic Preservation Act of 1966 Section 106 Consultation 

33 NRC staff initiated the NHPA Section 106 consultation process by letter dated July 2, 2010. 

34 NRC staff contacted the NM SHPO regarding information about historic sites and cultural 

35 resources that could potentially be affected by the proposed IIFP facility. In the letter, the NRC 

36 staff identified the Area of Potential Effect (APE) for the proposed project and requested 

37 information from the NM SHPO related to the proposed action’s potential to affect cultural 

38 resources. Also in the letter, the NRC staff stated its intent to use the NEPA process to comply 

39 with Section 106 of the NHPA as allowed in 36 CFR 800.8. The NM SHPO replied on July 15, 
1-13 

Table 1-2. Legal/Regulatory Requirements and Authorizations for Site Preparation and Construction of the Proposed 1 

IIFP Facility 2 

Agency 

Legal/Regulatory 

Authority Activity Covered Status 

Permits, Licenses, 

Authorizations, 

Approvals, and 

Consultations 

Identification Permit Dates 

Federal – NRC 10 CFR 40 Domestic licensing of 

source material 

IIFP’s application accepted February 24, 2010; pending NRC review ongoing 

License Application (LAIFP-001, IFP-002, & ER-IFP-001) 

pending 

Federal – EPA Region 6 and State – NMED 

CWA 33 USC 1251 

Construction Stormwater General Permit and NOI 

2nd Qtr. 2011; Stormwater Pollution Prevention Plan and NOI (IIFP) 

pending pending 

Federal – USACE CWA 

33 USC 1251 

Fill of wetlands Applicability of 

depressions onsite determined by consultation (IIFP) 

Jurisdictional Determination complete (no wetlands present; no permit necessary) 

No permit needed; no jurisdictional wetlands or waters of the U.S. are present. 

State – NMDOT District 2 

NMAC Title 18, Chapter 31, Part 6, State Highway Access Management Requirements 

Highway Access Management Permit for NM 483 and/or US 62/180 driveway entry and/or second (emergency) access point 

2nd Qtr. 2011 (IIFP or Lea County). The District 2 permit, if issued, would stipulate any required highway safety enhancements. 

pending pending 

3 
1-14 

Table 1-2. Legal/Regulatory Requirements and Authorizations for Site Preparation and Construction of the Proposed 1 

IIFP Facility (Continued) 2 

Agency Authority Activity Covered Status 

Permits, Licenses, 

Authorizations, 

Approvals, and 

Consultations 

Identification Permit Dates 

State – AQB 

Title 20 Chapter 2 Part 72 

Preconstruction and New Source Review 

Projected for 3rd Qtr. 2011(IIFP). A “Request for a No Permit Required Determination” for pre-licensing construction activities would be submitted. 

pending pending 

State – AQB 

Clean Air Act Title V & NESHAP 

NESHAP Permit (if needed; pending consultation with State AQB) 

Projected for 3rd Qtr. 

2011(IIFP), if needed 

pending pending 

State – NMRL/CID NMAC Title 14 Building permits for 

foundations, structures, and electrical / mechanical systems, as well as temporary construction-related structures 

Projected for 3rd Qtr. 

2011(IIFP), if needed 

pending pending 

State – PSTB Above Ground 

Storage Tank Registration 

Petroleum storage tanks (size, design specifications, and fuel type) 

Projected for 4th Qtr. 

2012 (IIFP) 

pending pending 

Source: IIFP, 2009a 3 EPA – U.S. Environmental Protection Agency; USACE – U.S. Army Corps of Engineers; NESHAP – National Emission Standards for Hazardous Air Pollution; 4 NHPA – National Historic Preservation Act; NMDOT – Department of Transportation; AQB – Air Quality Bureau; PSTB – Petroleum Storage Tank Bureau; NM 5 RL/CID – New Mexico Regulation and Licensing/Construction Industries Division. 6 

7 
1-15 

Table 1-3. Legal/Regulatory Requirements and Authorizations for Operation of the Proposed IIFP Facility 1 

Agency Authority Activity Covered Status 

Permits, Licenses, 

Authorizations, 

Approvals, and 

Consultations 

Identification Permit Dates 

Federal – NRC 10 CFR 40 Domestic licensing of 

source material 

Accepted February 24, 2010 (IIFP); pending review 

License Application (LA-IFP-001, LA-IFP-002, & ER-IFP-001) 

pending 

Federal – NRC 10 CFR 73 and 74 Domestic licensing of 

physical protection and material control / accountability 

IIFP’s application accepted February 24, 2010; pending NRC review 

License Application (LA-IFP-001, IFP-002, & ER-IFP-001) 

pending 

Federal – NRC 10 CFR 20 Standards for 

Protection Against Radiation 

IIFP’s application accepted February 24, 2010; pending NRC review 

License Application (LA-IFP-001, IFP-002, & ER-IFP-001) 

pending 

Federal – EPA Region 6 and NMED 

CWA 33 USC 1251 

Multi-sector Industrial Stormwater General Permit 

Projected for 2nd Qtr. 2011 (IIFP)

pending Multi-sector Industrial General Permit (IIFP) 

pending 

Federal – EPA Region 6 (and possibly HWB) 

RCRA Operations Permit 

EPA Operation If necessary, IIFP 

would submit 4th Qtr. 2011 (IIFP) 

pending (if necessary) 

pending 

Federal – EPA and HWB 

RCRA EPA Waste Activity, 

EPA ID Number, for storage and use of hazardous chemicals 

2nd Qtr. 2012 (IIFP) Small Quantity 

Generator pending 

pending 

State – NMED AQB 

Clean Air Act Title V Air Operation Permit (if 

needed; pending consultation with State)

Projected for 3rd Qtr. 2011 (IIFP); A Title V operating permit is not likely necessary based on emissions being below Federal and State regulatory standards. 

pending pending 
1-16 

Table 1-3. Authorizations Legal/Regulatory Requirements for Operation of the Proposed IIFP Facility (Continued) 1 

Agency Authority Activity Covered Status 

Permits, Licenses, 

Authorizations, 

Approvals, and 

Consultations 

Identification Permit Dates 

State – NMED AQB 

NESHAP (if needed; pending 

consultation with State)

Projected for 3rd Qtr. 2011 (IIFP) if needed. Anticipated emissions are below regulatory limits. 

pending pending 

State – HWB Hazardous 

Chemicals Information Act 

Hazardous Waste Permit 

Projected for 3rd Qtr. 2011 (IIFP) 

pending pending 

State – HWB Title 20, Chapter 4, 

Hazardous Waste 

EPA Waste Activity EPA ID Number 

Notification Form 8700-12 projected for 3rd Qtr. 2011 (IIFP) 

pending pending 

State – RCB NMSA, Chapter 74, 

Article 3, Radiation Control and Title 20, Chapter 3 

Machine-Produced Radioactivity (X-Ray Inspection) 

May be required for security contractor (not IIFP) 

pending pending 

State – DWB Safe Drinking Water 

Act (40 CFR 141, 142, 143; 07/01/2009) and 20-7.10 NMAC (10/15/2008) 

Drinking Water System Permit 

Projected for 2nd Qtr 2012 (IIFP) 

pending pending 

State – WQB Title 20 Chapter 6, 

Groundwater 

Groundwater Discharge Plan and Permit; Liquid Waste Permit 

Projected for 3rd Qtr. 2011 (IIFP) 

pending pending 

State – WQB NPDES NPDES Industrial 

Stormwater Permit 

Submit if required by 2nd Qtr. 2011 (IIFP) 

pending pending 

2 
1-17 

Table 1-3. Authorizations Legal/Regulatory Requirements for Operation of the Proposed IIFP Facility (Continued) 1 

Agency Authority Activity Covered Status 

Permits, Licenses, 

Authorizations, 

Approvals, and 

Consultations 

Identification Permit Dates 

State – RCB 

OSHA Regulations, 29 CFR 1910; Federal FD&C Act; New Mexico Radiation Control Act 

Required for x-ray security inspection machines 

Identify permit-holder by 1st Qtr. 2011 (IIFP); submit list of source equipment 2nd Qtr. 2012 (IIFP) 

Machine-produced radiation registration (X-Ray inspection) 

pending (possibly a separate contractor) 

State – Utah Low-Level 

Radioactive Waste Policy Act (Northwest Interstate Compact, Utah Code Title 19 Chapter 3) 

LLW disposal at Nuclear Solutions (if chosen) 

To be determined 

State – Washington Low-Level 

Radioactive Waste Policy Act (Northwest Interstate Compact, Compact for the State of Washington) 

LLW disposal at Hanford (Richland) (if chosen) 

To be determined 

State – Texas Low-Level 

Radioactive Waste Policy Act and Texas Radiation Control Act (Texas LLW Interstate Compact with Vermont) 

LLW disposal at Waste Control Specialists (if chosen) 

Would require approval from Rocky Mountain Compact 

Source: IIFP, 2009a 2 CWA – Clean Water Act; FD&C – Federal Food, Drug, and Cosmetic Act; DWB – Drinking Water Bureau; HWB – Hazardous Waste Bureau; RCB – Radiation 3 Control Bureau; WQB – Water Quality Bureau; NPDES – National Pollutant Discharge Elimination System; OSHA – Occupational Safety and Health 4 Administration. 5 

6 
 1-18 

1 2010, that the SHPO had no record of any cultural resources surveys having been conducted 

2 and outlined the process for completing a survey, undertaking tribal consultation, and 

3 completing the Section 106 consultation process. IIFP conducted an archeological 

4 reconnaissance survey of the proposed site (as explained in later chapters of this document) 

5 according to New Mexico’s Cultural Properties and Historic Preservation, Standards for Survey 

6 and Inventory (NMHPD, 2005). By letter dated October 14, 2010, the New Mexico 

7 Commissioner of Public Lands, following his review of IIFP’s cultural resources survey 

8 document, recommended “a finding of no effect/no cultural properties/no historic 

9 properties....There are no documented cultural properties within the APE when considering 

10 direct effects. Similarly, there are no registered cultural properties within the assumed, five-mile 

11 APE when considering indirect effects.” The NM SHPO concurred with the New Mexico 

12 Commissioner of Public Lands determination on October 25, 2010. 

13 Consultation under NHPA with Native American Tribes (listed below) was undertaken using a 

14 list maintained by the NM SHPO. The list is based partially on U.S. Indian Claims Commission 

15 data and also on an NM SHPO Historic Preservation Division (HPD) ethnographic study, the 

16 National Park Service's Native American Consultation Database, and Tribes that have notified 

17 NM SHPO directly that they wish to be consulted. Based on tribal information provided for Lea 

18 County, in July 2010, the NRC staff contacted the Tribes listed below and requested information 

19 on historically or culturally significant resources within the APE of the proposed facility. The 

20 NRC staff also contacted the NM SHPO tribal liaison (Appendix B). Correspondence between 

21 NRC staff and the responding tribes is provided in Appendix B. 

22 • Apache Tribe of Oklahoma 

23 • Comanche Tribe of Oklahoma 

24 • Kiowa Tribe of Oklahoma 

25 • Mescalero Apache Tribe 

26 • Ysleta del Sur Pueblo 

27 • Shawnee Tribe 

28 NRC staff will consider comments received from tribes concerning this draft EIS. Otherwise, the 

29 coordination that has been conducted in accordance with the NHPA is complete. 

30 1.7.2 Endangered Species Act of 1973 Section 7 Consultation 

31 The NRC staff consulted with the USFWS to comply with the requirements of Section 7 of the 

32 Endangered Species Act (ESA). On July 2, 2010, the NRC staff sent a letter to the USFWS 

33 (New Mexico Ecological Field Office) describing the proposed action and requesting a list of 

34 threatened and endangered species and critical habitats that could potentially be affected by the 

35 proposed action. The USFWS, in a letter dated August 10, 2010, provided general information 

36 about species of concern and critical habitat in New Mexico and Lea County, but made no site37 specific comments. In response to a verbal inquiry from the NRC staff, the NMGF responded in 

38 a letter dated June 21, 2011, with further information about wildlife habitat on the proposed IIFP 

39 site, recommendations for avoiding impacts to wildlife, and other best management practices 

40 (Appendix B). No federally threatened or endangered species or critical habitat have been 

41 identified on the proposed IIFP site to date; therefore formal Section 7 ESA consultation is not 

42 required for the NRC action (licensing) to occur. 
 1-19 

1 1.8 References 

2 (DOE, 2004) U.S. Department of Energy. 2004. Final Environmental Impact Statement for 

3 Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the 

4 Paducah, Kentucky, Site, DOE/EIS-0359. June 2004. ADAMS Accession No. ML 050380331. 

5 (IIFP, 2009a) International Isotopes Fluorine Products, Inc. 2009. Fluorine Extraction Process 

6 and Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A, ER7 IFP-001. December 27, 2009. ADAMS Accession No. ML100120758. 

8 (IIFP, 2009b) International Isotopes Fluorine Products. Inc. 2009. Fluorine Extraction Process 

9 and Depleted Uranium De-conversion Plant (FEP/DUP) License Application, Revision A, ER10 IFP-001. December 23, 2009. ADAMS Accession No. ML100630503. 

11 (NMHPD, 2005) New Mexico Historic Preservation Division, Department of Cultural Affairs. 

12 2005. New Mexico Register, Volume XVI, Number 15, Title 4, Cultural Properties and Historic 

13 Preservation; Chapter 10, Cultural Properties and Historic Preservation; Part 15, Standards for 

14 Survey and Inventory. Santa Fe, NM. August 15, 2005. ADAMS Accession No. ML112710497. 

15 (NRC, 2005) U.S. Nuclear Regulatory Commission. 2005. Environmental Impact Statement for 

16 the Proposed National Enrichment Facility in Lea County, New Mexico, NUREG-1790, Vol. 1. 

17 Washington, D.C. June 2005. ADAMS Accession No. ML051730238. 

18 (NRC, 2010a) U.S. Nuclear Regulatory Commission. 2010. Notice of Intent to Prepare an 

19 Environmental Impact Statement for the Proposed International Isotopes Uranium Processing 

20 Facility. July 8, 2010. ADAMS Accession No. ML101330539. 

21 (NRC, 2010b) U.S. Nuclear Regulatory Commission. 2010. Letter from Matt Bartlett (NRC) to 

22 John J. Miller (IIFP), “License Application for International Isotopes Fluorine Products, Inc. 

23 Facility – Acceptance Review (TAC No’s L32739 and L32740), February 23, 2010. ADAMS 

24 Accession No. ML100480302. 

25 

 2-1 

1 2.0 ALTERNATIVES 

2 This chapter describes and compares the proposed action and its alternatives. As discussed in 

3 Section 2.1, the proposed action is for IIFP to construct, operate, and decommission a DUF6

4 deconversion facility near Hobbs in Lea County, New Mexico. In this draft EIS; the NRC staff 

5 evaluates a reasonable range of alternatives to the proposed action, including alternative sites 

6 for the IIFP facility, alternative deconversion technologies, other DUF6 management options, 

7 and the no-action alternative. Under the no-action alternative, IIFP would not construct, 

8 operate, or decommission the proposed facility. Therefore, the no-action alternative provides a 

9 basis against which the potential environmental impacts of the proposed action are evaluated 

10 and compared. 

11 Section 2.1 presents detailed technical descriptions of the proposed action and related actions, 

12 including descriptions of the proposed site, preconstruction and construction activities, chemical 

13 process operations within the proposed plant, and decommissioning. Disposition of DUO2 is 

14 also discussed in Section 2.1. Section 2.2 describes alternatives to the proposed action, 

15 including the no-action alternative. The chapter concludes with a comparison of predicted 

16 potential environmental impacts of the proposed action and no-action alternative (Section 2.3) 

17 and a preliminary recommendation from the NRC staff regarding the proposed action 

18 (Section 2.4). 

19 2.1 Proposed Action 

20 The proposed action evaluated in this draft EIS is for NRC to grant IIFP a license to construct, 

21 operate, and decommission a facility (the proposed IIFP facility) in Lea County, New Mexico, for 

22 the deconversion of commercially generated DUF6 inventories into DUO2 and other 

23 deconversion products. The NRC would grant IIFP a license under 10 CFR 40 (Domestic 

24 Licensing of Source Material) to possess and use special nuclear material, source material, and 

25 byproduct material at the proposed IIFP facility. 

26 If the NRC issues a license to IIFP, the license would authorize IIFP to: 

27 • construct, operate, and decommission the proposed DUF6 conversion facility. 

28 • receive DUF6 cylinders from various commercial uranium enrichment facilities. 

29 • transport marketable deconversion byproducts to end users. 

30 • transport DUO2 for disposal as LLW or other potential disposition. 

31 IIFP anticipates that the proposed project would be implemented in two phases, but the current 

32 license application is for the first phase only (Phase 1), and only the potential impacts of the first 

33 phase are evaluated in this draft EIS. Phase 2 would be an expansion of the facility that would 

34 use a direct conversion technology described in Section 2.2.2.2.1. Because Phase 2 is a 

35 “reasonably foreseeable future action” (as defined in 40 CFR 1508.7), impacts associated with 

36 Phase 2 are considered cumulative impacts under NEPA. Cumulative impacts are discussed in 

37 Section 4.2.2 of this draft EIS. 

38 Phase 1 and 2 milestones are shown below. Phase 2 milestones are presented for information 

39 only. 
 2-2 

IIFP submitted license application to NRC December 30, 2009 

IIFP begins construction (Phase 1) 2Q 2012 

IIFP begins Phase 1 operations 4Q 2013 

IIFP submits license application for plant expansion (Phase 2) 2Q 2013 

IIFP begins construction of plant expansion (Phase 2) 2Q 2015 

IIFP begins Phase 2 operations late 2016 

1 The proposed action is described in detail in Sections 2.1.1 through 2.1.8. Unless otherwise 

2 indicated, the information presented in Section 2.1 is from the IIFP’s environmental report (IIFP, 

3 2009) and responses to NRC staff requests for additional information (IIFP, 2011a). 

4 2.1.1 Site Location and Description 

5 The proposed IIFP site is 22.5 km (14 mi) west of Hobbs, in Section 27 of Township 18S, Range 

6 36E, in Lea County, New Mexico. Figure 2-1 depicts the general site location in southeast New 

7 Mexico. Approximately 16 ha (40 ac) of the 259-ha (640-ac) Section would be dedicated to the 

8 deconversion facility. The remaining 243 ha (600 ac) would remain undeveloped. Figure 2-2 

9 locates the 16-ha (40-ac) facility within the Section. The Section now consists of mostly 

10 undeveloped land that has been used in the past for cattle grazing and gas and oil production. 

11 2.1.2 IIFP Deconversion Process 

12 At the proposed IIFP facility, the FEP/DUP would employ three basic processes, as described in 

13 detail in the sections that follow. In summary, the DUF6 would first be deconverted from DUF6

14 to depleted uranium tetrafluoride (DUF4), with marketable AHF produced as a byproduct. Then, 

15 DUF4 would be processed to produce two marketable deconversion byproducts: high-purity 

16 SiF4, and BF3, as needed. Plant throughputs are provided in Figure 2-3. The amount of silicon 

17 and boron byproducts produced would likely outpace the demand for these byproducts if all the 

18 potentially available DUF6 were converted using this process. Therefore, Phase 2 of the project 

19 would support a process that allows the direct conversion of DUF6 to uranium oxide, without 

20 producing the silicon and boron compounds. 

21 2.1.2.1 Deconversion of DUF6 to DUF4

22 As described in Chapter 1, DUF6 results from the enrichment of natural uranium during the 

23 manufacture of nuclear reactor fuel. It is stored and transported as a solid in cylinders 

24 specifically designed for these purposes. DUF6 is a solid at temperatures below 52oC (125oF). 

25 After receipt at the proposed IIFP facility, as the first step in the deconversion process, the 

26 cylinders would be placed in an autoclave enclosed in containment to vaporize the contents. 

27 The DUF6 vapor would be captured in a reaction vessel where it would react with hydrogen to 

28 produce DUF4 powder and AHF. The chemical equation for this process is as follows: 

29 DUF6 (gaseous) + H2 (gas) → DUF4 (solid) + 2HF (anhydrous) 

30 The DUF4 powder would be continuously withdrawn from the bottom of the vessel and fed to the 

31 FEP for further deconversion in either the silicon separation process or the boron separation 

32 process (Sections 2.1.2.2 and 2.1.2.3, respectively). Also, hydrogen fluoride (HF) can be 

33 anhydrous (meaning pure hydrogen fluoride without water) or not. In chemical equations, 

34 hydrogen fluoride is depicted as HF, but the parenthetic expression (anhydrous) is added when 
 2-3 

1 Figure 2-1. General Site Location Map 

2 
 2-4 

1 Figure 2-2. Proposed IIFP Facility Boundary 

2 
2-5 

Figure 2-3. Plant Throughput for the DUF6 Deconversion Process 1 

2 3 
 2-6 

1 appropriate. Hydrofluoric acid is another term for hydrogen fluoride combined with water. HF 

2 offgases would be filtered, and any residual DUF6 would be trapped on carbon filters. The AHF 

3 would then be condensed to liquid form, and any entrained hydrogen burned. Offgas treatment 

4 is described in Section 2.1.6.4.1. AHF would be collected in 3,630-kg (8,000-lb) storage vessels 

5 to limit inventory should a leak occur. AHF storage vessels would be located in a building 

6 designed to contain a leak. The AHF would be loaded from this building into tanker trucks and 

7 shipped to customers. Figure 2-4 shows the process flow chart for this process. 

8 2.1.2.2 SiF4 Production 

9 To produce SiF4, the powdered DUF4 would be mixed with powdered silicon dioxide (SiO2) in a 

10 rotary calciner, and heated to react to form gaseous SiF4 and solid UO2 (U3O8) triuranium 

11 octoxide, sometimes referred to simply as uranium oxide or “yellowcake.” The chemical 

12 equation for this process is as follows: 

13 SiO2 (solid) + DUF4 (solid) → SiF4 (gas) + DUO2 (solid) 

14 The gaseous SiF4 would be collected from the calciner, filtered to remove any particulate 

15 contamination, and cooled to condense any hydrofluoric acid or other trace gases. The purified, 

16 gaseous SiF4 then would be collected in cold traps. The cold traps would be warmed to 

17 vaporize the SiF4, and the gaseous SiF4 would be stored in a vessel for subsequent packaging 

18 and shipment to customers. Offgas treatment is described in Section 2.1.6.4.1. Figure 2-5 

19 shows the process flow chart for this process. 

20 2.1.2.3 BF3 Production 

21 The BF3 production process would be very similar to that for SiF4, except that there would be a 

22 pretreatment step in which a feed mixture of boron oxide (B2O3) and DUF4 would be heated 

23 prior to mixing in the rotary calciner (Figure 2-6). The preheating would remove moisture by 

24 reacting the water with the DUF4, releasing gaseous (anhydrous) HF. The gaseous (anhydrous) 

25 HF would be filtered and scrubbed in the offgas system. The remainder of the process would 

26 be very nearly the same as for SiF4 production. The chemical equation for this process is as 

27 follows: 

28 2B2O3 (solid) + 3DUF4 (solid) → 4BF3 (gas) + 3DUO2 (solid) 

29 2.1.3 Description of the Proposed Facility 

30 The proposed facility would be typical of specialty industrial chemical facilities. The proposed 

31 16-ha (40-ac) facility would be enclosed with a security fence with a surveillance road just inside 

32 the fence. Pole-mounted security lighting would be installed around the entire perimeter. Entry 

33 into the proposed facility would be from the west via a paved road accessed from New Mexico 

34 Highway (NM) 483 which bounds the proposed site on the west (Figure 2-2). Structures within 

35 the security fence would include process, administration, and laboratory buildings; a 

36 maintenance shop; security facilities; utilities; cylinder storage pads; and warehouses. The 

37 parking lot would be outside the security fence. The tallest building is expected to be 

38 approximately 21 meters (m) (70 feet [ft]) high, and the tallest structure a 40 m (131 ft) 

39 meteorological tower. 
2-7 

Figure 2-4. Process Flow Chart for Deconversion of DUF6 to DUF4 1 

2 
2-8 

Figure 2-5. Process Flow Chart for SiF4 Production 1 

2 3 
2-9 

Figure 2-6. Process Flow Chart for BF3 Production 1 

2 3 
 2-10 

1 The proposed IIFP facility would have a Full DUF6 Cylinder Storage Pad with bollards to protect 

2 the cylinders from vehicles. The Pad is designed to be 53.3 m wide by 61 m long (175 ft wide 

3 by 200 ft long) and is sized to store up to 60 full cylinders. The Pad would be curbed for 

4 stormwater collection and provided with underground drains to a stormwater retention basin 

5 south of the Pad. There would also be a 32 m by 56.3 m (105 ft by 185 ft) Empty DUF6 Cylinder 

6 Storage Pad, with capacity for 40 empty cylinders. It would be the staging area for the shipment 

7 of empty cylinders. 

8 The main process buildings, listed below, would be on the proposed 16-ha (40-ac) facility. 

9 • DUF6 Autoclave Building 

10 • DUF4 Process Building 

11 • DUF4 Container Staging Building 

12 • Decontamination Building 

13 • FEP Process Building 

14 • FEP Oxide Staging Building 

15 • DUF4 Container Storage Building 

16 • FEP Product Storage and Packaging Building 

17 • AHF Staging Containment Building 

18 • Fluoride Products Trailer Loading Building 

19 • SiO2 Storage Silo 

20 • Potassium Hydroxide (KOH) Storage Tank 

21 • FEP and DUF4 Scrubbers and Scrubber Containment Pads 

22 Hydrogen used as a reactant in the deconversion processes would be generated onsite from 

23 natural gas using a vendor-supplied steam reforming system. The system would provide 

24 approximately 6 to 9 pounds per hour of hydrogen at 24.7 to 29.7 pounds per square inch 

25 absolute. The natural gas requirement is approximately 18.7 pounds per hour (420 standard 

26 cubic feet per hour). Other than a small surge tank, the site would not store hydrogen gas. 

27 All the building area aprons and areas surrounding outside equipment would have concrete 

28 curbing dikes designed to contain the largest possible spill of liquid chemicals, based on the 

29 volume of chemicals expected to be stored in each building/area. Pads for the storage of 

30 hazardous or corrosive chemicals would be coated to prevent leaks penetrating through the 

31 pads. The dikes would be equipped with pumps to transfer any spills to the Environmental 

32 Protection Process (EPP) equipment (Section 2.1.6.4.2). Radiological hand and foot monitors 

33 would be installed at exits of buildings where uranium would be handled. Fluoride and 

34 radiological detection systems, local alarms, and alarms in the control rooms would alert 

35 workers to potentially hazardous conditions. 

36 Auxiliary buildings would generally house: 

37 • materials 

38 • maintenance shops 
 2-11 

1 • laboratories 

2 • steam boilers and supporting utilities 

3 • electrical utility equipment 

4 • sanitary water treatment equipment 

5 • equipment for process water treatment and recycling 

6 • personnel offices, break rooms, changing rooms, and restrooms 

7 2.1.4 Preconstruction and Construction 

8 Preconstruction activities include activities that would occur prior to issuance of the license and 

9 are discussed in cumulative impacts (Section 4.2.2). Preconstruction activities include site 

10 preparation activities and would not include the construction of process buildings or any safety11 related structures. Preconstruction activities would include: 

12 • clearing land 

13 • grading the site and installing erosion controls 

14 • building the main entrance roadbed and drainage 

15 • setting up construction trailers 

16 • preparing preliminary site roadways and gravel parking area 

17 • (potentially) drilling water wells 

18 • constructing an electrical substation 

19 • stubbing in gas line to meter 

20 • constructing the administrative building shell 

21 • constructing the maintenance and storage building 

22 • constructing the material warehouse building shell 

23 • installing temporary fencing 

24 • constructing facility roadbeds and gravel parking areas 

25 • installing a geothermal heat pump loop 

26 • installing a firewater tank 

27 • installing a truck washing station 

28 During preconstruction, the 16-ha (40-ac) IIFP facility site would be graded to provide an 

29 approximately level grade at elevation 1,157 meters (3,797 ft) above mean sea level. 

30 Approximately 11-ha (26-ac) on the northeast would be cut approximately 0.3 meters (1 foot) in 

31 depth, resulting in a cut of an estimated 32,400 cubic meters (42,400 cubic yards). This 

32 excavated material would be used as fill in the northwest and southwest areas of the proposed 

33 facility location, including two isolated depressions on the west side of the site (approximately 

34 7.3-ha [18-ac]). The amount of fill required would be approximately 32,600 cubic meters 

35 (42,600 cubic yards), resulting in a deficit of 150 cubic meters (200 cubic yards) of fill needed 

36 that would be obtained onsite. 
 2-12 

1 Heavy equipment that would be required for preconstruction (and construction) would include 

2 tractor/backhoes, graders, excavators, dozers, dump trucks, cranes, fuel trucks, water trucks, 

3 forklifts, and flatbeds. Additional equipment could include air compressors, concrete pumps, 

4 generators, and welding machines. During “construction,” which refers to all construction 

5 activities that occur after the license is issued, the remainder of the facility, including the process 

6 buildings, would be constructed. The following activities would occur during construction: 

7 • connecting utilities 

8 • completing the access road and parking lot 

9 • completing the construction of multiple structures including 13 process buildings, an 

10 administration building, laboratories, a maintenance shop, security facilities, cylinder 

11 storage pads, and warehouses 

12 • construction of a meteorological tower 

13 • installation of process equipment and other interior infrastructure 

14 • construction of the wastewater management system 

15 Construction of Phase 1 of the facility is expected to require 140 workers. 

16 During construction, a 0.6-m (2-ft) depth of topsoil (approximately 2,400 cubic meters 

17 [3,100 cubic yards]), would be removed in the areas of buildings and adjacent pads to provide 

18 adequate bearing for concrete floors and pads. Additionally, an estimated 3,000 cubic meters 

19 (4,000 cubic yards) would be removed at an approximate 0.6-m (2-ft) depth in the areas for the 

20 (full and empty) DUF4 cylinder pads. The material used to fill back to the foundation level would 

21 have soil compacting specifications suitable for the load bearing requirements that would be 

22 determined during the detailed engineering of the project. 

23 Foundations and footings for buildings, tanks and equipment, and for evaporation basins and 

24 the storm and sanitary sewer systems, would require excavation of an equivalent 3,170 cubic 

25 meters (4,150 cubic yards), encompassing excavation less backfill. 

26 The roadbed for the access road from NM 483 to the 16-ha (40-ac) site would require 

27 approximately 6,700 cubic meters (8,800 cubic yards) of fill. This fill would use most of the 

28 8,600 cubic meters (11,250 cubic yards) of material from the excavations described above. Any 

29 excess (or unsuitable fill material) would be spread approximately 0.15-m (6 inches [in]) deep 

30 and compacted over an estimated 0.4 to 0.8-ha (1 to 2-ac) area of the 258-ha (640-ac) Section. 

31 The grading and temporary preparation of a construction access road would be included in the 

32 preconstruction activities, but final construction would occur during Phase 1 activities. 

33 2.1.5 Utilities and Other Services 

34 The FEP/DUP plant would require the installation of electrical and natural gas service lines from 

35 existing utilities that cross the proposed site and are outside the facility boundary. It is expected 

36 that these utility connections would be installed during preconstruction. Steam and compressed 

37 air would be generated on site (Section 2.1.5.4). Nitrogen would be internally generated on site 

38 or procured from a vendor. Hydrogen would be generated on site. Water would be obtained 

39 from on-site groundwater wells. 
 2-13 

1 2.1.5.1 Electrical Power 

2 Most of the electrical power required by the proposed facility would be to operate four reaction 

3 vessels (calciners) in the FEP process building, and the refrigeration system and reaction vessel 

4 in the DUP process building. A new electrical substation and distribution line are proposed for 

5 providing electrical service to the facility. Currently 115- and 230-kilovolt transmission lines run 

6 along NM 483 and across Section 27. The local electric utility would install a 4.9 kilovolt7 ampere substation and distribution lines to the facility. The substation would be within the 

8 facility fence. For some lighter loads, solar electric panels, both ground- and roof-mounted, 

9 would supplement the offsite power. 

10 2.1.5.2 Water 

11 The proposed facility would require relatively low volumes of process water because it would 

12 recycle process water and re-circulate cooling water. IIFP estimates that the total water supply 

13 requirement is less than 38,000 liters (L) (10,000 gallons [gal]) per day. Sanitary water 

14 requirements for showers, lavatories, drinking, toilets, and the laboratory would be 11,000 L to 

15 17,000 L (3,000 to 4,500 gal) per day of the total. Treated sanitary waste water would be used 

16 for landscape watering. Boiler blow-down would be sent to the EPP (Section 2.1.6.4.2) for 

17 treatment, if needed, and evaporation. 

18 No municipal water line runs near the proposed site. Therefore, it is anticipated that there would 

19 be at least one but no more than two groundwater wells to supply water for the facility. Lea 

20 County will install and provide one groundwater well as part of the land transfer to IIFP; IIFP 

21 would install another, if necessary, to obtain the desired yield for operations (of both the Phase 

22 1 and Phase 2 facilities operations). A package treatment plant would render the groundwater 

23 acceptable for potable water use. 

24 2.1.5.3 Natural Gas 

25 The proposed facility would require natural gas for two gas-fired boilers that would support 

26 process steam production, the autoclave feed system, and the hydrogen production plant. 

27 Several natural gas pipelines cross Section 27. Gas would be conveyed to the facility from one 

28 of these existing pipelines via a smaller-diameter distribution pipeline. 

29 2.1.5.4 Internal Utilities 

30 2.1.5.4.1 Steam 

31 Steam would be the primary heat source for vaporizing DUF6 in the autoclave, heating some 

32 process and warehouse buildings, and warming pipes as necessary to prevent solidification of 

33 temperature-sensitive substances. Steam requirements for the facility are estimated to be 

34 2,500 to 3,500 pounds per hour. Steam would be generated on-site at 150 pounds per square 

35 inch (psig) using package boilers of about 10,000 pounds per hour capacity. 

36 2.1.5.4.2 Compressed Air 

37 Compressed air would be needed for operation of some instrumentation, control valves, dust 

38 collector blow-back, hopper vibrators, and miscellaneous uses. Ambient air would be filtered, 

39 compressed, and dried to deliver approximately 100 psig. 
 2-14 

1 2.1.5.4.3 Nitrogen 

2 Gaseous nitrogen would be required for purge gas and for cooling pre-condensers in the FEP 

3 process building. Liquid nitrogen would be used for the cold traps. The cold nitrogen vapor 

4 exiting the product cold traps would be used for the pre-condenser cooling. Gaseous nitrogen 

5 leaving the condensers would be collected and compressed to supply gaseous nitrogen to the 

6 parts of the facility that require a dry inert gas. The main application would be for purge and 

7 seal systems, such as the rotary calciner inlet and discharge seals. IIFP plans to conduct a 

8 cost-benefit analysis during detailed design to determine whether to make or buy the liquid 

9 nitrogen or to use another cryogenic system, such as gaseous helium. It is assumed for this 

10 draft EIS that liquid nitrogen would be procured from a vendor. 

11 2.1.6 Facility Operations 

12 2.1.6.1 Workforce 

13 During Phase 1 operations, the continuous, fulltime workforce is expected to be approximately 

14 140 workers. 

15 2.1.6.2 Feedstocks 

16 The primary raw materials used in the facility would be DUF6, SiO2, and B2O3. Annual 

17 throughputs of these materials are provided in Figure 2-3. Other materials needed would be 

18 hydrogen, nitrogen, potassium hydroxide (KOH), and lime. 

19 2.1.6.3 Products 

20 The finished products are fluoride products, namely AHF, SiF4, and BF3. The byproduct of the 

21 facility is a chemically stable DUO2 suitable for permanent offsite disposal, if desired 

22 (Section 2.1.8). The expected annual production of these materials is provided in Figure 2-3. 

23 The design-basis inventories are provided in Table 2-1. 

24 2.1.6.4 Waste Streams 

25 The wastes from the FEP/DUP plant include gaseous emissions, process wastewaters, sanitary 

26 wastes, and solid wastes. These waste streams and their treatment methods are described 

27 below. Gaseous emissions rates are provided in Table 2-2. 

28 2.1.6.4.1 Process Offgas Treatment and Stacks 

29 The plant would have three stacks to vent treated process offgases and particulates to the 

30 atmosphere: the KOH Scrubbing System Stack, the DUF4 Dust Collector System Stack, and 

31 the FEP Dust Collector System Stack. Prior to venting, the particulate and gas process streams 

32 would be filtered and/or scrubbed using multi-stage equipment. Additionally, one boiler vent 

33 stack would release natural gas combustion products to the atmosphere. 

34 Offgas Treatment 

35 Final off-gas streams from the DUF6 to DUF4, SiF4, and BF3 processes (comprised mostly of 

36 nitrogen, air, and trace fluorides) would enter the Plant KOH Scrubbing System, a three-stage 
 2-15 

1 Table 2-1. Facility Design Basis Inventories 

Material 

Maximum Limit 

Agreement with New Mexico 

Projected Average 

Phase 1 

Total depleted uranium 

(DUF6, DUO2 and DUF4) 

2,200,000 kg 

(4,851,000 lb) 

See Note 2

DUF6 See Note 1 15-20 full cylinders 

165,000-220,000 kg 

(363,000-484,000 lb)

DUF6 in process See Note 1 19,500-30,000 kg 

(43,000-66,000 lb) 

DUF4 See Note 1 63,500-136,100 kg 

(140,000-300,000 lb) 

Uranium oxides as DUO2 See Note 1 154,200-213,200 kg 

(340,000-470,000 lb) 

HF (aqueous) 23,300 kg 

(51,400 lb) 

4,500-6,800 kg 

(10,000-15,000 lb) 

AHF 45,000 kg 

(99,200 lb) 

14,000-15,900 kg 

(31,000-35,000 lb) 

SiF4 (packaged + 

in-process)

64,700 kg 

(142,700 lb) 

21,800-31,800 kg 

(48,000-70,000 lb) 

BF3 (packaged + 

in-process) 

22,400 kg 

(49,400 lb) 

7,800-15,000 kg 

(17,000-33,000 lb) 

KOH 8,100 kg 

(17,900 lb) 

6,800-7,700 kg 

(15,000-17,000 lb) 

CaF2 (calcium fluoride) 36,500 kg 

(80,500 lb) 

20,400-22,700 kg 

(45,000-50,000 lb) 

Source: IIFP, 2009 

lb = pound; kg = kilogram 

Note 1: The “Maximum Limit” applies to the total depleted uranium as either DUF6 (both in cylinders and in 

process), DUO2 or DUF4. 

Note 2: The “Projected Average” is provided as individual breakdowns for DUF6 in cylinders and in process, DUO2, 

and DUF4.

2 

3 Table 2-2. Projected Annual Gaseous Emissions to the Atmosphere from Phase 1 

4 Facility Operations 

Pollutant Emissions Units 

CO 1,200 

(1.3) 

kg/yr 

(tons/yr) 

NO2 290 

(0.32) 

kg/yr 

(tons/yr) 

PM2.5 100 

(0.11) 

kg/yr 

(tons/yr) 

PM10 100 

(0.11) 

kg/yr 

(tons/yr) 

SO2 18 

(0.02) 

kg/yr 

(tons/yr) 

5 
 2-16 

1 Table 2-2. Projected Annual Gaseous Emissions to the Atmosphere from Phase 1 

2 Facility Operations (Continued) 

Pollutant Emissions Units 

SiF4 3.7 

(8.2) 

kg/yr 

(lbs/yr) 

BF3 64 

(141) 

kg/yr 

(lbs/yr) 

HF 53 

(117) 

kg/yr 

(lbs/yr) 

CaF2 3.5 

(7.8) 

kg/yr 

(lbs/yr) 

CaCO3 61 

(134) 

kg/yr 

(lbs/yr) 

B2O3 4.9 

(10.8) 

kg/yr 

(lbs/yr) 

U-234 5.2 x 105

(1.4 x 10-5) 

becquerels (Bq)/yr 

curies (Ci)/yr 

U-235 4.8 x 104

(1.3 x 10-6) 

Bq/yr 

(Ci/yr) 

U-238 4.4 x 107

(1.2 x 10-3) 

Bq/yr 

(Ci/yr) 

3 Source: IIFP, 2011a 

4 CO = carbon monoxide; NO2= nitrogen dioxide; PM2.5=particulate matter less than 2.5 microns in diameter; 

5 PM10=particulate matter less than 10 microns in diameter; CaF2=calcium fluoride; CaCO3 = calcium carbonate; 

6 U-234, U-235 and U-238= isotopes of uranium. 

7 

8 scrubber system, to remove fluoride from the offgases prior to releasing them to the 

9 atmosphere. 

10 Two parallel systems would provide operating flexibility. The first stage of each scrubber 

11 system would consist of a primary wet venturi scrubber. The second stage would consist of a 

12 countercurrent-flow, gas-liquid packed tower scrubber. The third-stage scrubber would route 

13 gas exiting the secondary packed tower scrubber though a bed of sized coke (a cellular, 

14 carbonaceous material derived from the destructive distillation of coal or petroleum products). 

15 The coke would be wetted by an aqueous KOH solution that serves as the scrubber liquor. The 

16 aqueous KOH solution would be recycled within each of the scrubbers until the concentration of 

17 KOH needs replenishment (i.e., until the KOH no longer effectively captures the fluoride 

18 residuals, referred to as being “spent”). The KOH solution concentration in the scrubber 

19 equipment would be maintained to ensure it effectively reacts with (scrubs) the fluoride 

20 components in the gas stream. 

21 When the KOH scrubbing liquor concentration needs replenishment, some of the spent 

22 scrubbing solution, containing potassium fluoride (KF), water, and some excess KOH, would be 

23 pumped from the scrubber recycle tanks to the EPP (described in Section 2.1.6.4.2). The Plant 

24 KOH Scrubbing System process flow is depicted in Figure 2-7 and consists of a KOH storage 

25 tank, KOH pump tank, regenerated KOH tank, two or three (installed spare) venturi scrubbers, 

26 two packed towers, and two coke boxes. 
2-17 

Figure 2-7. Plant KOH Scrubbing System Process Flow 1 

2 
 2-18 

1 The three-stage KOH scrubbing system would be designed to remove fluoride-bearing 

2 components in the gas streams at approximate efficiencies of greater than 80 percent, 

3 95 percent, and 99 percent for the first, second, and third stages, respectively. The overall 

4 system removal efficiency would be designed at greater than approximately 99.9 percent. The 

5 plant KOH scrubbing system stack would be continuously sampled to measure for traces of 

6 fluorides or uranium in the vent gas. 

7 Process Dust Collection 

8 Dust capture and collection systems would be installed in areas where depleted uranium 

9 particulates, such as DUF4 or DUO2, would be handled or processed. The dust collection 

10 systems would be filter-type baghouses that would remove the depleted uranium particulates 

11 prior to discharging the process gas to the outside environment through the DUF4 Dust Collector 

12 Vent Stack. 

13 Equipment where depleted uranium-bearing powders would be handled or stored, such as 

14 storage hoppers and enclosed drum packaging stations, would be connected to the dust 

15 collection intakes. Uranium particulates captured by the dust collection systems either would be 

16 recycled back to the respective process operations or packaged and sent to an approved 

17 off-site disposal facility. The design efficiency of baghouse dust collectors would be greater 

18 than 99.5 percent for each collector. At least two components would be used in series to 

19 ensure an overall system efficiency of greater than 99.9 percent in the collection and removal of 

20 particulate uranium from the vented process gas. 

21 Sampling and analysis for uranium would be performed routinely on each baghouse dust 

22 collector. If an unacceptable level of uranium carryover was detected on any given dust 

23 collector, it would be removed from service for maintenance. Additionally, each baghouse 

24 would be continuously monitored for differential pressure across the filter bag sections to ensure 

25 bag design integrity was maintained. 

26 2.1.6.4.2 Environmental Protection Process 

27 The EPP would treat KF solutions to regenerate KOH, and neutralize weak aqueous HF. Both 

28 of these waste streams originate from offgas scrubbing systems designed to prevent air 

29 emissions, as described in Section 2.1.6.4.1. 

30 A KF solution would be generated when KOH was used as a scrubbing medium. In the KOH 

31 regeneration process of the EPP, the KF solution, water, and excess KOH spent solution from 

32 the plant KOH scrubbing system would react with a lime slurry, producing calcium fluoride 

33 (CaF2) and regenerated KOH solution. The regenerated KOH would be recycled and reused in 

34 the plant scrubbing process. The CaF2 would be filtered, dried, and packaged for shipment to 

35 an approved disposal facility, to an HF producer, or to another potential user. 

36 The other stream treated in the EPP would consist of a weak aqueous HF solution, water, or 

37 KOH solution that may contain a low concentration of fluorides. Also, small spills that could 

38 occur in spill control containment areas and require clean up and that could contain weak 

39 fluoride concentrations would be treated in the EPP like the weak HF solution. In these cases, 

40 the fluoride-bearing liquids could have too much water to send to the KOH regeneration system. 

41 The HF neutralization process would use lime slurry to react with weak HF to produce CaF2 and 

42 water. 
 2-19 

1 Figure 2-8 depicts the EPP HF Neutralization and KOH Regeneration processes. These 

2 processes are discussed below. 

3 KOH Regeneration 

4 Lime would be fed to an agitated mix tank and mixed with water. The lime/water slurry would be 

5 approximately 30 percent solids. Spent KOH solution (KOH solution with a weak concentration 

6 of KOH) would be transferred from a storage tank to an agitated reaction vessel that has a 

7 volume of about 22,712 L (6,000 gal). The lime slurry would be transferred from the mix tank to 

8 the reaction vessel. The solutions would remain in the reaction vessel tank for one hour or 

9 more to ensure the reaction was complete. Then the contents of the reaction vessel would be 

10 transferred to a thickening tank for settling. CaF2 from the chemical reaction and excess lime 

11 would be transferred by a slurry pump from the bottom of the thickening tank to a rotary drum 

12 vacuum filter. Solids would be discharged from the filter to a dryer to remove excess water. 

13 Liquors would be transferred from the filter to a clarifier to allow trace solids to settle. 

14 Regenerated KOH solution would be decanted from the top of the clarifier and passed through a 

15 set of filters to the regenerated KOH storage tank. The regenerated KOH solution would be 

16 recycled to the Plant KOH Scrubbing System, as needed, for reuse by the scrubbers. Solids 

17 from the clarifier would be transferred via a slurry pump from the bottom of the clarifier to the 

18 rotary drum vacuum filter and subsequently transferred to the dryer. The dried material would 

19 be packaged and stored for sale or sent to an approved disposal facility. The primary chemical 

20 reaction is: 

21 2KF + Ca(OH)2 (calcium hydroxide) → CaF2 +2KOH 

22 HF Neutralization 

23 The HF Neutralization process would operate intermittently, as needed. A lime silo would hold 

24 an inventory of hydrated lime. The silo would include a dust collector. Lime would be fed to a 

25 mix tank and mixed with water. The slurry would be approximately 30 percent solids. Dilute HF 

26 solution would be transferred from the weak HF solution tank to an agitated acid reaction vessel 

27 with a volume of about 22,712 L (6,000 gal). The lime slurry would be transferred from the mix 

28 tank to the acid reaction vessel. The solutions would remain in the acid reaction vessel for one 

29 hour or more to ensure the reaction was complete. Then the solution from the acid reaction 

30 vessel would be transferred to a thickening tank for settling. After thickening, CaF2 and excess 

31 lime would be transferred by a slurry pump from the bottom of the thickening tank to a rotary 

32 drum vacuum filter. Solids would be discharged from the filter to a dryer to remove excess 

33 water. Liquors from the filter would be recycled to the weak HF solution tank for recycling. After 

34 drying, the CaF2 would be packaged for sale or disposal at an approved disposal facility. The 

35 primary chemical reaction is: 

36 2HF + Ca(OH)2 → CaF2 + 2H2O (water) 

37 2.1.6.4.3 Sewer Systems 

38 Storm Sewers and Stormwater Collection Basins 

39 The facility storm sewer system design assumes a 100-year storm for the Hobbs, New Mexico, 

40 area of 8.9 to 10.2 centimeters (cm) (3.5 to 4 in) of rain falling in one hour. IIFP performed 

41 preliminary engineering of the drainage system size and layout to estimate costs, determine 

42 requirements, and provide information for later detailed design. The preliminary design includes 
2-20 

Figure 2-8. EPP HF Neutralization and KOH Regeneration Processes 1 

2 
 2-21 

1 the locations of the process buildings, auxiliary buildings, pads, roads, parking lot, and water 

2 treatment plant and electrical substation. All of the storm sewer systems would be inside the 

3 fenced area and would collect rainwater runoff from an estimated 8- to 10-ha (20- to 25-ac) 

4 area, including roadways, building roofs, and pads. 

5 Two collection basins are planned to handle storm water drainage surges. One basin would 

6 serve the Full DUF6 Cylinder Storage Pad. The other would be the main holding basin for the 

7 site storm sewer drainage system. Preliminary engineering calculations performed by IIFP 

8 estimate the main basin needs to be approximately 2,800,000 L (100,000 cubic ft) in volume, 

9 assuming a 20 percent freeboard above the maximum design water level. The basin would be 

10 double-lined with impervious synthetic materials typically used in these applications. IIFP’s 

11 current plans are to use a sand base with a layer of geo-synthetic liner and a second layer of 

12 high density polyethylene. Detail engineering and specifications would be refined after civil 

13 engineering data are obtained from the site surveys and after discussions with the New Mexico 

14 Environment Department regarding permits. 

15 Sanitary Sewer 

16 Preliminary design of the sanitary sewer system provides for capability to handle hydraulic 

17 loading of about 11,356 to 17,034 L (3,000 to 4,500 gal) per day. Sanitary sewer discharge 

18 would be treated in primary and secondary package systems for digestion and activation. 

19 Tertiary treatment with disinfection, probably using ultraviolet radiation, would follow. Biomass 

20 generated by the treatment would be removed from the site by a licensed disposal contractor. 

21 The triple-treated water would be re-used as process water in the facility or for landscape 

22 irrigation. 

23 Process Sewer 

24 Process water and solutions, and KOH liquors would be pumped, when contaminant 

25 concentrations dictate, from process systems or the air emissions scrubbing units, respectively, 

26 to the EPP via above-ground piping. Pipes would be double-walled to prevent leakage of 

27 hazardous solutions out of the piping system if the piping cannot be routed through areas with 

28 adequate spill containment. 

29 2.1.6.4.4 Solid Wastes 

30 IIFP would use solid waste management systems including facilities, administrative procedures, 

31 and practices for the collection, temporary storage, and disposal of categorized solid waste. No 

32 solid waste processing is planned. The facility would generate industrial (nonhazardous), 

33 radioactive, hazardous, and mixed wastes. Radioactive and mixed waste would be segregated 

34 according to the volume of liquid that could not be readily separated from the solids. Solid 

35 radioactive wastes would be low-level (radioactive) waste (LLW) as defined in 10 CFR 61, 

36 “Licensing Requirements for Land Disposal of Radioactive Waste.” Table 2-3 provides the 

37 estimated annual quantities of solid waste. 

38 Industrial waste, including sanitary waste, miscellaneous trash, vehicle air filters, empty cutting 

39 oil cans, miscellaneous scrap metal, and paper would be shipped off site for minimization, if 

40 appropriate, and then disposed in an appropriate licensed landfill. 
 2-22 

1 Table 2-3. Phase 1 Estimated Annual Solid Waste Generation - Operations 

Material Estimated Annual Amount 

Low-Level Waste 1,309,000 – 2,875,000 kg 

(2,885,650 – 6,337,300 lbs) 

Hazardous Waste a 92,000 – 140,000 kg 

(203,200 – 308,400 lbs) 

Other Solid Waste 27,510 – 41,400 kg 

(60,650 – 91,300 lbs) 

Source: IIFP, 2011a 

a Includes calcium fluoride which would not be hazardous waste if it is sold as a byproduct. 

2 

3 The DUO2 waste from the deconversion process could be shipped to an offsite LLW disposal 

4 facility licensed to accept DUO2 (Section 2.1.6.5.3 and Section 2.1.8). Other LLW, including 

5 dust collector bags, ion exchange resin, crushed contaminated drums, contaminated trash, 

6 contaminated coke, and carbon trap material would be collected in labeled containers in each 

7 radiological Restricted Area and transferred to the Radioactive Waste Storage Area for 

8 inspection. Waste would be volume-reduced, if appropriate, and disposed at a licensed LLW 

9 disposal facility. 

10 Hazardous wastes and some mixed wastes would be collected at the point of generation, 

11 transferred to the Waste Storage Area, inspected, and classified. Any mixed waste that could 

12 be processed to meet land disposal requirements would be treated in its original collection 

13 container and shipped as LLW for disposal at a licensed LLW disposal facility. Hazardous 

14 wastes would be collected and packaged in approved containers and shipped by a licensed 

15 transporter to a licensed hazardous waste disposal facility. There would be no on-site disposal 

16 of any solid waste at the IIFP facility. 

17 2.1.6.5 Product and Byproduct Packaging and Shipping 

18 Three types of products/byproducts would be shipped: AHF, FEP products (SiF4 and BF3), and 

19 depleted uranium oxides (e.g., DUO2). Given the hazards of fluoride products, especially AHF, 

20 the AHF Staging Containment Building and the FEP Products Trailer Loading Building would be 

21 equipped with an array of water-fog nozzles that would automatically activate in the event of a 

22 leak of AHF or fluoride product chemicals. Fluoride detectors would be deployed throughout the 

23 two buildings to ensure effective coverage. The detection and control system would be 

24 designed for automatically closing isolation valves at the storage tanks and at the tank trailer fill 

25 lines. The detection system would also provide automatic and manual controls for initiating the 

26 water deluge system in event of chemical leaks in either building. 

27 2.1.6.5.1 AHF 

28 The AHF Staging Containment Building and equipment would provide temporary storage of 

29 AHF received from the DUF6 to DUF4 process AHF condensers. AHF would be stored in the 

30 AHF Staging Containment Building in approximately 3,630-kg (8,000-lb) capacity tanks. Dikes 

31 around each storage tank would be sized to hold the contents of the storage tank, with a margin 

32 of safety to minimize the surface area (and evaporation rate of the AHF) in the unlikely event the 

33 tank breached and spilled liquid AHF. 
 2-23 

1 When AHF inventories reach a volume suitable for shipment, the AHF would be loaded into an 

2 approved tank trailer staged in the Fluoride Products Trailer Loading Building, which would be 

3 connected to the AHF Staging and Containment Building. The transporter-owned or customer4 owned tank trailer would be approved by the U.S. Department of Transportation (DOT) and of 

5 the design and type routinely used for shipping AHF nationwide (typically type DOT-412 trailer, 

6 loaded to about 13,608 to 18,144 kg [30,000 to 40,000 lb] of product). The Fluoride Products 

7 Trailer Loading Building would have a truck entrance door that remained closed, sealed, and 

8 controlled except for short periods when the tank trailer would be moved in and out. A transfer 

9 line from the storage tanks in the AHF Staging Containment Building would enter the tank trailer 

10 side of the Fluoride Products Trailer Loading Building. Safety precautions, controls, and 

11 barriers would prevent the tank trailer from inadvertently being moved or from contacting the fill 

12 line. 

13 2.1.6.5.2 FEP Products 

14 The SiF4 and BF3 products awaiting shipment to customers would be stored in the FEP Product 

15 Storage and Packaging Building until packaged within the Building into customer-owned, DOT16 approved shipping cylinders (typically type 3A or 3AA). The SiF4 or BF3 product could be 

17 packaged into DOT-approved shipping tube trailers, and in this case the product would be 

18 transferred from the storage vessels to a tube trailer parked in the Fluoride Products Trailer 

19 Loading Building. 

20 2.1.6.5.3 Depleted Uranium Oxides 

21 DUO2 and all other LLW materials generated at the facility would be transported by truck in 

22 208-(wet) or 242-(dry) L (55-gal) drums in accordance with NRC and DOT packaging and 

23 shipping regulations (10 CFR 71 and 49 CFR 171-173). Trucks would carry 20 to 25 drums per 

24 shipment. The drums would be disposed of at a licensed off-site LLW disposal facility. For 

25 purpose of analysis in this draft EIS, the expected disposal site is considered to be the 

26 EnergySolutions facility at Clive, Utah. See Section 2.1.8 for a discussion of depleted uranium 

27 oxide disposal options. 

28 2.1.7 Decommissioning 

29 The proposed IIFP facility would be licensed to operate for 40 years. At the end of this period, 

30 unless IIFP files a timely application for license renewal, the proposed facility would be 

31 decontaminated and decommissioned in accordance with applicable NRC license termination 

32 requirements. The FEP/DUP facility would be decommissioned such that the site and 

33 remaining facilities could be released for unrestricted use as defined in 10 CFR 20.1402. 

34 Decontamination and decommissioning would occur over three years, after the NRC operating 

35 license expires and if no application to renew the license is submitted. Decommissioning would 

36 employ 40 workers for the three-year period (IIFP, 2009). 

37 Two possibilities exist for the facility structures and paved areas. One is to leave the structures 

38 and most (non-uranium-processing) support equipment in place after it is decontaminated to 

39 free release levels, in accordance with 10 CFR 20, for ultimate use by another industrial tenant 

40 or owner. The second scenario is to raze the structures and remove the pavement, restoring 

41 the site for use as open range land (e.g., grazing and wildlife habitat). IIFP’s analytical 

42 assumption is that decommissioning would involve the removal of the internal equipment (both 

43 Phase 1 and Phase 2 expansion, if built), utilities, and products from the building(s); however, 

44 the physical structures, associated foundations, access roads, and utility lines would likely 
 2-24 

1 remain intact, (i.e., the first scenario). Decommissioning of the proposed IIFP facility would 

2 include decontamination and removal of uranium-processing equipment and other materials that 

3 would be shipped offsite for licensed disposal. Radioactively contaminated equipment and 

4 materials would be sent to a licensed treatment and/or disposal facility in a manner authorized 

5 by the NRC (IIFP, 2009). Prior to the expiration of the license or cessation of facilities 

6 operation, whichever comes first, IIFP would submit a detailed decommissioning plan, which 

7 would undergo additional NEPA review. 

8 2.1.8 Depleted Uranium Disposition Options 

9 On average, the facility would produce approximately 0.32 to 0.36 kg (0.7 to 0.8 lb) of DUO2 for 

10 every pound of DUF6 processed, yielding approximately 2.5 million kg (5.6 million lb) of DUO2

11 annually (Figure 2-3). The DUO2 could either be disposed as LLW or recycled. Potential 

12 reuses of depleted uranium are as aircraft and ship ballast, as ingredients in pigments and 

13 glazes, as shielding material, as forklift counterweights, in armor-piercing projectiles, in high 

14 density concrete, as material to downblend highly enriched uranium, as a component of fuel in 

15 fast breeder reactors (including the proposed variant, the traveling wave reactor), as an 

16 ingredient in mixed-oxide fuel for thermal reactors, and as shielding/absorber in waste 

17 repositories. Some of these uses are conceptual and have never been employed. Others are 

18 in little demand or use only small quantities of depleted uranium, making them unfavorable for 

19 disposition of large volumes of depleted uranium. The uranium fuel cycle as currently 

20 configured in the U.S. does not have the capacity to accept significant quantities of depleted 

21 uranium (DOE, 1999). 

22 Depleted uranium is different from most LLW in that it consists mostly of long-lived isotopes of 

23 uranium, with small quantities of thorium-234 and protactinium-234. The Commission affirmed 

24 that depleted uranium is properly considered a form of LLW in Louisiana Energy Services, L.P. 

25 (National Enrichment Facility), CLI-05-5, 61 NRC 22 (January 18, 2005; NRC, 2005a). This 

26 means that depleted uranium could be disposed of in a licensed LLW facility if the licensing 

27 requirements for land disposal of radioactive waste in 10 CFR 61 are met. However, a specific 

28 site may place additional limits on concentration, volume, or waste form. 

29 Disposal options, including waste form, would be determined after licensing and may change 

30 over the operating life of the facility; however, licensed LLW disposal facilities, including the U.S. 

31 Ecology site in Richland, Washington, EnergySolutions site in Clive, Utah, DOE’s site in Area 5 

32 of the Nevada National Security Site (formerly the Nevada Test Site), and the Waste Control 

33 Specialists (WCS) facility in Andrews, Texas are potential options, provided regulatory and 

34 contractual conditions can be satisfied. The U.S. Ecology facility is in the Pacific Northwest 

35 Compact which has an agreement with the Rocky Mountain Compact (of which New Mexico is a 

36 member) to dispose of waste, but the U.S. Ecology facility’s license would need a revision in the 

37 allowable total uranium inventory. EnergySolutions accepts shipments from all states and is 

38 currently developing a performance assessment to establish inventory limits, if needed. 

39 Shipment to the Nevada National Security Site would require DOE to accept possession of the 

40 LLW (consistent with Section 13 of the USEC Privatization Act of 1996). 

41 The WCS facility is 42 km (26 mi) southeast of the proposed site but is currently limited to waste 

42 from the Texas Compact and therefore, would have to establish approval mechanisms for out43 of-compact waste to be disposed. Furthermore, the Rocky Mountain Compact would have to 

44 approve shipment outside the compact. The analysis in the draft EIS is not intended to support 

45 selection of the LLW disposal facility for the DUO2. 
 2-25 

1 2.2 Alternatives to the Proposed Action 

2 The range of alternatives to the proposed action was determined by considering the underlying 

3 purpose and need for the proposed action and consideration of the no-action alternative. In 

4 addition, DUF6 management options from the DOE’s programmatic EIS on long-term DUF6

5 management (DOE, 1999) were considered. From this evaluation, the NRC staff developed a 

6 set of reasonable alternatives. These alternatives include: 

7 • a no-action alternative under which the proposed FEP/DUP facility would not be 

8 constructed 

9 • deconversion of DUF6 at DOE facilities 

10 • alternative sites for the proposed facility 

11 • alternative technologies available for DUF6 deconversion 

12 • overseas deconversion of DUF6

13 • indefinite storage of DUF6 at the uranium enrichment facilities 

14 • deconversion of DUF6 at the uranium enrichment facilities 

15 2.2.1 No-Action Alternative 

16 Under the no-action alternative, NRC would not grant a license to IIFP to construct, operate, 

17 and decommission the proposed IIFP facility near Hobbs, New Mexico. The proposed site 

18 would remain undeveloped except for preconstruction activities performed by IIFP. The regional 

19 economy would not be changed either positively or negatively. LLW would not be shipped to 

20 disposal facilities. Fluoride products would not be manufactured, sold, and shipped to end 

21 users. 

22 The comparison of impacts between the proposed action and no-action alternative is provided in 

23 Table 2-4. Environmental impacts of the no-action will be less than the proposed action. 

24 However, the no-action alternative does not serve the purpose and need. Presently, there are 

25 four existing or planned domestic commercial enrichment facilities: URENCO USA (formerly 

26 Louisiana Energy Services) National Enrichment Facility, Eunice, New Mexico; AREVA Eagle 

27 Rock, Idaho Falls, Idaho; American Centrifuge Plant, Piketon, Ohio; and GE Global Laser 

28 Enrichment, Wilmington, North Carolina. Under the no-action alternative, the four planned or 

29 existing domestic, commercial uranium enrichment facilities would not send their DUF6 to the 

30 IIFP facility for deconversion. Four other options would be open to them: (1) ship the DUF6 to a 

31 DOE deconversion facility; (2) ship the DUF6 to one of the deconversion facilities overseas; 

32 (3) indefinitely store the DUF6; or (4) construct their own deconversion facilities. As explained in 

33 the subsequent paragraphs of this Section and in Section 2.2.2, all of these options but the first 

34 are identified in Section 2.2.2 as alternatives considered but eliminated from further 

35 consideration in this draft EIS. 

36 DOE has constructed two deconversion plants to convert DUF6 to U3O8 and hydrofluoric acid; 

37 one in Piketon (Portsmouth), Ohio and one in Paducah, Kentucky (DOE, 2004a; DOE, 2004b). 

38 The Ohio facility began operating in October 2010, and the Kentucky facility is slated to begin 

39 operating in 2011. Therefore, shipment to these DOE facilities is a viable option under the no40 action alternative. Such shipment is allowed under the provisions of the United States 

41 Enrichment Corporation (USEC) Privatization Act of 1996. 
 2-26 

1 The option to ship DUF6 to the DOE deconversion facilities was considered in the National 

2 Enrichment Facility EIS (NUREG-1790; NRC, 2005b). This facility, near Eunice, New Mexico, is 

3 now known as the URENCO USA facility. As quoted in its Commission Order CLI-05-05 (NRC, 

4 2005a), NRC stated (in CLI-04-3 regarding the LES facility) that, “an approach by LES to 

5 transfer to DOE for disposal by DOE of LES[’s] depleted tails pursuant to Section 3113 of the 

6 USEC Privatization Act constitutes a ‘plausible strategy’ for dispositioning the LES depleted 

tails” if the tails could be considered LLW under 10 CFR 61.1 7 Commission Order CLI-05-05 

8 further stated that DUF6 tails are a form of LLW. Accordingly, deconversion by DOE is retained 

9 as part of the no-action alternative for this draft EIS. 

10 Given that DOE has a backlog of 700,000 metric tons (771,618 tons) of DUF6 (DOE, undated) 

11 (in approximately 57,000 cylinders) to deconvert, it is expected to take DOE approximately 

12 25 years to complete its mission (DOE, undated) and have the facility capacity to begin 

13 deconverting privately generated DUF6. The DOE process does not produce the FEP products, 

14 and it produces hydrofluoric acid solution rather than the more useful AHF. 

15 Table 2-4. Comparison of Impacts between Proposed Action and No-Action 

16 Alternatives 

Affected 

Environment 

Proposed Action 

IIFP would construct, operate, and 

decommission the proposed IIFP 

facility in Lea County, New Mexico. 

No-Action Alternative 

IIFP would perform preconstruction 

activities, but would not construct, 

operate, and decommission the 

proposed IIFP facility. 

Land Use The NRC staff has determined that 

land use impacts resulting from 

construction of the facility and 

restricting the current land use would 

be SMALL due to the abundance of 

other nearby undeveloped land. 

IIFP would obtain the proposed site, 

complete preconstruction of the IIFP 

facility, and institute restrictions on 

grazing and agriculture. The 16-ha 

(40-ac) site would be cleared and 

potentially reseeded. Grazing could 

resume on the entire 259-ha 

(640-ac) site. Impacts would be 

SMALL. 

Historic and 

Cultural 

Resources 

The NRC staff has determined that 

impacts of the construction and 

operations of the facility to historic 

resources or other cultural resources 

would be SMALL. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. The site would be 

cleared and graded. Impacts to 

historic and cultural resources would 

be SMALL. 

Visual 

Resources 

The NRC staff has determined that 

the proposed facility would not affect 

visual resources. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility which would not 

adversely affect visual resources. 

17 

 

1

 See Louisiana Energy Services, L.P. (National Enrichment Facility), CLI-04-3, 59 NRC 10, 22 (2004), reprinted in 69 

FR 5873, 5877 (Feb. 6, 2004).
 2-27 

Table 2-4. Comparison of Impacts between Proposed Action and No-Action 

Alternatives (Continued) 

Affected 

Environment 

Proposed Action 

IIFP would construct, operate, and 

decommission the proposed IIFP 

facility in Lea County, New Mexico. 

No-Action Alternative 

IIFP would perform preconstruction 

activities, but would not construct, 

operate, and decommission the 

proposed IIFP facility. 

Climatology, 

Meteorology, 

and Air Quality 

Small amounts of nonradioactive 

emissions and small quantities of

uranium isotopes would be released 

to the atmosphere. The NRC staff 

concludes that impacts to air quality 

during construction and operation of 

the IIFP would be SMALL to 

MODERATE. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Smaller amounts of 

nonradioactive air emissions would 

be released than by the proposed 

action. Impacts would be SMALL. 

Geology, 

Minerals, and 

Soil 

The NRC staff has concluded that 

construction impacts and operation 

of the proposed IIFP facility to 

geology, minerals, seismicity, and 

soil would be SMALL, if proper best 

management practices are instituted 

as mitigation. Note that seismicity 

was a key consideration in IIFP’s site 

evaluation process, and the 

proposed site is not in Seismic Zone 

4 or within 48 km (30 mi) of a 

quaternary active fault. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Impacts would be 

SMALL. 

Water 

Resources 

The NRC staff has concluded that no 

impacts would occur to surface 

waters, and groundwater use 

impacts during construction and 

operations are expected to be 

SMALL. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Additional groundwater 

use may or may not occur, 

depending on future uses of the site. 

Impacts would be SMALL. 

Ecological 

Resources 

The NRC staff has concluded that 

direct and indirect adverse impacts 

to ecological resources during 

construction and operation of the 

proposed facility would be SMALL. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. The 16-ha (40-ac) site 

would be cleared and potentially 

reseeded. Impacts would be 

SMALL. 

Noise The NRC staff has determined that 

the proposed facility would not affect 

ambient noise levels. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility which would not 

adversely affect ambient noise 

levels. 

Traffic and 

Transportation 

The NRC staff has concluded that 

impacts to traffic due to the IIPF 

construction and operation would be 

SMALL on NM 483 and US 62/180. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Impacts would be 

SMALL. 

Public and 

Occupational 

Regulated gaseous effluents would 

be below regulatory limits as 

IIFP would obtain the proposed site 

and complete preconstruction of the 
 2-28 

Table 2-4. Comparison of Impacts between Proposed Action and No-Action 

Alternatives (Continued) 

Affected 

Environment 

Proposed Action 

IIFP would construct, operate, and 

decommission the proposed IIFP 

facility in Lea County, New Mexico. 

No-Action Alternative 

IIFP would perform preconstruction 

activities, but would not construct, 

operate, and decommission the 

proposed IIFP facility. 

Health specified by the New Mexico Air 

Quality Bureau. Radiological 

impacts to off-site receptors from 

routine combined effluent releases 

and direct radiation are anticipated 

to be SMALL. Doses to public 

receptors at other sites of interest 

are also anticipated to be SMALL. 

The radiation exposure of involved 

workers is estimated to be well 

within public health standards and 

impacts would be SMALL. The 

impacts to human health from 

occupational injuries during 

operation would be SMALL. 

IIFP facility. Impacts would be 

SMALL. 

Waste 

Management 

Waste DUO2 and LLW materials 

would be disposed of at a licensed 

LLW disposal facility. There would 

be no onsite disposal of any solid 

waste at the IIFP facility. Hazardous 

wastes would be shipped to a 

Resource Conservation and 

Recovery Act (RCRA) disposal 

facility. The quantity of construction 

and operations hazardous and 

nonhazardous waste material would 

result in SMALL impacts that could 

be managed effectively. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Impacts would be 

SMALL. 

Socioeconomics 

and 

Environmental 

Justice 

The NRC staff has determined that 

impacts of the IIFP facility on tax 

revenues, housing, and community 

services for the two-county Region 

of Interest (ROI), consisting of Lea 

and Eddy Counties, where most inmigrating construction and 

operations workers are likely to live, 

and where the majority of economic 

impacts 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Impacts would be 

SMALL. 

Socioeconomics 

and 

Environmental 

Justice 

(Continued) 

would occur would be SMALL and 

positive; and where not positive, 

would still be SMALL. 

Decommissioning would provide 

short-term employment, and 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Impacts would be 

SMALL. 
 2-29 

Table 2-4. Comparison of Impacts between Proposed Action and No-Action 

Alternatives (Continued) 

Affected 

Environment 

Proposed Action 

IIFP would construct, operate, and 

decommission the proposed IIFP 

facility in Lea County, New Mexico. 

No-Action Alternative 

IIFP would perform preconstruction 

activities, but would not construct, 

operate, and decommission the 

proposed IIFP facility. 

depending upon the option chosen, 

the facility could be used for other 

industry and/or the site for 

agriculture. 

All resource impacts are SMALL and 

the identified minority and lowincome populations are not in close 

proximity to the proposed site, so 

impacts would not be considered 

disproportionately high and adverse 

for any populations in the region, 

including minority or low-income 

populations. 

Accidents NRC regulations and IIFP’s 

operating procedures for the 

proposed facility would ensure that 

the high and intermediate probability 

accident scenarios would be 

unlikely. Items which mitigate or 

prevent emergency conditions, and 

the implementation of emergency 

procedures and protective actions in 

accordance with the facility 

emergency plan, would limit the 

consequences and reduce the 

likelihood of accidents that could 

otherwise extend beyond the 

proposed facility site and property 

boundaries. IIFP would be required 

by NRC and DOT regulations to 

package and manage the 

transported waste to minimize the 

probability of accidental release of 

radioactive material. IIFP facility 

design, passive and active 

engineered controls, and 

administrative controls would reduce 

the likelihood of accidents. 

Therefore, the NRC staff has 

concluded that accident impacts 

would be SMALL. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Impacts would be 

SMALL. 

1 

2 
 2-30 

1 2.2.2 Alternatives Considered But Eliminated 

2 2.2.2.1 Alternative Sites 

3 IIFP conducted a site selection process (IIFP, 2009) to determine a suitable location for the 

4 proposed facility. The NRC staff reviewed the IIFP process to determine whether an obviously 

5 superior site was identified. This section discusses IIFP’s site-selection process, identifies the 

6 candidate sites for the proposed FEP/DUP facility, and discusses NRC staff’s review of the 

7 process, screening criteria, and results used by IIFP for selecting the preferred site. 

8 The IIFP site selection process involved (1) a solicitation of community interest to find potential 

9 sites; (2) coarse screening to identify the viable sites among those suggested; (3) fine screening 

10 to further narrow to the candidate sites based on the criteria listed in Table 2-5; and (4) final site 

11 selection based on quantitative criteria. 

12 Table 2-5. IIFP’s Evaluation Criteria for Fine Screening 

Evaluation Criteria 

Project 

Objective 

Impact 

Value 

Local community residents must accept and support facility siting Required Pass/Fail 

Local and state governments must support Regulatory Activities Required Pass/Fail 

Site cannot be in Seismic Zone 4 Required Pass/Fail 

Site cannot be within 50 km of a quaternary active fault Required Pass/Fail 

Presence of nearby activities or structures that could be exposed to a hazard 

by the facility (NUREG-1513) Regulatory 0.8 

Presence of nearby activities or structures that could pose a hazard to the 

facility (NUREG-1513) Regulatory 0.8 

Commitment of natural resources for site offered including the destruction or 

diminution of wildlife habitats, flora, woodlands, and marshlands Regulatory 0.8 

Presence of endangered or threatened species, or critical habitat in 

Endangered Species Act 

Regulatory 0.8 

Environmental Justice Requirements (minority and low-income populations: 

multiple effects to be considered) 

Regulatory 0.8 

Will action cause a violation of Federal, State, local, tribal laws or 

requirements for protection of environment (Air Quality, Water Quality, other) Regulatory 0.8 

Location of adjacent hazards or hazardous operations leading to cumulative 

impacts Regulatory 0.8 

State and local government financial incentives Cost 0.4 

Property tax incentive Cost 0.8 

State Income taxes Cost 0.8 

State Sales and use taxes Cost 0.8 

Transportation routes (impacts) for incoming feed material, considering 

distances & routes Cost 0.8 

Transportation cost to uranium oxide waste disposal site Cost 0.8 

Transportation cost to primary anhydrous HF buyers Cost 0.8 

Schedule time required to license and construct Schedule 0.4 

13 
 2-31 

Table 2-5. IIFP’s Evaluation Criteria for Fine Screening (Continued) 

Evaluation Criteria 

Project 

Objective 

Impact 

Value 

Existence of chemical or radiological contamination Regulatory 0.4 

Adequate water supply and cost Cost 0.4 

Presence of special interest groups (interveners) Regulatory 0.4 

Acreage Offered (min 640-acres) and cost Cost 0.4 

Waste types generated during construction, operation and demolition, 

RCRA, etc. Regulatory 0.4 

Cost of construction and operation Cost 0.4 

Electrical supply and cost Cost 0.4 

Gas supply and cost Cost 0.4 

Impact on water quality or water supply (reduction) Regulatory 0.4 

Site characteristics: Geology, topography, seismic Regulatory 0.2 

Decommissioning Requirements Regulatory 0.2 

Site characteristics: depth to frost line Regulatory 0.2 

Infrastructure incentive Cost 0.2 

Contaminants Regulatory 0.2 

Training, accessibility, availability of emergency response personnel / 

facilities Regulatory 0.2 

Existing environmental data Regulatory 0.2 

Ambient noise levels Regulatory 0.1 

Site characteristics: climatology and meteorology Regulatory 0.1 

Sanitary wastewater treatment availability Cost 0.1 

Availability of road, rail, and airport Cost 0.1 

Buildings offered and terms Cost 0.1 

Condition of land Cost 0.05 

Unemployment insurance tax Cost 0.05 

1 Source: IIFP, 2009 

2 

3 Potential environmental impacts can be avoided or significantly reduced through proper site 

4 selection. IFFP used an approach to select a preferred site based on technical, environmental, 

5 safety, and economic considerations (IIFP, 2009). The NRC staff reviewed the site selection 

6 process used by IIFP and determined that the process is comprehensive because it takes into 

7 account all applicable criteria, structured because it follows from coarse to more fine screening 

8 process, and appropriate for identifying and evaluating the proposed site and alternative 

9 candidates. 

10 2.2.2.1.1 Solicitation of Interest 

11 IIFP determined that desirable locations for the plant would be proximate to existing, private, 

12 DUF6 sources and near LLW disposal facilities that could accept DUO2 for disposal. This 

13 resulted in IIFP soliciting site proposals from communities in the states of Texas, Idaho, and 

14 New Mexico (IIFP, 2011b). The IIFP inquiry package requested information about the 
 2-32 

1 community and any interest or proposal for attracting and accepting a DUF6 deconversion 

2 facility. As a result, six potential sites were identified: one in Texas, two in Idaho, and three in 

3 New Mexico. 

4 2.2.2.1.2 First-Phase Screening 

5 IIFP used the following criteria to evaluate the six potential sites: 

6 • acceptance of the proposed facility by community 

7 • acceptance of the proposed facility by state and local governments 

8 • appropriate seismic qualifications (not to be in seismic zone 4) 

9 • no environmental legacy potential liabilities 

10 • location in proximity to customers and waste disposal sites 

11 • availability of utilities infrastructure 

12 The NRC staff reviewed the IIFP’s first-phase screening process, elimination criteria, and results 

13 and determined that they are reasonable and appropriate because the elimination criteria 

14 consists of considerations relevant to the evaluation of potential impacts to environmental 

15 resource areas discussed in this draft EIS. Further, the NRC staff agrees that these elimination 

16 criteria allow IIFP to exclude from further consideration certain sites due to their potential 

17 environmental impacts. 

18 Sites were excluded from further consideration based on the outcomes of these screening 

19 criteria when applied to each potential site: two of the six potential sites were eliminated from 

20 consideration. One New Mexico site was eliminated because it was distant from utilities and 

21 population centers, and it had no characterization data. One of the Idaho sites was eliminated 

22 because it was located on a previous radioactive materials processing site and, thus, had 

23 legacy issues that IIFP chose to avoid. As a result, one Texas site, one Idaho site, and two 

24 New Mexico sites moved on to IFFP’s fine screening. The NRC staff agreed it was appropriate 

25 to eliminate the two sites, based on the first-phase screening criteria. 

26 2.2.2.1.3 Second-Phase Screening 

27 The second-phase screening occurred in two rounds in which IIFP evaluated the remaining four 

28 sites using used various categories of evaluation criteria. The first round evaluated the four 

29 sites on qualitative site-specific criteria and quantitative cost-benefit criteria. The qualitative 

30 criteria included public and state support, seismic characteristics, land/soil issues, land/mineral 

31 rights, aesthetics, and licensing and permits. The cost-benefit criteria included incentives, 

32 infrastructure cost, operating costs, state and local taxes, and transportation costs. 

33 During this screening, two sites (one in New Mexico and one in Idaho) were eliminated because 

34 of site-specific features and excessive land and/or infrastructure costs. Subsequently, the 

35 communities that had offered the eliminated sites were asked to nominate a second 

36 (replacement) site, resulting in a second iteration of first-phase screening. The New Mexico 

37 replacement site was rejected in a reiteration of first-phase screening because of numerous oil 

38 wells on the site and the complexity of acquiring the land. The Idaho replacement site survived 

39 this screening (IIFP, 2011b). This left three sites to undergo the second round of IIFP’s second40 phase screening: one in Texas, one in Idaho, and one in New Mexico (the Hobbs site). 

41 Table 2-5 identifies the screening criteria used by IIFP in their siting selection process and the 

42 criterion’s relative importance. 
 2-33 

1 The NRC staff reviewed the IIFP’s second-phase screening process and determined that it is 

2 reasonable and appropriate as it consists of criteria allowing the applicant to consider potential 

3 environmental impacts as a result of the site selection process. Further, appropriate 

4 consideration was given to seismic potential, threatened and endangered species and critical 

5 habitat, economic considerations, emergency preparedness and response, air quality, 

6 climatology and meteorology, water quality and water supply, waste management, acreage, 

7 noise, nearby hazards or hazardous operations, and environmental justice. The NRC staff finds 

8 that consideration of these criteria is appropriate and comprehensive because it takes into 

9 consideration environmental resources such as wildlife habitats, potential for exposure to 

10 hazards to the facility, proximity to quaternary active faults, and applicable Federal State, local, 

11 and Tribal laws for protecting the environment. The application of the criteria allow for the 

12 identification and selection of a site that would be expected to result in reduced potential 

13 environmental impacts. 

14 2.2.2.1.4 Final Site Selection 

15 In the final site selection, the sites were evaluated by IIFP using the criteria listed in Table 2-5, 

16 assigning an impact value and an evaluation value to each criterion in Table 2-5 (IIFP, 2009). 

17 For each potential site the impact value of each criterion listed in Table 2-5 was multiplied by an 

18 evaluation number assigned for each potential site. The evaluation number for each criterion 

19 ranged from 1 for most favorable to 10 for least favorable potential site. The summation of the 

20 product of these multiplications produced the total score for each site. The lower the evaluation 

21 score the more favorable the site. The Hobbs, New Mexico site was ultimately selected 

22 because it has the lowest (best) score. 

23 IIFP determined that the Hobbs site offers overall the most beneficial combination of technical, 

24 safety, economic, and environmental factors (IIFP, 2009). IIFP selected the Hobbs, New 

25 Mexico, site for the proposed facility in part because it is not near an active fault, there is no 

26 legacy chemical or radiological contamination, there are no air quality non-attainment areas in 

27 the vicinity, the site is sparsely populated, the availability of water, electricity and natural gas, 

28 and public and state, and local support. Consideration was also given to threatened and 

29 endangered species, critical habitats, and historic and cultural properties. 

30 The NRC staff reviewed the IIFP process and determined that the process used by IIFP is 

31 reasonable and appropriate because the list of criteria is comprehensive and considers 

32 elements relevant to the evaluation of potential environmental impacts. It also includes 

33 regulatory requirements, and considers costs, scheduling impacts, and community support. The 

34 results concluding that the Hobbs site offers overall the most beneficial combination of 

35 environmental, technical, safety, and economic factors are reasonable. The NRC staff further 

36 concludes that none of the candidate sites is obviously superior to the IIFP preferred site. 

37 2.2.2.2 Alternative Technologies 

38 2.2.2.2.1 Direct Deconversion (IIFP Facility Phase 2) 

39 In Section 2.1.2, a direct conversion process is mentioned as a possible, future Phase 2 

40 licensing action. This technology is very similar to that of the proposed action, but it does not 

41 yield the marketable FEP products, SiF4 and BF3. In direct conversion, all the fluorides in the 

42 DUF6 would be converted to AHF. As an alternative, IIFP could seek a license for the Phase 2 

43 process without obtaining a license for Phase 1. The process, which directly converts DUF6 to 

44 uranium oxide, mainly as U3O8, is described in more detail below. 
 2-34 

1 In the direct conversion to oxide process, the DUF6 feed would be vaporized in the same type of 

2 autoclave as in the proposed DUF6 to DUF4 process. The DUF6 vapor would be fed to a 

3 first-stage reaction vessel where it would react with a feed of a vaporized mixture of HF and 

4 steam that has been recycled from the back end (distillation system) of the process. The 

5 reaction results in the formation of uranyl oxyfluoride (UO2F2) and HF. 

6 The UO2F2 powder would be withdrawn from the bottom of the reaction vessel and sent to a 

7 second-stage reaction vessel where it would undergo a reaction with steam to form U3O8 and 

8 HF. A more concentrated HF vapor mixture and water would exit the tops of the first and 

9 second stage reaction vessels and be condensed using heat exchanger equipment. The 

10 condensed and concentrated HF would then be distilled to produce commercial grade AHF. 

11 The resulting distillation bottom material of less concentrated HF would be recycled, vaporized, 

12 and returned as feed to the first-stage reaction vessel. 

13 U3O8 formed in the second-stage reaction vessel would be transferred to storage hoppers. A 

14 two-stage dust collector system would control and recycle U3O8 dust generated by air or gas 

15 flows associated with the solids handling equipment. The U3O8 in the storage hoppers would be 

16 packaged into DOT-approved shipping containers and transported to an off-site, licensed LLW 

17 disposal facility. 

18 The potential environmental impacts of the proposed action and the alternative technology of 

19 direct conversion would be nearly the same, because the throughput of DUF6 would be the 

20 same, both processes produce large volumes of AHF (the alternative technology somewhat 

21 larger), both produce the same quantity of chemically stabilized uranium (although in slightly 

22 different chemical forms), and the basic chemical processes are very similar. Because (1) direct 

23 conversion is analyzed as a cumulative impact in this draft EIS and (2) there is so little 

24 difference in the expected environmental impacts between the proposed action and the direct 

25 conversion alternative, this alternative is eliminated from consideration in this draft EIS as a 

26 separate alternative. 

27 2.2.2.2.2 DOE Deconversion Technology 

28 DOE has constructed two deconversion facilities, one at the site of the former Paducah 

29 Gaseous Diffusion Plant in Paducah, Kentucky and the other at the site of the former 

30 Portsmouth Gaseous Diffusion Plant near Piketon, Ohio. These plants were constructed to 

31 deconvert the approximately 700,000 metric tons (771,618 tons) of DUF6 stored at the Paducah 

32 plant, the Portsmouth plant, and the East Tennessee Technology Park (formerly the K-25 

33 Gaseous Diffusion Plant) at the Oak Ridge Reservation, Tennessee. Shipment of full DUF6

34 cylinders to these plants is allowed as described in Section 2.2.1 (the no-action alternative). 

35 As an alternative technology to the technology proposed in this draft EIS, IIFP could construct a 

36 plant that uses the technology of the DOE plants. The DOE deconversion process reacts DUF6

37 with water (steam) and hydrogen to produce U3O8 and aqueous HF. The DUF6 is directly 

38 converted to U3O8 in a one-stage reaction vessel. HF and water vapor exit the reaction vessel 

39 and are collected as aqueous HF. The U3O8 solids exit the reaction vessel, and are stored 

40 temporarily until they are shipped to a waste disposal site. DOE plans to market the aqueous 

41 HF, but any HF that is not sold may have to be treated as a waste liquid. This liquid waste 

42 would likely be reacted with lime to form CaF2 and stored in retention basins or sold. (DOE, 

43 2004a; DOE, 2004b). Assuming the CaF2 can be sold, it could be used to produce AHF at an 

44 industrial AHF production plant. 
 2-35 

1 This alternative is eliminated from consideration in this draft EIS because: 

2 • The DOE process has already been analyzed in two DOE-prepared NEPA documents 

3 (DOE, 2004a; DOE, 2004b), and the impacts of implementing the DOE technology 

4 would be sufficiently similar to the proposed action. For this reason no value would be 

5 gained by further analyzing this technology as an alternative to the proposed action. 

6 The throughput of DUF6 would be the same, both processes would produce the same 

7 quantity of chemically stabilized depleted uranium (although in slightly different chemical 

8 forms), and the basic chemical processes are very similar. 

9 • The DOE alternative has greater uncertainty regarding the disposition of the aqueous 

10 HF, and could result in higher environmental consequences should the conversion of HF 

11 to CaF2 and then AHF, be required. 

12 2.2.2.2.3 European Deconversion Technology 

13 Three processes can convert DUF6 to uranium oxide; the IIFP process, the DOE process, and 

14 the European process. The European process involves reacting DUF6 directly with steam in a 

15 first-stage reaction vessel, producing aqueous HF and depleted uranyl dioxyfluoride (DUO2F2). 

16 The DUO2F2 is processed further in a second-stage reaction vessel to form aqueous HF and 

17 depleted uranium oxide for disposal. The HF is collected in an aqueous form that can be sold or 

18 treated (IIFP, 2009). 

19 As with the DOE technology, this alternative is eliminated for the following reasons: 

20 • The impacts of implementing the European technology would be sufficiently similar to 

21 the proposed action such that no value would be gained by further analyzing this 

22 technology as an alternative to the proposed action. The throughput of DUF6 would be 

23 the same, both processes would produce the same quantity of chemically stabilized 

24 uranium (although in slightly different chemical forms), and the basic chemical processes 

25 are very similar (IIFP, 2009). 

26 • The European alternative has greater uncertainty regarding the disposition of the 

27 aqueous HF, and could result in higher environmental consequences should the 

28 conversion of HF to CaF2 and then AHF, be required. 

29 2.2.2.3 Overseas Shipment of DUF6 for Deconversion 

30 URENCO and AREVA are foreign companies that operate or are planning to operate 

31 enrichment plants in the U.S. These firms own and operate deconversion facilities overseas 

32 and could choose to ship their U.S.-generated DUF6 to those facilities for deconversion. Also, 

33 Russia has recently commissioned a deconversion facility and is planning another. Under this 

34 alternative, any of the four U.S.-based commercial enrichment companies could ship their DUF6

35 overseas for deconversion. However, this would involve shipping DUF6 long distances 

36 overseas and the uranium oxides would have to be shipped back to United States for licensed 

37 disposal (IIFP, 2009). The cost of such shipments would likely be significant. 

38 In its EIS for the National Enrichment Facility (now URENCO USA), the NRC staff (NRC, 2005b) 

39 examined three foreign disposition alternatives for DUF6: Russian re-enrichment, French 

40 deconversion or re-enrichment, and Kazakhstan deconversion. The NRC staff concluded, “Due 

41 to the costs for disposition in Russia, France, or Kazakhstan, the NRC staff does not consider 

42 these alternatives to be viable” (NRC, 2005b). 
 2-36 

1 For reasons discussed above, the NRC staff concludes that overseas shipment of DUF6 for 

2 deconversion is not a reasonable alternative. Thus, this alternative has been eliminated from 

3 further analysis. 

4 2.2.2.4 Indefinite Storage of DUF6

5 Commercial enrichment facilities in the U.S. could store their DUF6 at their enrichment facilities, 

6 much like DOE has done for decades. As described in Section 2.2.1, No-Action Alternative, the 

7 DOE deconversion facilities could eventually (approximately 25 years in the future) take this 

8 DUF6, making this alternative evolve over time to the no-action alternative. 

9 The DNFSB has reported that long-term storage of DUF6 represents a potential chemical 

10 hazard (DNFSB, 1995). DOE policy (DOE, 2000) is that alternatives for the long-term 

11 management of DUF6 include its deconversion to a more stable uranium oxide. DOE evaluated 

12 long-term storage in its Programmatic EIS on DUF6 management (DOE, 1999), but did not 

13 select the long-term storage option (64 FR 43358). 

14 In addition to creating a potential chemical hazard, the alternative of indefinite storage of DUF6

15 does not meet the need to deconvert this material (as discussed in Section 1.3) and has 

16 therefore been eliminated from consideration in this draft EIS. 

17 2.2.2.5 Commercial Enrichment Plant Deconversion of DUF6 at Uranium Enrichment 

18 Facilities 

19 The four U.S.-based enrichment companies could decide to construct and operate their own 

20 deconversion facilities. The only operational commercial enrichment facility in the U.S., the 

21 URENCO USA plant near Eunice, New Mexico, has already signed an agreement with IIFP for 

22 IIFP to accept URENCO’s DUF6. Furthermore, it is expected that the potential environmental 

23 impacts of implementing this alternative at each enrichment facility would be similar to that for 

24 the proposed action. However in this event these impacts would occur at up to four locations as 

25 a result of the construction of four deconversion facilities rather than just one as would be the 

26 case for the proposed action. One deconversion facility for each U.S.-based enrichment 

27 company would have greater environmental impacts than the construction of one facility to 

28 support all the enrichment facilities, which is the proposed action. Thus, the NRC staff has 

29 concluded that this alternative offers no meaningful advantages over the proposed action, and 

30 therefore does not warrant further consideration in this draft EIS. 

31 2.3 Comparison of Predicted Environmental Impacts 

32 Chapter 4 of this draft EIS presents a detailed evaluation of the potential environmental impacts 

33 of the proposed action and the no-action alternative. Table 2-4summarizes and compares 

34 these environmental impacts. A common element between the two alternatives is the 

35 occurrence of preconstruction activities. It is assumed that preconstruction activities take place 

36 under both alternatives and, therefore, the impacts associated with preconstruction activities 

37 would occur regardless of which alternative is selected. As a result, the comparison of 

38 alternatives presented in Table 2-4 is intended primarily to highlight the differences between the 

39 two alternatives after preconstruction activities have occurred. A standard of significance has 

40 been established for assessing potential environmental impacts. In its implementation of the 

41 Council on Environmental Quality’s regulations on significance (40 CFR 1508.27), NRC staff 

42 has assigned each impact one of the following three significance levels, as defined in NRC 

43 (2003): 
 2-37 

1 • SMALL. The environmental effects are not detectable or are so minor that they would 

2 neither destabilize nor noticeably alter any important attribute of the resource. 

3 • MODERATE. The environmental effects are sufficient to noticeably alter but not 

4 destabilize important attributes of the resource. 

5 • LARGE. The environmental effects are clearly noticeable and are sufficient to 

6 destabilize important attributes of the resource. 

7 These impact levels are used in the summary and comparison of alternatives in Table 2-4. 

8 2.4 Staff Recommendation Regarding the Proposed Action 

9 After weighing the impacts of the proposed action in Chapter 4 and comparing the impacts of 

10 the proposed action and the no-action alternative in Table 2-4, the NRC staff, in accordance 

11 with 10 CFR 51.71(f), sets forth its preliminary NEPA recommendation regarding the proposed 

12 action. 

13 The NRC staff preliminarily recommends that, unless safety issues mandate otherwise, the 

14 proposed license be issued to IIFP. The NRC staff has concluded that potential environmental 

15 impacts are in all aspects SMALL or MODERATE, and application of the environmental 

16 monitoring program described in Chapter 6 and the proposed IIFP mitigation measures 

17 discussed in Chapter 5 would eliminate or substantially lessen any potential adverse 

18 environmental impacts associated with the proposed action. 

19 The NRC staff has concluded that the overall benefits of the proposed IIFP facility outweigh the 

20 SMALL or MODERATE negative environmental impacts, based on consideration of the 

21 following: 

22 • The proposed IIFP facility would deconvert DUF6 into depleted uranium oxides for 

23 disposal. With the existing inventory of stockpiled depleted uranium as well as four new 

24 commercial enrichment plants in the U.S. expected to be operating within the next few 

25 years, there is a need to deconvert the quantity of DUF6 that exists and would be 

26 produced at these enrichment facilities. Without a deconversion facility, DUF6 would 

27 continue to be stored, primarily at commercial uranium enrichment facilities in the United 

28 States. Although DUF6 could be transferred to DOE for a fee, DOE’s existing inventory 

29 of DUF6 is not projected to be deconverted for 25 years. 

30 • The potential environmental impacts from the proposed action are in most aspects 

31 SMALL with the exception of short term construction related air quality impacts and in 

32 some cases, beneficial. 

33 2.5 References 

34 (DNFSB, 1995) U.S. Defense Nuclear Facilities Safety Board. 1995. Integrity of Uranium 

35 Hexafluoride Cylinders. Technical Report DNFSB/TECH-4. May 5, 1995. 

36 (DOE, undated) U.S. Department of Energy. Undated. Transporting DOE Uranium Oxide from 

37 Portsmouth Ohio, and Paducah Kentucky. Portsmouth/Paducah Project Office, Lexington, KY. 

38 ADAMS Accession No. ML110120583. 

39 (DOE, 1999) U.S. Department of Energy. 1999. Final Programmatic Environmental Impact 

40 Statement for Alternative Strategies for the Long-term Management and Use of Depleted 
 2-38 

1 Uranium Hexafluoride, DOE/EIA-0269. Office of Nuclear Energy, Science and Technology, 

2 Washington D.C. April 1999. ADAMS Accession No. ML050180302. 

3 (DOE, 2000) U.S. Department of Energy. 2000. Assessment of Preferred Depleted Uranium 

4 Disposal Forms. ORNL/TM-2000/161, Oak Ridge, TN. June 2000. ADAMS Accession No. 

5 ML060110351. 

6 (DOE, 2004a) U.S Department of Energy. 2004. Final Environmental Impact Statement for 

7 Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the 

8 Paducah, Kentucky Site, DOE/EIS-0359, Washington, D.C., June 2004. ADAMS Accession No. 

9 ML 050380331. 

10 (DOE, 2004b) U.S. Department of Energy. 2004. Final Environmental Impact Statement for 

11 Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the 

12 Portsmouth, Ohio Site, DOE/EIS-0360, Washington, D.C., June 2004. ADAMS Accession No. 

13 ML051030392. 

14 (IIFP, 2009) International Isotopes Fluorine Products. 2009. Fluorine Extraction Process and 

15 Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A, ER-IFP16 001, Revision A. December 27, 2009. ADAMS Accession No. ML100120758. 

17 (IIFP, 2011a) International Isotopes Fluorine Products, Inc. 2011. Fluorine Extraction Process 

18 and Depleted Uranium De-conversion Plant (FEP/DUP) Official Responses to Environmental 

19 Report RAIs, Revision A. March 31, 2011. ADAMS Accession No. ML110970481. 

20 (IIFP, 2011b) International Isotopes Fluorine Products, Inc. 2011. “Site Selection Information 

21 for International Isotopes Fluorine Products, Incorporated (IIFP) Fluorine Extraction and 

22 Depleted Uranium Deconversion Facility near Hobbs in Lea County, New Mexico,” E-mail, 

23 September 22, 2011. ADAMS Accession No. ML11265A322. 

24 (NRC, 2003) U.S. Nuclear Regulatory Commission. 2003. Environmental Review Guidance for 

25 Licensing Actions Associated with NMSS Programs. Final Report. NUREG 1748, Division of 

26 Waste Management, Washington, D.C. August 2003. ADAMS Accession No. ML032450279. 

27 (NRC, 2005a) U.S. Nuclear Regulatory Commission. 2005. In the matter of Louisiana Energy 

28 Services, L.P. (National Enrichment Facility), CLI-05-05, Memorandum and Order. Docket No. 

29 70-3103-ML. January 18, 2005. ADAMS Accession No. ML050180295. 

30 (NRC, 2005b) U.S. Nuclear Regulatory Commission. 2005. Environmental Impact Statement 

31 for the Proposed National Enrichment Facility in Lea County, New Mexico, NUREG-1790, 

32 Vol. 1. Washington, D.C. June 2005. Available at http://www.nrc.gov/reading-rm/doc33 collections/nuregs/staff/sr1790/vl/. ADAMS Accession No. ML051730238. 
 3-1 

1 3.0 AFFECTED ENVIRONMENT 

2 This chapter describes the existing regional and local environmental conditions at and near the 

3 proposed IIFP site before any preconstruction activities begin and prior to the proposed action. 

4 This chapter presents information on land use; historic and cultural resources; visual resources; 

5 climatology, meteorology, and air quality; geology, minerals and soils; water resources; 

6 ecological resources; socioeconomic resources; traffic and transportation; noise; and public and 

7 occupational health. The data and information presented here provide a baseline against which 

8 to assess impacts (Chapter 4) of the proposed action described in Chapter 2 of this draft EIS. 

9 3.1 Site Location 

10 The proposed IIFP site would occupy Section 27, in Township 18S, Range 36E of southeastern 

11 New Mexico, in Lea County. The 259-ha (640-ac) site is approximately 22.5 kilometers (km) 

12 (14 miles [mi]) west of Hobbs, New Mexico, 27.4 km (17 mi) west of the Texas/New Mexico 

13 border, and 362 km (225 mi) southeast of Albuquerque, New Mexico. The nearest population 

14 center is Hobbs, New Mexico, which had an estimated population of 30,838 in 2009 (USCB, 

15 2010a). The nearest important permanent surface water is the Pecos River, approximately 146 

16 km (91 mi) west of the site. The southern boundary of Section 27 is 1.6 km (1 mi) north of U.S. 

17 Highway 62/180 (US 62/180) and the western boundary is NM 483. Figures 3-1 and 3-2 depict 

18 the 80-km (50-mi) and 10-km (6-mi) radii surrounding the site, respectively, and are referred to 

19 in subsequent analyses. 

20 IIFP has set aside approximately 16 ha (40 ac) in the northeast quadrant of the proposed site 

21 for the deconversion facility (see Figure 2-2). The remainder of Section 27 would remain as 

22 undeveloped (IIFP, 2009). The facility’s location was selected to avoid, to the extent possible, 

23 utility rights-of-way including overhead transmission lines and underground pipelines. The 

24 facility would be enclosed by a security fence with a surveillance road just inside the fence. See 

25 Section 2.1.3 for a list of the structures at the facility. 

26 3.2 Land Use 

27 This section includes a description of land use on and near the proposed IIFP site, including a 

28 description of offsite areas and the regional setting. For the purposes of this draft EIS, the 

29 Region of Influence (ROI) for land use is defined as the area within a 10-km (6-mi) radius of the 

30 center point of the proposed IIFP site (see Figure 3-2 for site location and nearby features within 

31 the ROI). 

32 The proposed IIFP site is in Section 27, in Township 18S, Range 36E of southeastern New 

33 Mexico, in Lea County, approximately 22.5 km (14 mi) west of Hobbs, New Mexico. Property 

34 ownership in the county (which is approximately 1.1 million ha [2.8 million ac] in size) is 

35 17 percent Federal ownership, 31 percent State ownership, and 52 percent private ownership. 

36 The Federally owned land is primarily in the southwestern portion of the county, the State37 owned land is located throughout the central portion of the county, and the privately owned land 

38 primarily extends from north to south in the county’s eastern portion. Large tracts of land in Lea 

39 County are privately owned by farmers, ranchers, and oil, gas, and mining companies. 

40 Urbanized areas near cities and towns include smaller tracts used for residential, municipal, and 

41 commercial purposes. Approximately 93 percent of Lea County is used as range land for 

42 grazing and approximately 4 percent is used for crop farming. Urban areas and the roadway 
 3-2 

1 Figure 3-1. 80-km (50-mi) Radius Map 

2 
 3-3 

1 Figure 3-2. 10-km (6-mi) Radius Map

2 

3 
 3-4 

1 system account for the county’s remaining land use. Most of the land actively farmed in Lea 

2 County is irrigated (Leedshill-Herkenhoff et al., 2000). 

3 The public roadways closest to the proposed IIFP site are US 62/180 running east-west and 

4 NM 483 running north-south (Figure 3-2). These roadways mostly traverse open range land in 

5 the ROI. 

6 The proposed 259-ha (640-ac) IIFP site and the surrounding ROI are largely undeveloped. The 

7 land has been used for cattle grazing and for gas and oil development (IIFP, 2009). There are 

8 715 oil or gas wells within the 10-km (6-mi) ROI. Seven of these wells, all of which have been 

9 abandoned, are within 1.6 km (1.0 mi) of the site (Oil and gas wells are discussed in more detail 

10 in Section 3.6.3). Both overhead and underground utilities, and their associated rights-of-way, 

11 cross the site and the ROI. Several overhead transmission lines and underground gas/oil 

12 pipelines run generally east to west across the proposed IIFP site. Xcel Energy’s Cunningham 

13 Station, just west of Section 27, has four groundwater monitoring wells in Section 27 (see 

14 Figures 3-2 and 3-14). Three other energy production facilities are within 10 km (6 mi) of the 

15 proposed facility: the Colorado Energy Station (also known as the Hobbs Generating Station) is 

16 2.4 km (1.5 mi) northeast of the proposed IIFP site; the Xcel Energy Maddox Generating Station 

17 is 3.7 km (2.3 mi) east-southeast of the proposed site; and the DCP Midstream Linam Ranch 

18 Plant is 5 km (3.1 mi) southeast of the proposed site (Figure 3-2). 

19 The nearest residence is west-northwest of the site approximately 2.6 km (1.6 mi) from the 

20 northern boundary of the site (Figure 3-2). There are no public recreational areas or National 

21 Register of Historic Places (NRHP)-listed historic structures or properties within 10 km (6 mi) of 

22 the proposed facility. 

23 Other than the proposed IIFP facility (Phase 1 and Phase 2), there are no current developments 

24 or proposed developments in the ROI. The proposed IIFP site is not subject to local or county 

25 zoning, land use planning, or associated review process requirements; and there are no 

26 potential conflicts of land use plans, policies, or controls (Appendix A). 

27 The State of New Mexico and Lea County have transferred ownership of the proposed 259-ha 

28 (640-ac) site from the State and Lea County to IIFP. The transfer to IIFP was part of an 

29 economic incentives package developed by the Economic Development Corporation of Lea 

30 County. The land transfer was carried out in accordance with the New Mexico Economic 

31 Development Act. 

32 See Section 3.6.4 for a discussion of farmland protection programs in New Mexico. 

33 3.3 Historic and Cultural Resources 

34 This section includes a description of the potential and documented human habitation on and 

35 near the proposed IIFP site, and a discussion of significant offsite historic resources and the 

36 regional setting. The ROIs for historic and cultural resources are explained later in this section, 

37 corresponding to Areas of Potential Effect (APEs), which vary for different resources that could 

38 be directly or indirectly affected. 

39 Southeastern New Mexico was settled by humans approximately 12,000 years ago. The 

40 cultural sequence in the region includes six chronological periods: the Paleo-Indian period 

41 (10,000 B.C. to 7,000 B.C.), the Archaic period (5,000 B.C. to A.D. 1000), the Formative period 

42 (A.D. 900 to 1500), the Protohistoric/Spanish Colonial period (1541 to 1800), the Mexican 
 3-5 

1 period (1828 to 1834), the Territorial period (1834 to 1912), and the Statehood period (1912 to 

2 present) (NMHPD, 2001). 

3 While archeological sites documenting occupation during all of these periods have been 

4 identified in southeastern New Mexico, the proposed project site on the Llano Estacado is part 

5 of a flat, arid plain without permanent or even intermittent water sources. While the Paleo6 Indians used the Llano Estacado for hunting when the climate was less arid (prior to 6000 B.C.), 

7 it was not hospitable to more extensive human occupation (Rothman and Holder, 1998). 

8 Archaeological resource records indicate prehistoric, protohistoric, and historic human 

9 occupation in areas of southeastern New Mexico within the Llano Estacado only in areas with 

10 reliable potable water, shelter, and food. Therefore, because there is no permanent water 

11 source near the site (see Section 3.7.2), the potential for archeological resources is low at the 

12 IIFP site and any prehistoric, protohistoric, or historic activity would have been transient. Only 

13 isolated artifacts have been found in the vicinity of the proposed IIFP site (Daras, 2009). 

14 3.3.1 Prehistoric Occupation 

15 The initial prehistoric period in New Mexico, the Paleo-Indian period, is characterized by kill 

16 sites, camp sites, butchering sites, and lithic quarries associated with small, nomadic groups 

17 subsisting by the hunting of now-extinct large game animals such as mammoths and large 

18 bison. The Paleo-Indian period is better represented in the southeastern quadrant of the State 

19 than in any other area of New Mexico (Main, 1992). Several Paleo-Indian hunting sites have 

20 been found on the Llano Estacado, although none have been found in the vicinity of the 

21 proposed IIFP site (Daras, 2009). During the Archaic period, people became more sedentary 

22 as a society, settling in small bands along major watercourses in response to drier conditions. 

23 The vicinity of the proposed IIFP site, far from permanent watercourses, would have been 

24 unattractive for hunting, gathering, or settlement (Rothman and Holder, 1998). During the 

25 Formative (or Ceramic) period tribal groups became increasingly settled and concentrated 

26 within villages and base campsites. Formative period sites also were generally located near 

27 permanent sources of water, and the proposed site’s setting within the Llano Estacado - far from 

28 watercourses - remained unsuitable for increasingly sedentary and growing populations 

29 (Rothman and Holder, 1998). Therefore, the proposed IIFP site is not expected to yield 

30 significant Formative period archaeological resources. 

31 3.3.2 Historic Indian Tribes 

32 By the early 1540s, when Spanish explorer Vasquez de Coronado arrived in New Mexico, the 

33 southeastern quadrant of the State was dominated by small hunter-gatherer groups and small 

34 settlements along river valleys such as the Pecos (Rothman and Holder, 1998). The groups 

35 occupying the region included the Suma, the Tigua, and the Jumano (Gerald, 1974; Kelley, 

36 1986; Hickerson, 1994). In the nineteenth century, these groups were replaced by Apache and 

37 Plains Indians, including the Kiowa and Comanche (Hickerson, 1994). Tribal testimony before 

38 the U.S. Indian Claims Commission indicates that the proposed IIFP site lies west of a large 

39 area used and/or or occupied by the Plains Apache, Comanche, and Kiowa; and east of a large 

40 area used by the Mescalero Apache (ICC, 1979). However, the proposed IIFP site was not 

41 known to be occupied, or known to have been used, other than for hunting, by tribes who 

42 occupied lands to the east (Plains Apache, Comanche, and Kiowa) and west (Mescalero 

43 Apache). 

44 Today, the Mescalero Apache Reservation is approximately 190 km (118 mi) west of the 

45 proposed site, in northeast Otero County, New Mexico. The Kiowa, Plains Apache, and 
 3-6 

1 Comanche reservations are in south central Oklahoma, approximately 570 km (354 mi) to the 

2 northeast. A remnant group of the Tigua (Ysleta del Sur Pueblo) has traditional-use areas, 

3 where activities such as hunting and gathering have traditionally occurred, in the general project 

4 area, which includes large areas appropriate for traditional cultural uses throughout the region. 

5 Therefore, the land containing the proposed IIFP site is not unique in providing traditional 

6 cultural use opportunities for Native Americans. 

7 3.3.3 Historic Euro-American Exploration and Settlement 

8 Historic Euro-American interests in the region began with Spanish exploration in the mid- to 

9 late-sixteenth century during the Protohistoric/Spanish Colonial Period. There is no indication 

10 that any of the Spanish expeditions during the sixteenth and seventeenth centuries ventured 

11 near the vicinity of the proposed project site, with almost all activity confined to the river valleys 

12 of the Rio Grande and Pecos River (Rothman and Holder, 1998). The Llano Estacado region 

13 was one of the last areas of New Mexico to be settled by Euro-Americans, because of the lack 

14 of surface water and semiarid climate. No settlement or significant activities took place in the 

15 vicinity of the proposed site during the Mexican Period. In the 1810s and 1820s, sheep 

16 ranchers, formerly concentrated west of and along the Rio Grande River, began to move into 

17 the eastern plains and the Pecos Valley (Merlan, 2010), but would not likely have ventured into 

18 the dry Llano Estacado region in the vicinity of the proposed site, and no archeological 

19 resources from this period were found in the vicinity of the proposed IIFP site. 

20 During the Territorial Period, some Texas cattle ranchers drove their herds through 

21 southeastern New Mexico along the Goodnight-Loving Trail, which followed the Pecos River 

22 approximately 80 km (50 mi) west of the proposed site (Clampitt, 2008). Euro-American 

23 settlement in the area began in the late nineteenth and early twentieth centuries during the 

24 Territorial period, prior to New Mexico achieving statehood in 1912. After the American Civil 

25 War, homesteaders established ranches at Monument Springs, near Monument, New Mexico 

26 (Anderson, Undated). 

27 The Hat Ranch, established in 1890 and variously known as “Monument Springs” and the 

28 “Monument Springs Ranch,” was the largest ranch in the area. It operated on more than one 

29 million acres of purchased and leased public lands from Seminole, Texas westward to the 

30 Pecos River, and northward to the vicinity of Tatum, New Mexico, including the area of the 

31 proposed project. The ranch headquarters was established near Monument Springs, about 

32 10 km (6 mi) south-southeast from the southern extent of the proposed IIFP site (Anderson, 

33 Undated). As one of New Mexico's first large-scale cattle ranching operations, the Hat Ranch at 

34 its peak in the early 1900s had 50,000 head of cattle, 500 saddle horses, 26 water wells, and 

35 several windmills and ranch houses (Anderson, Undated; NMMA, Undated), however, no 

36 structures associated with the Hat Ranch have been documented on the IIFP site. 

37 During the early Statehood Period, most of the land continued to serve as pasture for cattle 

38 grazing. In the open-range tradition, no fences were used to demarcate property lines in Lea 

39 County into the 1910s and 1920s (Merlan, 2010). The ranch continues operation today on 

40 reduced acreage, and the headquarters remain at Monument Spring, where the ranch owners 

41 reside (Hat Ranch, 2010). The Hat Ranch is not listed in or determined eligible for the NRHP, 

42 but is listed on New Mexico’s State list of historic resources (NMHPD, 2011). 
 3-7 

1 3.3.4 Archaeological and Historic Resources at the Proposed IIFP Site 

2 This section describes the historic and cultural resources in the vicinity of the proposed IIFP 

3 facility. Historic and cultural resources include archaeological sites, architectural resources 

4 (such as historic structures, objects, districts, or landscapes) and places of cultural importance 

5 to groups for maintaining their heritage. Cultural resources are nonrenewable; that is, once 

6 adversely altered, the information contained in cultural resources cannot be recovered. 

7 The National Historic Preservation Act of 1966, as amended (NHPA), requires that all adverse 

8 effects to National Register of Historic Places (NRHP)-listed and eligible historic and cultural 

9 resources be considered during Federal undertakings, such as the NRC licensing activity for the 

10 proposed IIFP facility. The requirement to consider adverse effects to cultural resources takes 

11 the form of a consultation process and/or mitigation. A resource is eligible for listing on the 

12 NRHP if it meets at least one of the following four criteria (36 CFR 60.4): (1) association with an 

13 historic person, (2) association with a historic event, (3) representation of the work of a master, 

14 or (4) potential to provide information on the history or prehistory of the United States. 

15 Section 106 of the NHPA identifies the process for considering whether a project would affect 

16 significant cultural resources, which are discussed in Chapter 4 of this draft EIS. The 

17 archaeological APE for the Section 106 review for the proposed IIFP facility is the 16 ha (40 ac) 

18 proposed facility site (Figure 2-2), the access road from NM 483, and an external parking lot 

19 immediately outside the security fence surrounding the facility property all of which would be 

20 directly affected by construction. The architectural resource APE includes the viewshed from 

21 any NHRP-eligible historic resources which would include the proposed facility structures. The 

22 APE also considers the potential auditory or direct physical impacts of the project to historic 

23 architectural resources. A distance of 10 km (6 mi) from the project site was determined to be 

24 an appropriate APE, based on the height of the facility security fence and the facility buildings, 

25 which would generally be less than 6 m (20 ft) high. 

26 The Section 106 process requires consultation between the lead Federal agency and the State 

27 Historic Preservation Office (SHPO), which is the custodian of information on cultural resources 

28 for the State. The Section 106 process also requires that Federally recognized Native American 

29 Tribes who have ancestral interest in the property be consulted to determine if resources 

30 important to the Tribe are present (36 CFR 800.2(4)(c)(ii)). 

31 Information on historic and archaeological resources at the proposed IIFP site was obtained by 

32 a file review completed by the applicant’s archaeological resources consultant at the Historic 

33 Preservation Division of the New Mexico Office of Cultural Affairs on April 17, 2009, and from an 

34 archaeological survey conducted by IIFP’s archaeological consultant in response to the New 

35 Mexico State Land Office for the proposed project in May 2009 (Daras, 2009). 

36 According to the Archaeological Resource Management Records Section of the New Mexico 

37 Office of Cultural Affairs, the proposed IIFP site had not been the focus of a cultural resource 

38 survey, and no archaeological or historic architectural resources were identified at the proposed 

39 site prior to the 2009 cultural resources survey (Daras, 2009) conducted by the applicant. 

40 The New Mexico State Register of Cultural Resource Properties lists one historic resource 

41 within 10 km (6 mi) of the proposed site. This is the cluster of stone ranch houses and 

42 outbuildings that make up the Hat Ranch Headquarters (Site LA 43256, SR #162), which is 

43 approximately 9.5 km (5.9 mi) from the southern boundary of the proposed site. As noted 

44 earlier, the Hat Ranch Headquarters has not been listed in or determined eligible for the NRHP 
 3-8 

1 (NMHPD, 2011); therefore, it is not an historic property subject to protection under Section 106 

2 of the National Historic Preservation Act. 

3 IIFP’s archaeological consultant conducted a cultural resource survey in May 2009 on the entire 

4 249-ha (640-ac) Section 27 tract. The survey was conducted according to New Mexico’s 

5 Cultural Properties and Historic Preservation, Standards for Survey and Inventory (NMHPD, 

6 2005 and consisted of systematic surface pedestrian coverage at 15-m (49-ft) intervals. The 

7 survey identified three isolated artifacts, but no archaeological sites. The isolated artifacts were 

8 the distal end of a San Jose (Archaic period) chert projectile point, a gray quartzite 

9 hammerstone, and three decolorized manganese glass vessel fragments. In accordance with 

10 Section 18-6-5 of the New Mexico Cultural Properties Act, the archaeological consultant 

11 completed a “negative survey report” to describe the survey and record the isolated artifact 

12 occurrences. The isolated occurrences were recorded, and the State Land Office and their 

13 contract archaeologists recommended no further archaeological studies or evaluations (Daras, 

14 2009). The State Land Office cultural resources survey did not note the presence of any historic 

15 structures or structural remains. 

16 Consultation with Native American Tribes was undertaken using a list maintained by the New 

17 Mexico (NM) SHPO. The NRC staff received three responses (Appendix B). On July 13, 2010, 

18 the Ysleta del Sur Pueblo stated that the Pueblo believes the project will not adversely affect 

19 traditional, religious, or culturally significant sites, but requested consultation should human 

20 remains or artifacts regulated by the Native American Graves Protection and Repatriation Act

21 be discovered. On June 15, 2011, the Tribal Historic Preservation Officer for the Comanche 

22 tribe noted that he had no comments on the project. On July 13, 2011, the Shawnee Tribe’s 

23 Tribal Historic Preservation Department concurred that no known historic properties would be 

24 impacted by the project, but also requested consultation if archaeological materials are 

25 encountered during construction or operation of the facility. 

26 In a letter dated October 14, 2010, from David C. Eck, Trust Land Archaeologist, in the office of 

27 the State of New Mexico Commissioner of Public Lands, to Jan Biella, New Mexico Historic 

28 Preservation Division (Appendix B), the Commissioner’s Office states that it “recommends a 

29 finding of no effect/no cultural properties /no historic properties.... There are no documented 

30 cultural properties within the Area of Potential Effect (APE) when considering direct effects. 

31 Similarly, there are no registered cultural properties within the assumed, five-mile APE when 

32 considering indirect effects.” The New Mexico State Historic Preservation Officer concurred 

33 with this determination (Appendix B). 

34 3.4 Visual Resources 

35 This section includes a description of the visual setting on and near the proposed IIFP site. For 

36 the purposes of this draft EIS, the ROI for visual resources is defined as the area within a 10 km 

37 (6 mi) radius of the center point of the proposed IIFP site; accounting for the view of, and view 

38 from, the proposed facility. 

39 The 259-ha (640-ac) site is flat and sparsely developed with a few irregularly spaced structures 

40 for natural gas and oil extraction, and overhead transmission lines. The proposed IIFP facility 

41 would be approximately 22.5 km (14 mi) west of the nearest population center, Hobbs, New 

42 Mexico, and would not be visible from Hobbs. As noted in Section 3.2, four energy industry 

43 facilities are less than 10-km (6-mi) of the proposed site, and three are visible from the site. The 

44 proposed IIFP site is 1.6 km (1 mi) north of US 62/180 and is bordered on the west by NM 483. 
 3-9 

1 Although the proposed IIFP facility would be located near the center of the site, it is anticipated 

2 that it would be visible from both roads. 

3 No mountain ranges are in the site vicinity. The landscape of the site and vicinity is typical of a 

4 semi-arid climate and consists of caliche soils with Plains vegetation such as mesquite bushes 

5 and native prairie grasses. 

6 As noted in Section 3.2, no recreational areas are within 10 km (6 mi) of the site. The closest 

7 recreation facilities are golf courses 12 km (7.5 mi) east and northeast (Hobbs Country Club, 

8 2010; Ocotillo Park Golf Course, 2010), and a motorsports park, also 12 km (7.5 mi) northeast 

9 (Hobbs Motorsport Park, 2010). These recreational facilities are not within the visual resources 

10 ROI of the site. The nearest residence is approximately 2.6 km (1.6 mi) northwest of the site 

11 boundary. A State-listed historic site, Monument Springs, is approximately 10 km (6 mi) 

12 southeast of the site. 

13 IIFP assessed the scenic quality of the proposed IIFP site using the U.S. Bureau of Land 

14 Management (BLM) visual resource inventory process (BLM, 2007). A visual rating is 

15 determined by evaluating potential impacts of a proposed project on the surrounding area. 

16 Classes range from Classes I and II (most valued), through Class III (moderate value), to Class 

17 IV (least valued). Based on the visual resource inventory, the proposed IIFP site was 

18 determined to be in Class IV (IIFP, 2009). This rating means that the level of change to the 

19 characteristic landscape can be high, and allows for the greatest level of landscape 

20 modification. 

21 3.5 Climatology, Meteorology, and Air Quality 

22 3.5.1 Climatology 

23 The climate in the region of the proposed IIFP site is semi-arid with mild temperatures, low 

24 precipitation and humidity, and a high evaporation rate. The weather is often dominated in the 

25 winter by high-pressure systems in the central part of the U.S. and low-pressure systems in 

26 north-central Mexico. The region is typically affected by low-pressure systems located over 

27 Arizona in the summer (WRCC, 2010). 

28 The mean monthly temperature over the last 98 years has ranged from 5.7oC (42.2oF) in 

29 January to 26.8oC (80.2oF) in July. July is the hottest month with an average maximum of 

30 34.3oC (93.9oF) and an average minimum of 19.2oC (66.6oF). January is the coldest month with 

31 an average minimum of -2.3oC (27.9oF) and an average maximum of 13.6oC (56.4oF) (WRCC, 

32 2010). 

33 The average annual total rainfall in Hobbs, New Mexico, is 40.54 cm (15.96 in). Average 

34 monthly rainfall ranges from 1.14 cm (0.45 in) in January to 6.58 cm (2.59 in) in September. 

35 The mean annual snowfall in Hobbs is 12.7 cm (5.01 in) (WRCC, 2010). 

36 Thunderstorms occur in Lea County throughout the year, though they are most common in the 

37 spring and summer, and occasionally include hail. Thunderstorms occur on average 36 days 

38 per year. Summer rains fall almost entirely during brief, but frequently intense, thunderstorms. 

39 Rain showers and thunderstorms from June through September account for more than half the 

40 annual precipitation. The general southeasterly circulation towards the Gulf of Mexico brings 

41 moisture from the Pacific into New Mexico, and strong surface heating, combined with lifting as 

42 the air moves over higher terrain, causes air currents and condensation. As storms move inland 
 3-10 

1 from the Pacific Coast, much of the moisture is precipitated over the coastal and inland 

2 mountain ranges of California, Nevada, Arizona, and Utah. Much of the remaining moisture falls 

3 on the western slope of the Continental Divide, which is west of the proposed site, and over 

4 northern and high-central mountain ranges. Winter is the driest season in eastern New Mexico. 

5 On average, nine tornadoes are reported per year in New Mexico. Ninety-two tornadoes were 

6 reported in Lea County from January 1950 to May 2010. There has only been one tornado 

7 reported in Hobbs, New Mexico, in May 1997 (NCDC, 2010). 

8 Wind speeds in New Mexico are usually moderate, although relatively strong winds often 

9 accompany occasional weather fronts during late winter and spring and sometimes occur just in 

10 advance of thunderstorms. Frontal winds may exceed 48.3 kilometers per hour (km/hr) 

11 (30 miles per hour [mph]) for several hours and reach peak speeds of more than 80.5 km/hr 

12 (50 mph) (WRCC, 2010). Winds are generally stronger in the eastern plains, to the north of the 

13 proposed facility, than in other parts of the state. Winds are generally from the southeast in 

14 summer and from the west in winter, but local surface wind directions will vary greatly because 

15 of local topography and mountain and valley breezes (WRCC, 2010). 

16 Blowing sand may occur occasionally in the area due to the combination of strong winds, sparse 

17 vegetation, and the semi-arid climate. High winds associated with thunderstorms are frequently 

18 a source of localized blowing dust. Dust storms that cover an extensive region are rare; and 

19 those that reduce visibility to less than 1.6 km (1 mi) occur only with the strongest pressure 

20 gradients such as those associated with intense extra-tropical cyclones which occasionally form 

21 in the area during winter and early spring (DOE, 2006). 

22 3.5.2 Greenhouse Gases 

23 Greenhouse gases (GHGs) include those gases, such as carbon dioxide (CO2), water vapor, 

24 nitrous oxide (N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and 

25 sulfur hexafluoride (SF6), that are transparent to solar (short-wave) radiation but opaque to long 

26 wave (infrared) radiation from the earth’s surface. The net effect over time is a trapping of 

27 absorbed radiation and a tendency to warm the planet’s surface and the boundary layer of the 

earth’s atmosphere, which constitute the “greenhouse effect” (IPCC, 2007). Some direct GHGs1 28 

29 (CO2, CH4, and N2O) are both naturally occurring and the product of industrial activities, while 

30 others, such as the hydrofluorocarbons, are man-made and are present in the atmosphere 

31 exclusively due to human activities. Each GHG has a different radiative forcing potential, which 

is defined as the gas’ ability to affect a change in climatic conditions in the troposphere2 32 (IPCC, 

33 2007). The radiative efficiency of a GHG is directly related to its concentration in the 

34 atmosphere. 

35 As a way to compare the radiative forcing potentials of various GHGs without directly calculating 

36 changes in their atmospheric concentrations, an index known as the Global Warming Potential 

(GWP) (IPCC, 2007) has been established with CO2 as the reference point3 37 . GWPs are 

38 calculated as the ratio of the radiative forcing that would result from the emission of 1 kg 

 

1

 Direct GHGs are those gases that can directly affect global warming once they are released into the 

atmosphere. 

2

 Radiative forcing potential is expressed as the amount of thermal energy [in watts] trapped by the gas 

per square meter of the earth’s surface. 

3

 Water vapor is the most abundant and most dominant greenhouse gas in the atmosphere. However, it 

is neither long-lived nor well mixed in the atmosphere, varying from 0 to 2 percent. CO2 is the most 

abundant of GHGs released to the atmosphere after water vapor. 
 3-11 

1 (2.2 lbs) of a GHG to that which would result from the emission of 1 kg (2.2 lbs) of CO2 over a 

2 fixed period of time. GWPs represent the combined effect of the amount of time each GHG 

3 remains in the atmosphere and its ability to absorb outgoing thermal infrared radiation. As the 

4 reference point in this index, CO2 has a GWP of 1. On the basis of a 100-year time horizon, 

5 GWPs for other key GHGs are as follows: 21 for CH4, 310 for N2O, 11,700 for HFC-23, and 

23,900 for SF6 (IPCC, 2007). Indirect GHGs, carbon monoxide (CO), nitrogen oxides (NOx)

4 6 , 

7 nonmethane volatile organic compounds (NMVOCs), and sulfur dioxide (SO2), indirectly affect 

8 terrestrial solar radiation absorption by influencing the formation and destruction of tropospheric 

9 and stratospheric ozone or, in the case of SO2, by affecting the absorptive characteristics of the 

10 atmosphere. 

11 3.5.2.1 Greenhouse Gas Emissions and Sinks in the United States 

12 The U.S. Environmental Protection Agency (EPA) is responsible for preparation and 

13 maintenance of the official U.S. Inventory of Greenhouse Gas Emissions and Sinks to comply 

14 with existing commitments under the United Nations Framework Convention on Climate 

15 Change. GHG sinks are those activities or processes that can remove GHGs from the 

atmosphere. GHG emissions5 16 are reported in sectors, using the GWPs established in the 

Second Assessment Report of the Intergovernmental Panel on Climate Change (IPCC)6 17 . Site 

18 preparation, construction, operation, and decommissioning of the proposed IIFP facility would 

19 result in the release of GHGs as a result of the same human activities that were identified by 

20 EPA as the sources of GHGs in the U.S. Inventory. Results of the most recent report on the 

21 U.S. Inventory of GHG Emissions and Sinks (EPA, 2010a) for direct GHGs that are most 

22 relevant to the proposed IIFP facility include: 

23 • The primary GHG emitted by human activities in the U.S. was CO2, representing 

24 approximately 85.1 percent of the total GHG emissions. 

25 • In 2008, total U.S. GHG emissions were 6,957 teragrams of CO2 equivalent (Tg CO2

26 Eq), an increase of 14 percent from 1990. 

27 • Overall emissions of GHGs fell 2.9 percent from 2007 to 2008. 

28 • CO2 emissions for 2008 were 5,921.2 Tg CO2 Eq, of which 5,572.8 was the result of the 

29 combustion of fossil fuel primarily related to electricity generation (2,363.5), 

30 transportation (1,785.3), industrial applications (819.3), residential heating (342.7), and 

31 commercial applications (219.5) (this considers only fossil fuel emissions in the 50 U.S. 

32 states, not the U.S. territories). 

33 • Fifty-three percent of the CO2 emissions related to transportation were the result of 

34 consumption of gasoline in privately owned vehicles; the remainder was from 

35 combustion of fuels in diesel trucks and aircraft. 

36 • Emission of CH4 in 2008 as a result of combustion of fossil fuels in mobile sources was 

37 2.0 Tg CO2 Eq. 

 

4

 NOx represents all thermodynamically stable oxides of nitrogen, excluding nitrous oxide (N2O). 5 In keeping with the GWP convention that names CO2 as the reference gas, assigning it a GWP of 1, 

GWPs of other direct GHGs are expressed as equivalents (Eq.) of CO2, as teragrams (Tg) of CO2

equivalent (Tg CO2 Eq.). One Tg is equal to 1012 grams, or one million metric tons (1.102 million tons). 6

 IPCC assessment reports are a compilation of separate reports of the various working groups that are 

established by the Panel. IPCC periodically updates assessment reports to incorporate newly 

established data, including revisions to GWPs and radiative forcing potentials of GHGs. 
 3-12 

1 • Emission of N2O in 2008 as a result of combustion of fossil fuels in mobile sources was 

2 26.1 Tg CO2 Eq. 

3 • Emission of HFCs (released from equipment) in 2008 was 113 Tg CO2 Eq. 

• Emission of SF6 in 2008 as a result of electrical transmission and distribution7 4 was 

5 13.1 Tg CO2 Eq. 

6 • The primary GHG sinks functional in 2008 included carbon sequestration in forests, 

7 trees in urban areas, agricultural soils, and landfilled yard trimmings and food scraps, all 

8 of which, in aggregate, offset 13.5 percent of the total GHG emissions in 2008. 

9 • The most significant emissions of indirect GHGs in 2008 included: 

10 o 13,578 Tg CO2 Eq. of NOx, primarily from mobile fossil fuel combustion (7,441), 

11 stationary fuel combustion (5,148), and industrial processes (520). 

12 o 60,739 Tg CO2 Eq. of CO, primarily from mobile fossil fuel combustion (51,533), 

13 stationary fossil fuel combustion (4,792), and industrial processes (1,682). 

14 o 13,254 Tg CO2 Eq. of NMVOCs, primarily from mobile fossil fuel combustion 

15 (5,447), solvent use (3,834), industrial processes (1,804), and stationary fossil 

16 fuel combustion (1,321). 

17 o 10,368 Tg CO2 Eq. of SO2, primarily from stationary fossil fuel combustion 

18 (8,891), industrial processes (795), and mobile fossil fuel combustion (472). 

19 As noted above, consumption of fossil fuels for electricity generation represents the single 

20 greatest source of CO2 emissions in 2008 (2,363.5 Tg CO2 Eq.). The total gross GHG 

21 emissions in the United States from all sectors (transportation, industrial, residential, and 

22 commercial) in 2008 were 6,957 Tg CO2 Eq. Net emissions (considering all emissions and 

23 sinks) were 6,016.4 Tg CO2 Eq. 

24 3.5.2.2 Greenhouse Gas Emissions and Sinks in New Mexico 

25 A review of statewide emissions of GHGs can inform an understanding of the impact anticipated 

26 GHG emissions from the proposed IIFP facility would have in a regional context. Among the 

27 United States, New Mexico ranks 35th with respect to GHGs emissions and 35th in population, 

based on 2003 data (CRS, 2007). The Center for Climate Strategies8 28 , published a report in 

29 November 2006 on New Mexico’s Greenhouse Gas Inventory and Reference Case Projections 

30 for the period 1990–2020 (CCS, 2006). Table 3-1 shows New Mexico GHG emissions by 

31 sector. Table 3-2 compares the most recent GHG inventories by sector in New Mexico with the 

32 United States as a whole in calendar year 2000. 

 

7

 SF6 is a gas at standard conditions and is used as a dielectric medium in high-voltage electrical 

equipment. 

1

 SF6 is a gas at standard conditions and is used as a dielectric medium in high-voltage electrical 

equipment. 

on established in 2004 to assist in climate policy development at the Federal and State levels. 8

 The Center for Climate Strategies is a public-purpose, nonprofit, nonpartisan 501(c)(3) partnership 

organization established in 2004 to assist in climate policy development at the Federal and State levels. 
 3-13 

1 Table 3-1. New Mexico GHG Emissions, by Sector 

Sector 

Carbon Dioxide Equivalents 

(million metric tons) 

19901 20001 20102 20202

Electricity Production 29.5 33.2 33.3 38.8 

Coal 28.0 30.7 30.4 35.5 

Natural Gas 1.4 2.5 2.9 3.2 

Oil 0.0 0.0 0.0 0.0 

Residential/Commercial/Non-Fossil Industrial (RCI) 7.0 7.3 8.5 9.9 

Coal 0.1 0.2 0.2 0.2 

Natural Gas 3.8 4.6 4.5 5.4 

Oil 3.1 2.5 3.8 4.3 

Wood (CH4 and N2O) 0.0 0.0 0.0 0.0 

Transportation 11.0 14.2 17.6 22.3 

On-road Gasoline 7.2 8.7 10.2 12.2 

On-road Diesel 2.5 4.2 5.6 7.9 

Natural Gas, LPG, Other 0.1 0.1 0.1 0.1 

Jet Fuel and Aviation Gasoline 1.2 1.2 1.6 2.0 

Fossil Fuel Industry 15.2 19.5 20.3 20.7 

Natural Gas Industry 12.7 17.0 17.3 17.7 

Oil Industry 2.3 2.3 2.3 2.3 

Coal Mining (Methane) 0.2 0.2 0.7 0.7 

Industrial Processes3 0.5 1.5 2.0 2.8 

ODS Substitutes 0.0 0.5 1.3 2.3 

PFCs in Semi-conductor Ind. 0.1 0.5 0.2 0.1 

SF6 from Electric Utilities 0.2 0.1 0.1 0.0 

Cement & Other Industry 0.2 0.4 0.4 0.4 

Waste Management 0.8 1.2 1.4 1.2 

Solid Waste Management 0.6 1.0 1.1 0.9 

Wastewater Management 0.2 0.2 0.3 0.3 

Agriculture 4.5 6.0 6.4 6.7 

Manure Management & Enteric Ferment (CH4) 2.3 3.5 4.1 4.4 

Agricultural Soils (N2O) 2.2 2.4 2.3 2.3 

Total Gross Emissions 68.5 82.9 89.4 102.4 

Forestry and Land Use -20.9 -20.9 -20.9 -20.9 

Net Emissions (incl. forestry) 47.6 62.0 68.5 81.5 

2 Source: CCS, 2006 

1 3 Historical estimates 

2 4 Projected estimates

3 5 The proposed facility would be classified in the Industrial Processes sector. 

6 
 3-14 

Table 3-2. Comparison of New Mexico vs. U.S. GHG Emissions (Percent) by Sector1 1 

Sector Percent of State Total 

GHG Emissions2

Percent of U.S. GHG 

Emissions2

Electricity 40 32 

Fossil fuel industry (CH4) 23 3 

Transportation 17 26 

Agriculture 7 7 

Residential/commercial fuel use 5 9 

Non-Fossil Industrial fuel use 4 14 

Waste 2 4 

Industrial processes 2 5 

2 Source: CCS, 2006 

1 3 All data, calendar year 2000 

2 4 As shown in Table 3-1, total net CO2 emissions for New Mexico for the year 2000 were 62 million metric tons (68 

5 million tons) of CO2 equivalents. For the United States for that same year, total net CO2 emissions were 5,977 million 

6 metric tons (6,588 million tons) (EPA, 2010a) 

7 

8 In March 2010, the NMED published the Inventory of New Mexico Greenhouse Gas Emissions: 

9 2000-2007 which presented estimates of historical New Mexico anthropogenic GHG emissions. 

10 This information was compiled to support efforts to address anthropogenic climate change, 

11 including those of the Climate Change Action Implementation Team, which was created by 

12 Executive Order 2006-69 – New Mexico Climate Change Action. As reported in the inventory, 

13 after a 3 percent annual GHG emissions growth rate experienced from 1990 to 2000, the total 

14 (gross) direct emissions in New Mexico remained essentially level from 2000 to 2007 despite a 

15 6.7 percent growth in New Mexico’s population over that period (NMED, 2010a). 

16 3.5.2.3 Projected Impacts from Construction and Operation of the Proposed IIFP 

17 Facility on Carbon Dioxide and Other Greenhouse Gases 

18 Site preparation, construction, operation, and decommissioning of the proposed IIFP facility can 

19 be expected to result in emissions of CO2 and other GHGs through various mechanisms, 

20 primarily from combustion of fossil fuels in both mobile and stationary sources. Individual 

21 contributions of construction and operations are discussed in Chapter 4. Transportation 

22 volumes used in the following sections were established in Section 4.1.2.9 and are applied here 

23 without modification. 

24 3.5.3 Meteorology 

25 The closest National Climatic Data Center Cooperative Network weather station to the IIFP site 

26 with the longest length of service is the Hobbs weather station, at the Hobbs Regional Airport, 

27 approximately 13 km (8 mi) east of the proposed site, which has been in service since 1912. 

28 The most recent data available for the Hobbs weather station from the Western Regional 

29 Climate Center are from July 2010. 

30 Table 3-3 presents a summary of temperatures from the Hobbs weather station from 1912 to 

31 2010. July, on average, is the hottest month and January is the coldest month. The highest 

32 temperature measured over the period of record, 45.6oC) (114oF), occurred in June 1998. The 

33 lowest temperature measured, -21.7oC (-7oF), occurred in January 1962. 
 3-15 

1 Table 3-3. Monthly Temperature in Hobbs, New Mexico, 1912 to 2010 

Monthly Averages Daily Extremes 

Month Maximum Minimum Mean High Date Low Date 

January 13.6°C 

(56.4°F) 

-2.3°C 

(27.9°F) 

5.7°C 

(42.2°F) 

28.3°C 

(83°F) 1/11/1953 -21.7°C 

(-7°F) 1/11/1962 

February 16.6°C 

(61.8°F) 

0.0°C 

(32.0°F) 

8.3°C 

(46.9°F) 

30.6°C 

(87°F) 2/12/1962 -18.9°C 

(-2°F) 2/2/1985 

March 20.6°C 

(69.1°F) 

3.1°C 

(37.5°F) 

11.8° 

(53.3°F) 

35.0°C 

(95°F) 3/27/1971 -17.2°C 

(1°F) 3/2/1922 

April 25.4°C 

(77.8°F) 

7.9°C 

(46.3°F) 

16.7°C 

(62.1°F) 

36.7°C 

(98°F) 4/30/1928 -7.8°C 

(18°F) 4/4/1920 

May 29.8°C 

(85.6°F) 

12.9°C 

(55.3°F) 

21.3°C 

(70.4°F) 

41.7°C 

(107°F) 5/30/1951 1.1°C 

(34°F) 5/2/1916 

June 33.9°C 

(93.0°F) 

17.5°C 

(63.5°F) 

25.7°C 

(78.2°F) 

45.6°C 

(114°F) 6/27/1998 4.4°C 

(40°F) 6/3/1919 

July 34.4°C 

(93.9°F) 

19.2°C 

(66.6°) 

26.8°C 

(80.2°F) 

43.3°C 

(110°F) 7/15/1958 10.0°C 

(50°F) 7/1/1927 

August 33.4°C 

(92.2°F) 

18.7°C 

(65.6°F) 

26.1°C 

(78.9°F) 

41.7°C 

(107°F) 8/9/1952 8.3°C 

(47°) 8/29/1916 

September 29.9°C 

(85.8°F) 

15.2°C 

(59.3°F) 

22.5°C 

(72.5°F) 

40.6°C 

(105°F) 9/5/1948 1.1°C 

(34°F) 9/23/1948 

October 25.0°C 

(77.0°F) 

9.1°C 

(48.4°F) 

17.1°C 

(62.7°F) 

36.7°C 

(98°F) 10/3/2000 -11.1°C 

(12°F) 10/29/1917

November 18.4°C 

(65.2°F) 

2.7°C 

(36.8°F) 

10.6°C 

(51.0°F) 

31.1°C 

(88°F) 11/1/1952 -15.6°C 

(4°F) 11/29/1976

December 14.3°C 

(57.7°F) 

-1.4°C 

(29.4°F) 

6.5°C 

(43.7°F) 

28.9°C 

(84°F) 12/9/1922 -18.3°C 

(-1°F) 12/24/1983

Source: WRCC, 2010 

2 

3 Table 3-4 summarizes precipitation at the Hobbs weather station from 1912 to 2010. 

4 September, on average, is the wettest month, while January and February receive the least 

5 precipitation. The one-day maximum rainfall of 19.05 cm (7.5 in) occurred in September, 1995. 

6 The NRC staff prepared an EIS for the National Enrichment Facility in Eunice, New Mexico 

7 (NRC, 2005). The NRC staff examined climatology data from four weather stations in the area: 

8 Eunice, New Mexico; Hobbs, New Mexico; Midland-Odessa, Texas; and Roswell, New Mexico. 

9 Table 3-5 describes these weather stations’ locations relative to the proposed IIFP site, and the 

10 historic records available for each station. 

11 The data presented in the National Enrichment Facility EIS indicate that the general wind 

12 patterns for Midland-Odessa, Hobbs, and Eunice were similar (NRC, 2005). Roswell data 

13 appeared to have a stronger northerly and westerly component. 

14 Midland-Odessa and Hobbs had comparable climate data based on a comparative analysis of 

15 meteorological data at the four weather stations nearest the proposed IIFP site (Table 3-5). 

16 
3-16 

Table 3-4. Monthly Precipitation in Hobbs, New Mexico, from 1912 to 2010 1 

Rainfall Snowfall 

Month Mean High Year Low Year 1-Day Maximum Mean High Year 

January 1.14 cm 

(0.45 in) 

7.52 cm 

(2.96 in) 1949 0.00 1924 3.07 cm (1.21 in) 1/11/49 3.30 cm (1.3 in) 31.75 cm (12.5 in) 1983 

February 1.19 cm 

(0.47 in) 

6.22 cm 

(2.45 in) 2010 0.00 1917 5.08 cm (2.0 in) 4/10 2.79 cm (1.1 in) 36.32 cm (14.3 in) 1973 

March 1.42 cm 

(0.56 in) 

7.57 cm 

(2.98 in) 2000 0.00 1918 5.08 cm (2.00 in) 3/20/02 1.27 cm (0.5 in) 25.40 cm (10.0 in) 1958 

April 2.01 cm 

(0.79 in) 

13.13 cm 

(5.17 in) 1922 0.00 1917 4.75 cm (1.87 in) 4/20/26 0.51 cm (0.2 in) 22.86 cm (9.0 in) 1983 

May 5.05 cm 

(1.99 in) 

35.13 cm 

(13.83 in) 1992 0.00 1938 13.21 cm (5.20 in) 5/22/92 0.0 0.0 1913 

June 4.78 cm 

(1.88 in) 

23.62 cm 

(9.30 in) 1921 0.00 1924 11.23 cm (4.42 in) 6/7/18 0.0 0.0 1913 

July 5.38 cm 

(2.12 in) 

23.90 cm 

(9.41 in) 1988 0.00 1954 11.35 cm (4.47 in) 7/19/88 0.0 0.0 1913 

August 6.12 cm 

(2.41 in) 

23.29 cm 

(9.17 in) 1920 0.10 cm (0.04 in) 1938 11.30 cm (4.45 in) 8/9/84 0.0 0.0 1913 

September 6.58 cm 

(2.59 in) 

32.99 cm 

(12.99 in) 1995 0.00 1939 19.05 cm (7.50 in) 9/15/95 0.0 0.0 1913 

October 4.01 cm 

(1.58 in) 

20.70 cm 

(8.15 in) 1985 0.00 1917 14.22 cm (5.60 in) 10/9/85 0.25 cm (0.1 in) 11.43 cm (4.5 in) 1976 

November 1.42 cm 

(0.56 in) 

11.00 cm 

(4.33 in) 1978 0.00 1915 9.65 cm (3.80 in) 11/4/78 1.52 cm (0.6 in) 41.91 cm (16.5 in) 1980 

December 1.42 cm 

(0.56 in) 

12.90 cm 

(5.08 in) 1986 0.00 1917 4.72 cm (1.86 in) 12/21/42 2.54 cm (1.0 in) 24.13 cm (9.5 in) 1986 

Annual 40.54 cm 

(15.96 in) 

81.76 cm 

(32.19 in) 1941 13.41 cm (5.28 in) 1917 19.05 cm (7.50 in) 9/15/95 12.7 cm (5.0 in) 68.83 cm (27.1 in) 1980 

Source: WRCC, 2010 
 3-17 

1 Table 3-5. Weather Stations Located Near the Proposed IIFP Site 

Station 

Distances and Direction from 

Proposed Site 

Length of Record 

(years)1 Station Elevation 

Eunice, New Mexico 34 km (21 mi) south of site 1 (1993) 1,050 m (3,445 ft) 

Hobbs, New Mexico 13 km (8 mi) east of site 16 (1982-1997) 1,115 m (3,658 ft) 

Midland-Odessa, Texas 138 km (86 mi) southeast 

of site 16 (1982-1997) 872 m (2,861 ft) 

Roswell, New Mexico 129 km (80 mi) northwest 

of site 16 (1982-1997) 1,118 m (3,668 ft) 

Source: NRC, 2005 and WRCC, 2010 

1

 Years of compiled data for climatology analysis. 

2 

3 Because Midland-Odessa was a first-order weather station with data completeness exceeding 

4 EPA requirements, NRC staff used the data from the Midland-Odessa weather station for its 

5 dispersion modeling for the National Enrichment Facility EIS. Hourly meteorological 

6 observations at Midland-Odessa were used to generate wind rose plots. Monthly wind speeds 

7 and prevailing wind directions at Midland-Odessa for the years 1987 to 1991 are presented in 

8 Figure 3-3. The annual mean wind speed was 17.7 km/hr (11 mph) and the prevailing wind 

9 direction was 180 degrees with respect to north. The maximum 5-second wind speed was 

10 112.7 km/hr (70 mph) (NRC, 2005). At Hobbs, the average wind speed varied from 16.1 km/hr 

11 (10.0 mph) for the month of August to 21.6 km/hr (13.4 mph) for the month of April. The annual 

12 average wind speed recorded at Hobbs was 18.3 km/hr (11.4 mph). The prevailing wind 

13 direction was out of the north blowing to the south. 

14 3.5.4 Air Quality 

15 3.5.4.1 Regulatory Setting 

16 3.5.4.1.1 Criteria Pollutants 

17 Under the Clean Air Act, the EPA has established National Ambient Air Quality Standards 

18 (NAAQS) that specify the maximum concentrations for seven criteria air pollutants: CO, 

19 particulate matter with aerodynamic diameters of 10 microns or less (PM10), particulate matter 

20 with aerodynamic diameters of 2.5 microns or less (PM2.5), ozone, SO2, lead, and NO2. New 

21 Mexico also has ambient air quality standards in place (New Mexico Ambient Air Quality 

22 Standards [NMAAQS]), which are equal to or more stringent than the NAAQS. NMAAQS are 

23 enforced by New Mexico, and allowed under the Clean Air Act by EPA. Table 3-6 lists the 

24 Federal and Mew Mexico Ambient Air Quality Standards. Areas with air quality as good as or 

25 better than the standards are designated as “attainment areas.” Areas with air quality that is 

26 worse than the standards are designated as “non-attainment areas.” Areas that were 

27 designated non-attainment and subsequently re-designated as attainment due to meeting the 

28 standards are termed “maintenance areas.” States with maintenance areas are required to 

29 develop an air quality maintenance plan as an element of the State Implementation Plan. 

30 The EPA divided the nation into 247 Air Quality Control Regions (AQCRs) based on a number 

31 of factors that influence regional air quality including climate and meteorology, topography, 

32 vegetation, land use patterns, population characteristics, and growth projections. Lea County is 

33 in the Pecos-Permian Basin Intrastate AQCR (40 CFR 81.242) and is in attainment for all of the 

34 NAAQS, as is the rest of the Pecos-Permian Basin Intrastate AQCR (40 CFR 81.332). The 
 3-18 

1 Figure 3-3. Wind Roses for Midland-Odessa, Roswell, Hobbs, and Eunice for 1993 

2 

3 Source: NRC, 2005 

4 

5 closest non-attainment areas are in the El Paso-Las Cruces-Alamogordo Interstate AQCR 

6 (40 CFR 81.82), approximately 314 km (195 mi) southwest of the proposed IIFP facility. The 

7 Anthony area in Doña Ana County, New Mexico and the city of El Paso in El Paso County, 

8 Texas are designated as moderate non-attainment areas under the PM10 NAAQS 

9 (40 CFR 81.332 and 40 CFR 81.344). 
 3-19 

1 3.5.4.1.2 Hazardous Air Pollutants 

2 Provisions of the Clean Air Act as amended required EPA to establish technology-based 

3 standards for Hazardous Air Pollutants (HAP). Under Federal law, HAPs are those air 

4 pollutants listed in Section 112 of the Clean Air Act for which no NAAQS have been established. 

5 Table 3-6. Federal and New Mexico Ambient Air Quality Standards 

Pollutant Averaging Period NAAQS NMAAQS 

CO 8-hour 9 ppm 

(10 mg/m3

) 

8.7 ppm 

1-hour 35 ppm 

(40 mg/m3) 

13.1 ppm 

NO2 Annual 0.053 ppm 0.05 ppm 

24-hour None5 0.10 ppm 

1-hour 0.100 ppm None5

Ozone 8-hour 0.075 ppm None 

1-hour1 0.12 ppm None 

SO2 Annual Revoked6 0.02 ppm 

24-hour Revoked6 0.10 ppm 

3-hour 0.50 ppm None 

1-hour 0.075 ppm None 

PM2.5 Annual 15.0 μg/m3 None 

24-hour 35 μg/m3 None 

PM10 Annual Revoked7 None 

24-hour 150 μg/m3 None 

Lead Rolling 3-month 0.15 μg/m3 None 

Total Suspended 

Particulates 

Annual Geometric Mean Not an NAAQS Pollutant 60 μg/m3

30-day 90 μg/m3

7-day 110 μg/m3

24-hour 150 μg/m3

Hydrogen Sulfide (H2S) 1-hour2 Not an NAAQS Pollutant 0.010 ppm 

1⁄2-hour3 0.100 ppm 

1⁄2-hour4 0.030 ppm 

Total Reduced Sulfur 1⁄2-hour2 Not an NAAQS Pollutant 0.003 ppm 

1⁄2-hour3 0.010 ppm 

1⁄2-hour4 0.003 ppm 

Source: : 40 CFR 50; NMAC 20.2.3 

1

 The 1-hour ozone NAAQS will not apply to an area one year after the effective date of the designation of that area 

for the 8-hour ozone NAAQS. The effective designation date for most areas is June 15, 2004 (40 CFR 50.9). 2

 For the state, except for the Pecos-Permian Basin Intrastate AQCR. 3

 For the Pecos-Permian Basin Intrastate AQCR. 4 For within 5 miles of the corporate limits of municipalities within the Pecos-Permian Basin Intrastate AQCR. 5

 Regulatory agencies have not established standards. 

6

 The 24-hour and annual SO2 NAAQS was revoked by EPA on June 22, 2010. 7

 The annual PM10 NAAQS was revoked by EPA on September 21, 2006. 

μg/m3

 = micrograms per cubic meter 

mg/m3 = milligrams per cubic meter 

ppm = parts per million 

6 
 3-20 

1 There are currently 188 hazardous air pollutants listed, including, but not limited to, the 

2 pollutants controlled by the National Emissions Standards for Hazardous Air Pollutants 

3 (NESHAP) program (40 CFR 61 and 63). 

4 3.5.4.1.3 Prevention of Significant Deterioration 

5 Under the Clean Air Act, the EPA established Prevention of Significant Deterioration (PSD) 

6 regulations, which apply to proposed new or modified sources in an attainment area that have 

7 the potential to emit NO2, PM2.5, PM10, or SO2 in excess of predetermined levels 

8 (40 CFR 52.21). Allowable deterioration to air quality can be expressed as the incremental 

9 increase in ambient concentrations of criteria pollutants, or PSD increment. Increments for 

10 criteria pollutants are based on the PSD classification of the area. Class I areas, which include 

11 certain national parks and wilderness areas, allow the lowest amount of permissible 

12 deterioration by precluding development near designated areas. All other areas of the United 

13 States are Class II areas where moderate, well-controlled industrial growth is allowed. The 

14 allowable PSD increments for Class I and Class II areas are identified in Table 3-7. 

15 The proposed IIFP facility is in a PSD Class II area. There are no PSD Class I areas within 

16 100 km (62 mi) of the proposed IIFP facility (40 CFR 81, Subpart D). The nearest PSD Class I 

17 areas to the proposed IIFP facility are Carlsbad Caverns National Park and the Guadalupe 

18 Mountains National Park, located about 114 km and 154 km (71 mi and 96 mi), respectively, 

19 southwest of the proposed site. Therefore, due to the distances involved to the closest PSD 

20 Class I areas; there is no reason to expect deterioration of air quality from the volumes of IIFP 

21 facility-generated NO2, particulate matter, and SO2. 

22 Table 3-7. Allowable Prevention of Significant Deterioration Increments 

Pollutant Averaging Period 

Class I PSD Increment 

(μg/m3) 

Class II PSD Increment 

(μg/m3) 

NO2 Annual 2.5 25 

PM2.5 Annual 1 4 

24-hour 2 9 

PM10 Annual 4 17 

24-hour 8 30 

SO2 Annual 2 20 

24-hour 5 91 

3-hour 25 512 

Source: 40 CFR 52.21 

23 

24 3.5.4.1.4 Regional Haze 

25 Regional haze is a visibility impairment caused by cumulative air pollutant emissions from 

26 numerous sources over a wide geographic area. The primary cause of regional haze in many 

27 parts of the country is light scattering from fine particles (PM2.5) in the atmosphere. Course 

28 particles (PM10) can also contribute to light extinction. Section 169 of the Clean Air Act

29 established a national goal for visibility, defined as the “prevention of any future, and remedying 

30 of any existing, impairment of visibility in Class I areas...from manmade air pollution.” Under 

31 the regional haze rule, States are required to develop State Implementation Plans to address 

32 visibility at designated mandatory PSD Class I areas, including designated national parks, 
 3-21 

1 wilderness areas, and wildlife refuges (40 CFR 51.309). A visibility analysis is required for each 

2 PSD Class I area located within 100 km (62 mi) of any new or modified major stationary sources 

3 whose emissions exceed PSD modeling thresholds. As discussed above, there are no PSD 

4 Class I areas within 100 km (62 mi) of the proposed IIFP so no visibility analysis is required. 

5 3.5.4.1.5 General Conformity for Federal Actions 

6 According to Section 176 of the Clean Air Act (40 CFR 51.853), a Federal agency must make a 

7 conformity determination in the approval of a project with air emissions that exceed specified 

8 thresholds in nonattainment and/or maintenance areas. This General Conformity Rule ensures 

9 that the actions taken by Federal agencies in non-attainment and maintenance areas meet 

10 national standards for air quality and do not cause further degradation to air quality which would 

11 be inconsistent with the attainment and maintenance of ambient air quality standards. The 

12 proposed project is not in a non-attainment or maintenance area; therefore, no general 

13 conformity analysis is required. 

14 3.5.4.2 Existing Conditions 

15 Air quality in Lea County, New Mexico is considered unimpaired. Farming, ranching, oil and gas 

16 development, a few industrial facilities, and vehicular traffic are the primary activities that would 

17 affect ambient air quality. 

18 The closest air quality monitoring station to the proposed IIFP site is in Hobbs, New Mexico. 

19 The Hobbs station monitors NO2, ozone, PM2.5, and PM10. The nearest air quality monitoring 

20 stations for CO, SO2, and lead are in Rio Rancho, New Mexico, Artesia, New Mexico, and El 

21 Paso, Texas, respectively. The monitored criteria pollutant concentrations for the years 2006 

22 through 2008 are summarized in Table 3-8. 

23 Table 3-8. Ambient Levels of Criteria Pollutants in Nearby Counties 

Pollutant 

Averaging 

Time NAAQS 2006 2007 2008 

Monitor 

Location 

CO (ppm) 8-hour 9 1.4 0.6 NA Rio Rancho, 

NM1

1-hour 35 1.6 1.1 NA 

NO2 (ppm) Annual 0.053 0.008 0.006 0.006 Hobbs, NM 

1-hour 0.100 0.054 0.053 0.052 

Ozone (ppm) 8-hour 0.075 0.075 0.064 0.067 Hobbs, NM 

SO2 (ppm) Annual 0.03 0.001 0.001 0.001 Artesia, NM 

24-hour 0.14 0.004 0.001 0.001 

3-hour 0.50 0.017 0.005 0.001 

1-hour 0.075 0.066 0.011 0.002 

PM2.5 (μg/m3) Annual 15.0 6.82 7.26 6.85 Hobbs, NM 

24-hour 35 12.5 14.8 14.6 

PM10 (μg/m3) 24-hour 150 60 55 39 Hobbs, NM 

Lead (μg/m3) Quarterly 0.15 0.04 0.05 0.02 El Paso, TX 

Source: EPA, 2009a 

1

 The CO monitor in Rio Rancho did not operate in 2008. 
 3-22 

1 3.6 Geology, Minerals, and Soil 

2 3.6.1 Regional and Site Near-surface Geology 

3 The proposed IIFP site is in the Llana Estacado section of the Southern High Plains 

4 physiographic region. The Llana Estacado is an isolated mesa that slopes gently to the east5 southeast and covers a large part of eastern New Mexico and western Texas. The Mescalero 

6 Ridge escarpment, which defines the southwestern limit of the Llano Estacado (Figure 3-4) 

7 crosses the western and central portions of Lea County as a nearly perpendicular cliff 

8 (Nicholson and Clebsch, 1961). 

9 The site is underlain by (in descending order) Quaternary-age alluvium, Triassic- and 

10 Cretaceous-age rocks, and Permian-age rocks that fill the Permian Basin. The Permian Basin 

11 underlies an area approximately 402 km (250 mi) wide and 483 km (300 mi) long and is a major 

12 oil and natural gas producing area (UTPB, 2010). Beginning in 1921, more than 40,000 

13 exploration wells and 200,000 development wells have been drilled in the Permian Basin region 

14 (Scholle, 2000). The Basin produces 17 percent of the nation’s crude oil (UTPB, 2010). The 

15 Basin is also a major source of potassium salts (potash) (UTPB, 2010). Oil, gas, and potash 

16 production in Lea County are summarized in Section 3.6.3. 

17 According to the EPA, there were 95 point sources of criteria pollutants in Lea County, New 

18 Mexico for emissions year 2002 (EPA, 2009b). Emission data for 2002 are the most recent data 

19 available from EPA. Motor vehicles and various area sources also contributed to the criteria 

20 pollutant emissions in Lea County. Table 3-9 presents a summary of the 2002 annual Criteria 

21 Air Pollutants emissions for Lea County. 

22 The Ogallala Formation consists of valley-fill deposits of clay, silt, fine- to coarse-grained sand, 

23 gravel and caliche (hardened calcium carbonate), the distributions of which vary both vertically 

24 and horizontally. The formation ranges in thickness from 0 to as much as 107 m (350 ft) 

25 (Fahlquist, 2003; Tillery, 2008). Locally, the top of the Ogallala Formation consists of a resistant 

26 layer of caliche as thick as 18 m (60 ft) (Nicholson and Clebsch, 1961). 

27 Table 3-9. Lea County Criteria Pollutant Emissions in 2002 

Pollutant 

Point 

metric tons 

per year 

(tons per year) 

Mobile 

metric tons 

per year 

(tons per year) 

Area 

metric tons 

per year 

(tons per year) 

Total 

metric tons 

per year 

(tons per year) 

CO 7,250 (7,992) 13,376 (14,744) 618 (681) 21,244 (23,417) 

NO2 25,605 (28,225) 1,386 (1,528) 128 (141) 27,119 (29,894) 

SO2 7,197 (7,933) 67.8 (74.7) 68.5 (75.5) 7,334 (8,084) 

PM2.5 214 (236) 47.9 (52.8) 2,630 (2,899) 2,892 (3,188) 

PM10 244 (269) 57.2 (63.1) 24,747 (27,279) 25,048 (27,611) 

VOC 1,996 (2,200) 1,067 (1,176) 1,373 (1,513) 4,436 (4,890) 

Source: EPA, 2009b 

28 Quaternary-age alluvial deposits underlying the site consist of sand ranging up to 1 m (3 ft) thick 

29 (Hunt, 1977) that mantles the underlying late Tertiary-age Ogallala Formation (NMBGMR, 

30 2003). 
 3-23 

1 3.6.2 Seismicity and Volcanism 

2 The proposed IIFP site is in a seismically quiet region, with local earthquakes of relatively small 

3 magnitude (moment magnitude of less than 2 on the Modified Mercalli-Revised 1931 scale 

4 [MM]). No Quaternary faults or folds, thought to be associated with most earthquakes of 

5 moment magnitude 6 or greater over the last 1.6 million years, exist in the southeast New 

6 Mexico/west Texas region (Crone and Wheeler, 2000; Machette et al., 1988; Yarger, 2009). 

7 The nearest faulting is more than 161 km (100 mi) west of the site and is associated with the 

8 Rio Grande Rift. 

9 Seismic activity in southeastern New Mexico is typically of small magnitude and generally 

10 caused by oil field injection activities. However, the largest recent major earthquake (5.0 MM) in 

11 New Mexico occurred south of Eunice in January, 1992 (Sanford et al., 2002; Sanford et al., 

12 2006; Yarger, 2009). A seismic event of 5.0 MM would be felt outside only and observed inside 

13 by swinging doors or swaying wall pictures. 

14 The New Mexico Institute of Mining and Technology using instrumental data has estimated 

15 probabilistic seismic hazards for New Mexico of duration magnitude 2.0 MM or greater for the 

16 time period 1962 through 1998 (Sanford et al., 2002; Sanford et al., 2006). Figure 3-5 shows 

17 the probabilistic seismic hazard map in the format of peak horizontal ground acceleration (PGA) 

18 at 10 percent probability of exceeding 6 MM in a 50-year period (or, approximately once every 

19 500 years). PGA is a measure of earthquake force at ground surface and is an index of hazard 

20 for structures. The units for PGA are in percent gravity (g). As shown in Figure 3-5, the highest 

21 predicted PGA, approximately 0.18 g, is approximately 40 km (25 mi) north of Socorro. The 

22 IIFP site area has a predicted PGA of approximately 0.02 g. A PGA of 0.02 g is considered the 

23 acceleration level at which considerable damage can begin to occur to poorly designed or 

24 weakly-built structures of masonry, adobe, or stone (Sanford et al., 2002; Sanford et al., 2006). 

25 New Mexico has experienced almost 700 volcanic events over the past 5 million years, ranging 

26 from small basalt flows to large eruptions. The volcanic events are roughly aligned with two 

27 zones of structural weakness that cross New Mexico: the Colorado Plateau Transition Zone 

28 and the Rio Grande Rift. The most recent volcanic activities were the eruptions of two relatively 

29 large basalt flows associated with the tectonic activity along Rio Grande Rift: the Carrizozo and 

McCarty’s basalts (Limburg, 2009). The Carrizozo basalt covers approximately 329 km2 30 

(127 mi2 31 ) near the town of Carrizozo, approximately 258 km (160 mi) west of the site. Studies 

32 indicate that the age of the basalt flow is between 4,800 and 5,200 years. The McCarty basalt 

flow covers approximately 344 km2

 (133 mi2 33 ) near the town of Grants, approximately 547 km 

34 (340 mi) northwest of the site. Isotope studies indicate that the Grants flow is approximately 

35 3,000 years old (Zimbelman and Johnston, 2001). 

36 3.6.3 Minerals 

37 Mineral resources in Lea County include industrial minerals such as fluorite and gypsum; 

38 construction materials such as potash, caliche, sand, and gravel; and energy sources such as 

39 coal, oil, and gas (Figure 3-6). 

40 Although there are no designated mining districts in Lea County (McLemore et al., 2007), 

41 industrial and construction materials including potash, salt, sulfur, sand, gravel and caliche are 

42 mined at the eight active commercial mines/pits/mills in Lea County listed on Table 3-10. 
 3-24 

1 Figure 3-4. Physiography of New Mexico

2 
 3-25 

1 Figure 3-5. PGA 10% for New Mexico

2 
 3-26 

1 Figure 3-6. Mineral Resource Map

2 

3 
 3-27 

1 Table 3-10. Summary of Active Mines, Mills, Pits and Quarries in Lea County 

Name Commodity Operation 

Lea County Pit Base course, crushed rock, caliche, top soil, sand Pit/Mill 

Hawthorne Pit Caliche Pit 

Constructors Aggregate, caliche, other Pit 

Eunice Pit Sand and gravel Pit 

Old Baldy Pit Aggregate Pit 

Intrepid Potash Potash Mill 

Rowland Salt Salt Mine 

Eunice Plant Sulfur Sulfur Pit 

Sources: USGS, 2005a; Pfeil, et al., 2001; NMEMNRD, 2010a 

2 

3 Caliche caps the Llano Estacado to a maximum thickness of 18 m (60 ft). It is mined throughout 

4 southeastern New Mexico, including Lea County, for construction and cement uses. Lea 

5 County is riddled with hundreds of small, abandoned caliche pits that were used by the New 

6 Mexico Department of Transportation for road construction material. There is a small caliche pit 

7 in the southeastern corner of Section 27. Caliche is currently mined at the Hawthorne Pit north 

8 of Lovington in Lea County. 

9 Coal is not mined in Lea County (McLemore et al., 2007). 

10 The New Mexico portion of the Permian Basin contains 1,112 designated, discovered oil 

11 reservoirs and 672 designated, discovered gas reservoirs. Large active oil and gas fields have 

12 existed in Lea County for more than 50 years (Leedshill-Herkenhoff et al., 2000). 

13 According to the New Mexico Oil & Gas Wells database (NMEMNRD, 2010b), 715 oil or gas 

14 wells are within a 10-km (6-mi) radius of the proposed IIFP site. Seven of these wells are within 

15 a 1.6-km (1-mi) radius. The seven wells were drilled between 1987 and 1999, but subsequently 

16 abandoned. One abandoned well is in the extreme southwestern corner of Section 27, but no 

17 oil or gas wells are located within the proposed facility boundary. The locations of the seven 

18 wells are shown in Figure 3-7, and well details are summarized in Table 3-11. The proposed 

19 IIFP site has been explored for oil and gas and caliche. The site has very limited leasable, 

20 locatable, or marketable mineral resources (NMEMNRD, 2010a; NMEMNRD,2010b; NMT, 

21 2010; Pfeil, et al., 2001; USGS, 2005a). 

22 3.6.4 Soil 

23 Soils occupying the southern High Plains in Lea County generally comprise shallow to deep 

24 gravelly and loamy soils, or deep sandy soils formed from windblown and water-deposited 

25 materials in the Quaternary and late Tertiary periods. Soft or hard caliche is generally found 

26 below the soils in most of the southern High Plains. 

27 Soils underlying the proposed IIFP site include those of Kimbrough, Lea, Portales, Stegall 

28 and Slaughter soil associations. The distribution of these soil associations are shown in 

29 Figure 3-8, and the soil characteristics are summarized in Table 3-12. 

30 In October 2010, a study was conducted by GL Environmental, Inc. for IIFP (GL Environmental, 

31 2010a). They collected two soil samples from the site, which were analyzed to characterize 
 3-28 

1 Figure 3-7. Oil and Gas Well Map

2 

3 
 3-29 

1 Table 3-11. Oil and Gas Wells within 1.6 km (1 mi) of the Site 

Grid Name 

American 

Petroleum Institute 

(API) Number 

Spud 

Date1

Depth Meters 

(ft) Comments 

Yates Petroleum Corp 3002529864 1987 3,360 (11,025) Plugged and 

abandoned 

Chevron USA Inc 3002528999 1999 3,475 (11,400) Abandoned 

Basin Alliance LLC 3002528083 1982 3,708 (12,164) Abandoned 

Westbrook Oil Corp 3002526605 1999 1,728 (5,670) Abandoned 

Shell Oil Company 3002512733 1999 1,612 (5,289) Abandoned 

Getty Oil Company 3002503974 1999 1,433 (4,700) Abandoned 

Texas Pacific & Pure 3002503977 1999 3,733 (12,245) Abandoned 

Source: NMT, 2010 

1

 Spud date is the date when the drill bit first hits the ground. 

API = American Petroleum Institute 

2 

3 Table 3-12. Site Soil Characteristics 

Soil Association 

Soil 

Map 

Symbol 

Section 27 

Hectares 

(Acreage) Description 

Kimbrough gravelly 

loam 

KO 17.7 (43.7) Gravelly loam from zero to 15.2 cm (6 in). Cemented 

material from 15.2 to 40.6 cm (6 to 16 in). Welldrained with a very low capacity to transmit water. 

Kimbrough-Lea 

Complex 

KU 227.3 

(561.7) 

Loam from zero to 66 cm (26 in). Cemented material 

from 25.4 to 66 cm (10 to 26 in). Well-drained with a 

very low capacity to transmit water. 

Portales loam PC 18 (44.5) Farmland of Statewide Importance. Loam from zero 

to 20.3 cm (8 in). Clay loam from 20.3 to 152.4 cm (8 

to 60 in). Well-drained with a high capacity to transmit 

water. 

Portales-Stegall 

loam 

PS 0.4 (0.9) Farmland of Statewide Importance. Loam from zero 

to 22.9 cm (9 in). Clay loam from 22.9 to 71.1 cm (9 

to 28 in). Cemented material from 71.1 to 96.5 cm 

(28 to 38 in). Variable from 96.5 to 152.4 cm (38 to 

60 in). Well-drained with a very low to moderate 

capacity to transmit water. 

Stegall and 

Slaughter soils 

SS 2.0 (5.0) Farmland of Statewide Importance. Loam from zero 

to 5.1 cm (2 in). Clay from 5.1 to 38.1 cm (2 to 15 in). 

Cemented material from 38.1 to 63.5 cm (15 to 25 in). 

Variable from 63.5 to 152.4 cm (25 to 60 in). Welldrained with a very low to moderately high capacity to 

transmit water. 

4 Source: NRCS, 2010 
 3-30 

1 Figure 3-8. Section 27 Soils Map

2 

3 
 3-31 

1 baseline soil conditions. The soil samples were collected from a depth of 6 in and analyzed for 

2 radiological parameters, RCRA metals, volatile organic compounds (VOCs) and semi-volatile 

3 organic compounds (SVOCs). 

U-234 was reported in the two soil samples at concentrations from 4.42 × 10-7 to 5.95 × 10-7 4 

microcuries per gram (μCi/g). U-235/-236 was reported in concentrations from 5.58 × 10-9 5 to 

2.60 × 10-8 μCi/g. U-238 results were from 5.86 × 10-7 to 5.95 × 10-7 6 μCi/g. All isotope 

7 concentrations are consistent with background levels in the site area. 

8 Detected RCRA metals included barium with concentrations from 88.5 to 109 milligrams per 

9 kilograms (mg/kg), cadmium from 0.27 to 0.42 mg/kg, chromium from 10.0 to 12.2 mg/kg, and 

10 lead from 11.7 to 14.7 mg/kg. All other RCRA metals were at less than laboratory method 

11 detection limits. These elements are not uncommon in soils, but levels may have been elevated 

12 due to past petrochemical-related operations in the area. No VOCs or SVOCs were detected 

13 (GL Environmental, 2010a). 

14 New Mexico has farmland protection programs to help slow the conversion of farmland to 

15 developed uses. Farmland is usually divided into three distinct categories: prime farmland, 

16 unique farmland, and farmland of statewide or local importance. Prime farmland is land of 

17 exceptional physical and chemical soil characteristics that can be used in agriculture with 

18 minimum input of nutrients, labor, etc. Prime farmland cannot be committed to urban 

19 development or water storage. Unique farmland is of lower quality than prime farmland but is 

20 still able to produce high-value food or grain products. Farmland of statewide or local 

21 importance does not meet the criteria for prime or unique farmland, but the soil is still 

22 considered important for the production of food and fiber. 

23 The proposed IIFP site has approximately 20.4 ha (50.5 ac) of soils classified as farmland of 

24 statewide importance. The soils on the proposed site do not include tracts of land that have 

25 been designated for agriculture by state law (Carter, 2010). 

26 3.7 Water Resources 

27 These sections consider the groundwater and surface water use, and groundwater and surface 

28 water quality that could affect water use or quality at the site, or be affected by the construction 

29 or operation of the proposed IIFP facility. 

30 3.7.1 Groundwater 

31 Regional and site-specific data on the physical and hydrologic characteristics of the 

32 groundwater resources at, and in the vicinity of, the site are summarized in this section to 

33 provide basic data for an evaluation of impacts on the aquifers of the area. 

34 3.7.1.1 Regional Groundwater 

35 The High Plains aquifer, also known as the Ogallala aquifer, is a regional aquifer system that 

underlies 450,660 km2

 (174,000 mi2 36 ) in parts of eight States: Colorado, Kansas, Nebraska, New 

37 Mexico, Oklahoma, South Dakota, Texas, and Wyoming (USGS, 2010a; McGuire et al., 2003). 

38 Because of its large size, the High Plains aquifer has been geographically subdivided into three 

39 aquifer regions: the southern High Plains, central High Plains, and the northern High Plains. 

40 About 27 percent of the irrigated land in the United States overlies this aquifer system, which 

41 yields about 30 percent of the nation’s groundwater for irrigation. In addition, the aquifer system 
 3-32 

1 provides drinking water to 82 percent of the population within the aquifer boundary (USGS, 

2 2010a). 

3 The proposed IIFP site and surrounding region are underlain by the southern High Plains 

4 aquifer (Hart and McAda, 1985). The southern High Plains aquifer is an unconfined aquifer and 

5 is composed primarily of Quaternary-age alluvial sediments and the Tertiary-age Ogallala 

6 Formation. The Ogallala Formation, which underlies about 80 percent of the High Plains, is the 

7 principal geologic unit forming the aquifer (USGS, 2010a). The Ogallala aquifer is typically 

8 underlain by impermeable clays and shale, although in some places the underlying Cretaceous9 age formations are hydraulically connected to the aquifer. Beneath the Ogallala aquifer in the 

10 Lea County underground water basin (UWB) are the Triassic-age Lower Dockum Group Santa 

11 Rosa aquifer and the deeper Permian-age rocks, which include the Rustler Formation, Capitan 

12 aquifer, and San Andres aquifer (Figure 3-9) (NMOSE, 2009; McCoy and Perry, 2004). 

13 3.7.1.2 Local Groundwater 

14 Groundwater resources in Lea County include hydrogeologic strata within five UWBs 

15 (Figure 3 10). The UWBs are areas of underground water with reasonably ascertainable 

16 boundaries declared by the New Mexico Office of the State Engineer (NM OSE). The four 

17 primary basins, from north to south, are the Lea County UWB, the Capitan UWB, the Carlsbad 

UWB, and the Jal UWB. A small area (approximately 142 km2

 [55 mi2 18 ]) of a fifth UWB, the 

19 Roswell UWB, lies beneath west-central and northeast Lea County. The UWBs are designated 

20 based on their distinct hydrogeologic configurations, which do not typically end at county or 

21 State boundaries. The four primary UWBs include the following primary aquifers: Lea County 

22 UWB (Ogallala aquifer), Capitan UWB (Capitan aquifer), Carlsbad UWB (Santa Rosa aquifer), 

23 and the Jal UWB (Alluvial aquifer) (Leedshill-Herkenhoff et al., 2000). 

24 The Lea County UWB is discussed in detail below because it underlies the proposed IIFP site. 

25 Following that discussion, site and vicinity groundwater are more specifically characterized. 

26 3.7.1.2.1 Lea County Underground Water Basin 

The proposed IIFP site is above the Lea County UWB, which encompasses 5,646 km2 27 

(2,180 mi2 28 ) and covers most of northern Lea County and small portions of Chaves and Eddy 

29 Counties in southeast New Mexico (Stephens & Assoc., 2009). The basin boundaries are 

30 shown in Figures 3-9, 3-10, and 3-11. 

31 The Ogallala aquifer is the primary water source in the Lea County UWB, which extends the 

32 width of Lea County to the east and west. To the south, the Lea County UWB is bounded by 

33 the Mescalero Ridge and associated escarpment (Figures 3-11 and 3-4), which indicates the 

34 southern extent of the High Plains aquifer. The maximum saturated thickness of the Ogallala 

35 aquifer within the UWB is about 76 m (250 ft) (Leedshill-Herkenhoff et al., 2000). The depth to 

36 groundwater in the Ogallala Formation is approximately 9.1 m (30 ft) in the site area 

37 (Figure 3-12). 

38 Generally, the Ogallala Formation has an upward fining of sediments, which may have a 

39 significant effect on the distribution of porosity and permeability in the aquifer, controlling both 

40 the amount of water that can be stored and its movement through the aquifer (Stephens & 

41 Assoc., 2009). 
 3-33 

1 Figure 3-9. Underground Water Basins of NM

2 
 3-34 

1 Figure 3-10. Geologic Cross-section Showing the Deep Aquifers of Lea County

2 
 3-35 

1 Figure 3-11. Groundwater Flow Map

2 
 3-36 

1 Figure 3-12. Depth to Groundwater Map

2 

3 
 3-37 

1 The hydraulic conductivity of the Ogallala aquifer in the Lea County UWB, as reported by a 

2 number of different studies (McGuire et al., 2003; Musharrafieh and Chudnoff, 1999; Stephens 

3 & Assoc., 2009), ranges from 0.9 to 80 m per day (3 to 262 ft per day), with higher hydraulic 

4 conductivities near Hobbs (i.e., near the proposed IIFP site) and eastward toward the Texas 

5 border. Irrigation well yields in the aquifer range from 757 to nearly 7,571 liters per minute 

6 (L/min) (200 to nearly 2,000 gallons per minute [gpm]) (Leedshill-Herkenhoff et al., 2000). 

7 Discharge from the Ogallala aquifer in Lea County occurs through groundwater pumping and 

8 subsurface flow. The largest amount of natural groundwater discharge is the subsurface flow 

9 into Texas (Figure 3-11). A small amount of groundwater discharges through the Quaternary 

10 alluvium to southern Lea County (McAda, 1984). 

11 The principal source of recharge to the aquifer occurs from precipitation infiltrating into the 

12 subsurface, primarily in areas covered by dune sand or playa lakes. Annual average recharge 

13 is estimated to range from 1.3 to 2.5 cm (0.5 to 1 in) (Tillery, 2008). It is estimated that 

14 approximately 3,840,000 ha-m (31,100,000 ac-ft) of groundwater is presently in storage in the 

15 UWB, of which only 45 percent (approximately 1,730,000 ha-m [14,000,000 acre-ft]) can 

16 actually be recovered because the saturated thickness of much of the aquifer is too shallow for 

17 water recovery to be feasible (Musharrafieh and Chudnoff, 1999; Leedshill-Herkenhoff et al., 

18 2000). 

19 Under pre-pumping conditions, recharge of the Ogallala aquifer was in equilibrium with natural 

20 discharge. Because current pumping for municipal, industrial, irrigation and other uses exceed 

21 the Ogallala’s recharge rate, the aquifer has experienced significant drawdown. The water level 

22 in the Ogallala aquifer has declined as much as 30 m (97 ft) in the Lea County UWB from 1914 

23 to 2007. The area of maximum saturated thickness is generally near or coincident with the area 

24 of maximum water-level decline, which is north of Hobbs and near the Texas state line (Tillery, 

25 2008). Groundwater in the Ogallala aquifer flows east-southeast towards Texas (Figure 3-11). 

26 Depths to groundwater in the Lea County UWB range from 6.1 m (20 ft) in the Monument area 

27 to 76 m (250 ft) near the exposed caprock of the Mescalero Ridge (Figure 3-12) (Tilllery, 2008; 

28 Musharrafieh and Chudnoff, 1999). 

29 Modeling by Musharrafieh and Chudnoff (1999) and observed water level declines indicate 

30 portions of the aquifer may become unsaturated by the year 2045. Other portions of the aquifer 

31 are also predicted to have a saturated thickness inadequate to sustain existing water rights 

32 (NMOSE, 2009). 

33 Due to the limited groundwater supply within the southern High Plains aquifer, the NM OSE 

34 issued an order on March 10, 2009 closing the southern High Plains aquifer to the filing of 

35 applications under NMSA Section 72-12-3, which is the statute that regulates wells for new 

36 appropriations other than those applications filed under Section 72-12-1. The order does not 

37 apply to applications filed under NMSA Section 72-12-1.1 (wells required for relatively small 

38 amounts of water for single or multiple households, or for drinking or sanitary uses in 

39 conjunction with a commercial operation); Section 72-12-1.2 (livestock wells); or 

40 Section 72-12-1.3 (wells used for a period not to exceed one year for specifically listed 

41 purposes) (NMOSE, 2009). 

42 Applications filed under NMSA Section 72-12-3 to appropriate groundwater from the units listed 

43 on Table 3-13 are considered on a case-by-case basis (NMOSE, 2009). 
 3-38 

1 Table 3-13. Summary of Potential Deep-Aquifer Groundwater Sources for Lea County 

Aquifer 

Geologic 

Age 

Typical Depth to 

Top of Aquifer 

m (ft) bgs 

Typical Thickness 

m (ft) 

Estimate 

Yields 

L/min (gpm) 

Santa Rosa aquifer Triassic 150 to 335 

(500 to 1,100) 

60 to 76 (200 to 250) 

[730 (2,400) max] 

23 to 379 

(6 to 100) 

Rustler Formation Upper 

Permian 

210 to 410 

(700 to 1,350) 

24 to 43 (80 to140) 

[110 (360) max] 

38 to 379 

(10 to 100) 

Capitan aquifer Permian 850 to 1,400 

(2,800 to 4,600) 

270 to 430 

(900 to1,400) 

[670 (2,200) max] 

189 to 4,921 

(50 to 1,300) 

San Andres aquifer Permian 910 to 1,500 

(3,000 to 5,000) 

210 to 610 

(700 to 2,000) 833 (220) 

Source: McCoy and Perry, 2004 

bgs = below ground surface 

gpm = gallons per minute 

L/min = litters per minute 

2 

3 The NM OSE guidelines for new groundwater withdrawal applications for all UWBs include 

4 block administration and local assessment methods to limit aquifer drawdown. The block 

administration consists of 1.6 km2

 (1 mi2 5 ) blocks that correspond to model cells in the 

6 groundwater-flow model (Musharrafieh and Chudnoff, 1999). A 40-year planning period ending 

7 in 2045 has been selected for block administration (NMOSE, 2009). 

8 Model cells predicted to become unsaturated or with an inadequate saturated thickness for 

9 continued well operation require a higher level of restriction. Areas requiring such restriction are 

10 designated Critical Management Areas (CMAs). The CMAs include those model cells predicted 

11 to have a saturated thickness of 17 m (55 ft) or less by the year 2045 (Figure 3-13). 

12 Key aspects of the NM OSE guidelines for new groundwater applications include the following: 

13 (1) water rights can be moved from one block to another throughout the basin, (2) the 

14 administrative groundwater flow model will be used to determine regional drawdowns resulting 

15 from an application, (3) applications to move water rights cannot create more drawdown than 

16 0.0076 m/yr (0.025 ft/yr) in a CMA, or 0.061 m/yr (0.20 ft/yr) in a non-CMA, and (4) local area 

17 impacts from the proposed water-rights application will be performed and will include evaluation 

18 of impacts to the saturated thickness and reductions in water columns of existing wells (NMOSE 

19 2009). On March 10, 2009, the NM OSE issued an order closing the Lea County UWB to the 

20 filing of groundwater applications (NMOSE, 2009). In 1999, in order to meet the projected 

21 groundwater demands of Lea County, 138 applications were filed by the Lea County Water 

22 Users Association to appropriate 6,389 ha-m (51,797 ac-ft) per year of groundwater, which was 

23 essentially all the unappropriated groundwater in the Lea County UWB (Leadshill-Herkenhoff 

24 et al., 2000). 

25 A portion of the applications to appropriate groundwater, totaling 4,215.2 ha-m (34,173 ac-ft) per 

26 year, have been assigned to Lea County during (at least) the 40-year planning period to allow 

27 the County to hold the subject water rights unused until the rights can be put to beneficial use at 

28 projects currently under construction, select future projects, and homes and businesses in 

29 unincorporated areas. The proposed IIFP site has been included in Lea County’s 40-Year 

30 Water Development Plan as an area of proposed development where up to 21.6 ha-m (175 

31 ac-ft) per year of the Lea County’s water rights would be put to beneficial use. The estimated 
 3-39 

1 Figure 3-13. Critical Management Areas Lee County Basin

2 

3 
 3-40 

1 quantity of groundwater that Lea County would need by the end of the 40-year planning period 

2 for all projects that currently exist, are being constructed, or have a high likelihood of being 

3 constructed in the near future is 1,173.5 ha-m (9,514 ac-ft) per year (Leadshill-Herkenhoff et al., 

4 2000). 

5 3.7.1.2.2 Site and Vicinity Groundwater 

6 A data query of the NM OSE Statewide well database on water supply wells within 1.6 km (1 mi) 

7 of the site is summarized in Table 3-14, and the locations of the wells are shown in Figure 3-14. 

8 The depth to groundwater in the 10 water supply wells within 1.6 km (1 mi) of the site ranges 

9 from 8.5 to 21 m (28 to 70 ft) below ground surface (bgs). One well (L 04011) has insufficient 

10 data and was most likely not completed. The wells are installed in the Ogallala aquifer at 

11 depths ranging from 35 to 62.5 m (115 to 205 ft) bgs. 

12 Xcel Energy’s Cunningham Station, located just west of Section 27 has four groundwater 

13 monitoring wells (M-3, CU-6, -8, and -9) in Section 27 (Figure 3-14). 

14 According to the NM OSE Statewide well database (2010), 261 groundwater wells are within a 

15 10-km (6-mi) radius of the site (Figure 3-15). Most of the wells are categorized as prospecting 

16 wells. There is a domestic well approximately 2.6 km (1.6 mi) northwest of the site. 

17 Table 3-14. Summary of Supply Wells within 1.6 km (1 mi) of the Site 

Owner POD Number 

Well 

Use 

Drill 

Date 

Total Depth

m (ft) 

Depth to 

Water 

m (ft) 

Well Yield

L/min 

(gpm) 

Abbott, Murrell L 03757 PRO 1957 38.1 (125) 13.7(45) NA 

Abbott, Murrell L 03928 PRO 1958 35 (115) 18.3 (60) NA 

NA L 04011 PUB NA NA NA NA 

Abbott Bros L 05176 X IND 1965 60.4 (198) 16.8 (55) 200 (53) 

Abbott Bros L 05176 X-2 

(M-3) IND 1965 50 (164) 16.8 (55) 151 (40) 

Abbott Bros L 05176 X-3 IND 1965 58 (190) 21.3 (70) 159 (42) 

Abbott Bros L 05176 X-4 IND 1965 54 (177) 21.3 (70) 144 (38) 

Abbott Bros L 05176 X-5 IND 1965 62.5 (205) 15.2 (50) 151 (40) 

Abbott Bros L 05176 X-6 IND 1965 61.9 (203) 8.5 (28) 151 (40) 

NA L 07469 DOM 1976 48.8 (160) 21.3 (70) NA 

Keith, Ronny L 12341 POD1 SAN 2009 58 (190) 21.3 (70) NA 

Source: NMOSE, 2010 

DOM = Domestic 

IND = Industrial 

NA = Not available 

POD = Point of diversion 

PRO = Prospecting/development of natural resources 

PUB = Construction of public works 

SAN = Sanitary in conjunction with a commercial use 

18 
 3-41 

1 Figure 3-14. 1-Mile Radius Groundwater Well Map

2 
 3-42 

1 Figure 3-15. 6-Mile Radius Groundwater Well Map 

2 
 3-43 

1 The nearest municipal water system is the City of Hobbs municipal system, approximately 

2 16 km (10 mi) east northeast of the site. The system comprises 29 active groundwater supply 

3 wells, which are grouped into five well fields or systems. The wells range in depth from 54 to 

4 81.7 m (177 to 268 ft) bgs, and the depth to water ranges from 23 to 51 m (75 to 167 ft) bgs. 

5 Yields for the wells range from 927 to 3,407 L/min (245 to 900 gpm). The combined yield from 

6 the five systems is estimated at 59,620 L/min (15,750 gpm) when the pumps are running 

7 24 hours a day (Stephens & Assoc., 2009). 

8 3.7.1.3 Groundwater Use 

9 Groundwater use for Lea County, as reported by the NM OSE, is summarized in Table 3-15. 

10 Irrigation systems are the largest users (72.8 percent) of groundwater in the county, followed by 

11 mining (9.9 percent) and public water supply systems (7.2 percent). Smaller amounts of 

12 groundwater are used by industry, electric power generators, livestock, and domestic/ 

13 commercial users. 

14 Table 3-15. Summary of Groundwater Use in Lea County, 2005 

Groundwater Use Category 

Groundwater Use 

ha-m (ac-ft) 

Commercial (self-supplied) 403 (3,264) 

Domestic (self-supplied) 175 (1,419) 

Industrial (self-supplied) 751 (6,088) 

Irrigated Agriculture 16,698 (135,371) 

Livestock (self-supplied) 453 (3,670) 

Mining (self-supplied) 2,265 (18,365) 

Power (self-supplied) 545 (4,415) 

Public Water Supply 1,648 (13,360) 

Total 22,937 (185,952) 

Source: NMOSE, 2008 

ha-m = hectare meters 

ac-ft – acre feet 

15 

16 3.7.1.4 Groundwater Quality 

17 This section considers the groundwater quality of aquifers that could affect water use at the 

18 proposed site, or be affected by the construction or operation of the proposed IIFP facility. 

19 3.7.1.4.1 Regional Groundwater Quality 

20 In 2001, the U.S. Geological Survey (USGS) National Water-Quality Assessment Program 

21 collected groundwater samples from 48 wells screened in the Southern High Plains aquifer, 

22 primarily from domestic wells in eastern New Mexico and western Texas. Depths of wells 

23 sampled ranged from 30 to 152 m (100 to 500 ft), with a median depth of 61.3 m (201 ft). 

24 Depths to water ranged from 10 to 136 m (34 to 445 ft) bgs, with a median depth of 40.8 m 

25 (134 ft). 

26 Of 240 parameters analyzed in the 48 wells, EPA public drinking-water standards or guidelines 

27 were exceeded in one or more wells for arsenic, boron, chloride, dissolved solids, fluoride, 
 3-44 

1 manganese, nitrate, radon, strontium, or sulfate. Pesticides were detected at very low 

2 concentrations (<1 mg/L) in fewer than 20 percent of the samples (Fahlquist, 2003). 

3 Groundwater quality data from the City of Hobbs municipal drinking water system between 2005 

4 and 2009 are summarized in Table 3-16. Each of the 29 wells comprising the system is 

5 screened in the Ogallala aquifer. The data indicate that groundwater quality in the aquifer near 

6 Hobbs is good and water quality standard exceedances are rare. 

7 3.7.1.4.2 Site Groundwater Quality 

8 The three monitoring wells along the western Section boundary (Figure 3-13) were installed by 

9 Xcel Energy to monitor for the presence of contaminants in groundwater that could originate 

10 from an unlined cooling tower pond at the Cunningham Station, and runoff from agricultural 

11 fields. Groundwater analytical data collected from monitoring wells CU-6, -8, and -9 indicate 

12 that of seven constituents sampled, sulfate, total dissolved solids, and chloride exceeded the 

13 New Mexico Water Quality Bureau Control Commission Standards for Groundwater (NMAC 

14 20.6.2); however, boron, chlorite, pH and nitrates (including nitrate nitrogen) are below or within 

15 the standards. Groundwater quality data were not available for monitoring well M-3 

16 (GL Environmental, 2010b). 

17 3.7.2 Surface Water 

The Southern High Plains Basin in New Mexico encompasses 14,211 km2

 (5,487 mi2 18 ) in Curry, 

19 Roosevelt, Chavez, and Lea Counties (NMWQCC, 2002). The Mescalero Ridge (see 

20 Figure 3-4) separates the Southern High Plains (and the associated Texas Gulf Basin 

21 watershed) from the Pecos River Basin watershed. The proposed IIFP site lies just east of the 

22 Mescalero Ridge, in the Southern High Plains Basin and the Texas Gulf Basin watershed (see 

23 Figure 3-4). 

24 No perennial streams traverse the Southern High Plains although there are some ephemeral 

25 streams that occasionally have large flows after rain storms. Surface water in Lea County is 

26 limited to intermittent streams, lakes, and numerous small playa lakes that result from heavy 

27 rainfall during the summer (Leedshill-Herkenhoff, Inc. et al., 2000). Surface drainage to playa 

28 lakes captures 80 to 90 percent of rainfall (Sublett and Peery, 2009). There is no true drainage 

29 system off the High Plains within Lea County. 

30 Several depressions that hold water after rainfalls dot Section 27. Two dry stream beds bisect 

31 the southern portion of the Section from the northwest to the southeast, outside the boundaries 

32 of the proposed facility (Figure 3-16). The US ACE has determined that these ephemeral 

33 surface waters are not jurisdictional wetlands (USACE, 2011). 

34 The nearest surface waters flow through Monument Draw, which is an ephemeral stream that 

35 can have large flows (Leedshill-Herkenhoff, Inc. et al., 2000). The headwaters of Monument 

36 Draw’s nearest tributary is approximately 4 km (2.5 mi) from the nearest Section boundary and 

37 the main reach is approximately 10 km (6 mi) from the nearest Section boundary. The nearest 

38 permanent lake is approximately 32 km (20 mi) southwest of the proposed IIFP site 

39 (Figure 3-17). The site is in an area classified as an undetermined risk for flooding (Zone D) by 

40 the Federal Emergency Management Agency (FEMA) (Figure 3-18) (eHow, undated). 

41 Properties in Zone D lie outside areas that are known floodplains, but may still flood. 
 3-45 

1 Table 3-16. Summary of City of Hobbs Municipal Water System Groundwater Water 

2 Quality, 2005 – 2009 

Parameter 

MCLa

(μg/Lb

) 

Number of 

Detections 

Detected Concentrations (μg/Lb

) 

Minimum Maximum Average 

1,2-Dichloroethane 5 3 0.47 0.61 0.52 

Antimony, Total 6 4 0.09 0.13 0.11 

Arsenic 10 13 6.5 8.1 7.29 

Barium 2,000 13 43.51 89 69.77 

Benzene 5 2 0.58 0.81 0.70 

Beryllium, Total 4 1 0.25 0.25 0.25 

Bromodichloromethane 100 3 0.08 0.3 0.16 

Bromoform 100 4 0.092 12 6.43 

Chloroform 100 4 0.057 0.24 0.13 

Chromium 100 13 2.9 18.8 7.09 

Combined Uranium 30 6 0.00321 0.00927 0.01 

Dibromochloromethane 100 3 0.055 0.37 0.23 

Dichloromethane 5 5 4.35 5.62 4.89 

Ethylbenzene 700 1 0.50 0.50 0.50 

Fluoride (mg/L) 4 13 0.719 1.13 0.91 

Gross Beta Particle Activity (pCi/L) 4 6 2.869 7.305 4.33 

Iron (mg/L) 0.3c 1 0.0134 0.0134 0.0134 

Nickel 100 13 0.3 3.51 1.46 

Nitrate (as N) (mg/L) 10 12 2.69 5.82 4.01 

Nitrate plus Nitrite (as N) (mg/L) 10 30 2.7 6.97 4.24 

pH (standard units) 6.5 to 8.5c 1 7.24 7.24 7.24 

Radium-226 (pCi/L) 5 2 0.175 0.382 0.28 

Radium-228 (pCi/L) 5 1 1.082 1.082 1.082 

Selenium 50 13 0.00589 18 5.24 

Total Haloacetic Acids) 60 11 1 105.3 14.01 

Total Trihalomethanes 80 20 0.602 13.95 6.85 

Thallium, Total 2 2 0.05 0.05 0.05 

Xylenes, Total 10,000 6 0.7 2.05 1.37 

Note: Includes water quality data for five ground storage reservoirs and Well 5, which pumps directly into the 

distribution system. Samples were collected after the raw water had been chlorinated. 

Source: Stephens & Associates, 2009. 

a

 Maximum contaminant level specified in EPA National Primary Drinking Water Regulations (40 CFR 141 (2010)) b

 Unless otherwise noted 

c

 EPA National Secondary Drinking Water Regulations (40 CFR 143 (2010)) 

μg/L = micrograms per liter 

MCL = maximum contaminant level 

mg/L = milligrams per liter 

pCi/L = picocuries per liter 

3 
 3-46 

1 Figure 3-16. Ephemeral Stream Map

2 
 3-47 

1 Figure 3-17. Water Distances Map

2 
 3-48 

1 Figure 3-18. FEMA Map

2 

3 
 3-49 

1 3.8 Ecological Resources 

2 This section describes the ecological communities on the 259-ha (640-ac) proposed IIFP site, 

3 which includes the 16-ha (40-ac) proposed facility, and in the vicinity of the proposed site. It 

4 also discusses important species that occur or have the potential to occur on the site or in the 

5 vicinity, and habitats in the vicinity that are important to those species. 

6 Surveys were conducted for IIFP for vegetation and wildlife, including the dunes sagebrush 

7 lizard (Sceloporus arenicolus) and the lesser prairie chicken (Tympanuchus pallidicintus), two 

8 Federal candidate species (GL Environmental, 2010c; GL Environmental, 2010d; SORA, 2011). 

9 The dunes sagebrush lizard’s range encompasses the IIFP site and a BLM resource 

10 management plan has been proposed to preserve habitat for the lesser prairie-chicken and the 

11 dunes sagebrush lizard, roughly 11 km (7 mi) from the IIFP site, and create a travel corridor for 

12 the lesser prairie-chicken roughly 52 km (32 mi) from the site, as discussed in Section 3.8.6.3. 

13 3.8.1 Ecosystems in the Proposed Facility 

14 As described in Section 3.6.1, the site is on the Llano Estacado of the Southern High Plains 

15 physiographic region. The western portion of the Llano Estacado supports shortgrass prairie 

16 habitat, and the southern portion is transitional to the more arid Chihuahuan Desert. The site 

17 lies in a transitional zone between two distinct ecoregions: Western Great Plains Shortgrass 

18 Prairie and Apacherian-Chihuahuan Mesquite Upland Scrub (Figure 3-19) (USGS, 2010b). 

19 3.8.1.1 Western Great Plains Shortgrass Prairie 

20 Western Great Plains Shortgrass Prairie habitat covers approximately 55 percent of the 

21 proposed site. The short grasses that dominate the system are extremely drought- and grazing22 tolerant. This ecosystem is characterized by blue grama grass (Bouteloua gracilis). Scattered 

23 shrub and dwarf-shrub species such as sand sagebrush (Artemisia filifolia), prairie sagewort 

24 (Artemisia frigida), little sagebrush (Artemisia tridentate), fourwing saltbush (Atriplex 

25 canescens), crispleaf buckwheat (Eriogonum effusum), broom snakeweed (Gutierrezia 

26 sarothrae), and pale desert-thorn (Lycium pallidum) may also be present. Climate, fire, and 

27 grazing maintain this system (NatureServe, 2009; USGS, 2010b). 

28 3.8.1.2 Apacherian-Chihuahuan Mesquite Upland Scrub 

29 Apacherian-Chihuahuan Mesquite Upland Scrub habitat covers approximately 45 percent of the 

30 proposed site. This ecosystem often occurs as invasive upland shrublands such as those that 

31 are concentrated in the foothills and piedmont of the Chihuahuan Desert (NatureServe, 2009). 

32 Vegetation is dominated typically by honey mesquite (Prosopis glandulosa) or velvet mesquite 

33 (Prosopis velutina) and succulents. Grass cover is typically low and composed of desert 

34 grasses such as low woollygrass (Dasyochloa pulchella), bush muhly (Muhlenbergia porteri), 

35 curlyleaf muhly (Muhlenbergia setifolia), and tobosagrass (Pleuraphis mutica) (NatureServe, 

36 2009). During the last century, the area occupied by this ecosystem has increased through 

37 conversion of desert grasslands as a result of drought, overgrazing by livestock, and decreases 

38 in fire frequency (NatureServe, 2009; USGS, 2010b). 
 3-50 

1 Figure 3-19. Vegetation Communities Map 

2 
 3-51 

1 3.8.1.3 Wetland and Riparian Habitat 

2 As described in Section 3.7.2, there are no wetlands or stream systems within the footprint of 

3 the proposed facility. Depressions that hold ephemeral water, which are located throughout 

4 Section 27, are important breeding and nursery sites for amphibians, and can be important 

5 stopovers for migrating waterfowl and shorebirds. Vegetated arroyos, such as the one running 

6 across the southern part of Section 27 (and outside the 16-ha [40-ac] facility footprint), serve as 

7 excellent wildlife corridors, and nesting habitat for birds (New Mexico Department of Game and 

8 Fish [NMGF] correspondence in Appendix B). 

9 3.8.2 Vegetation of the Proposed Facility 

10 Most of the plant species on the proposed facility are typical of Plains-Mesa Grassland and 

11 Desert Grassland communities (Dick-Peddie, 1993). These communities are characterized by 

12 significant amounts of grasses and less than 10 percent of total cover being forbs and shrubs 

13 (Dick-Peddie, 1993). 

14 A vegetation survey was conducted by GL Environmental on behalf of IIFP at the proposed 16-

15 ha (40-ac) facility on October 16, 2010 to determine total vegetative cover and relative cover 

16 (GL Environmental, 2010c). Total vegetative cover represents the percentage of ground that 

17 has living vegetation on it compared to bare ground or litter. Relative cover represents the 

18 fraction of total vegetative cover that is composed of a certain species or category of plants 

19 (e.g., perennial plants). Total vegetative cover is approximately 45 percent with 98 percent of 

20 this cover consisting of perennial grasses, including blue grama, burrograss (Scleropogon 

21 bevifolius), black grama (Bouteloua eripoda), and James Galleta grass (Pleuraphis jamesii). 

22 Shrubs included honey mesquite and hedgehog cactus (Echinocereus sp.). Forbs on the site 

23 included Texas croton (Croton texensis), Texas blueweed, (Helianthus ciliaris), and curly cup 

24 gumweed (Grindelia squarrosa) (GL Environmental, 2010c). 

25 3.8.3 Wildlife that Could Occur on the Site and Proposed Facility 

26 Wildlife that could occur on the IIFP site include species typical of arid grassland and desert 

27 habitats. Table 3-17 lists mammals, birds, amphibians, and reptiles that could be present on the 

28 site, based on habitat requirements, and presents information regarding their preferred habitats. 

29 The table was compiled from the lesser prairie-chicken survey (SORA, 2011) conducted by 

30 SORA on behalf of IIFP for the proposed site in April 2011 and surveys conducted in 2004 for 

31 the Louisiana Enrichment Services (LES) National Enrichment Facility, located approximately 

32 33 km (20 mi) southeast of the proposed IIFP (NRC, 2005). Comparison with the LES site is 

33 appropriate because both facilities are in the transition zone from the shortgrass prairie to the 

34 Chihuahuan desert (USDA, 2004). 

35 A diverse assemblage of animals, including several commercially and recreationally important 

36 game species are typical of this habitat. Pronghorn “antelope” (Antilocapra americana) and 

37 mule deer (Odocoileus hemionus) are plentiful in eastern New Mexico (NMGF, 2009). NMGF 

38 has assigned sections of the State to specific Antelope Management Units in order to better 

39 manage pronghorn antelope populations. The proposed IIFP site is within Antelope 

40 Management Unit 26, one of several management units in southeastern New Mexico. An 

41 estimated 44 pronghorn were harvested from this Management Unit in 2007-2008 (NMGF, 

42 2008a). The site is also a part of New Mexico Game Management Unit 31. Approximately 

43 500 mule deer were harvested from Game Management Unit 31 in 2009 (NMGF, 2010a). 
 3-52 

1 Table 3-17. Mammal, Bird, Amphibian, and Reptile Species Likely to be Present at the 

2 Proposed Site and Vicinity 

Common Name Scientific Name 

Mammals Preferred Habitat 

Black-tailed jackrabbit Lepus californicus Grasslands and open areas 

Black-tailed prairie dog Cynomys ludovicianus Shortgrass prairie 

Cactus mouse Peromyscus eremicus Grasslands, prairies, and mixed 

vegetation 

Collared peccary Dicotyles tajacu Brushy, semi-desert, chaparral, 

mesquite, and oaks 

Coyote Canis latrans Open space, grasslands, and 

brush country 

Deer mouse Peromyscus maniculatus Grasslands, prairies, and mixed 

vegetation 

Desert cottontail Sylvilagus audubonii Arid lowlands, brushy cover, and 

valleys 

Mule deer Odocoileus hemionus hemionus Desert shrubs, chaparral, and 

rocky uplands 

Ord’s kangaroo rat Dipodomys ordii Hard desert soils 

Plain’s pocket gopher Geomys bursarius Deep soils of the plains 

Pronghorn Antilocapra americana Sagebrush flats, plains, and 

deserts 

Raccoon Procyon lotor Brushy, semi-desert, chaparral, 

and mesquite 

Southern Plains woodrat Neotoma micropus Grasslands, prairies, and mixed 

vegetation 

Spotted ground squirrel Spermophilus spilosoma Brushy, semi-desert, chaparral, 

mesquite, and oaks 

Striped skunk Mephitis mephitis All land habitats 

Swift fox Vulpes velox Rangeland with short grasses and 

low shrub density 

White-throated woodrat Neotoma albigula Grasslands, prairies, and mixed 

vegetation 

Yellow-faced pocket gopher Pappogeomys castanops Deep soils of the plains 

Birds Seasonal Preference 

American kestrel Falco sparverius Year round 

Ash-throated flycatcher Myiarchus cinerascens Spring 

Bewick’s wren Thyromanes bewickii Spring and summer 

Black-chinned hummingbird Archilochus alexandri Spring 

Blue grosbeak Guiraca caerulea Summer 

Bullock’s oriole Icterus bullockii Summer 

Cassin’s sparrow Aimophila cassinii Spring and Fall 

Cactus wren Campylorhynchus 

brunneicapillus 

Year round 
 3-53 

1 Table 3-17. Mammal, Bird, and Amphibian, and Reptile Species Likely to be Present at 

2 the Proposed Site and Vicinity (Continued) 

Common Name Scientific Name 

Birds (Continued) Seasonal Preference 

Chihuahuan raven Corvus cryptoleucus Year round 

Common raven Corvus corax Summer and winter 

Crissal thrasher Toxostoma dorsale Migrant 

Eastern meadowlark Sturnella magna Year round 

European starling Sturnus vulgaris Year round 

Gambel’s quail Lophortyx gambelii Rare 

Great-tailed grackle Quiscalus mexicanus Year round 

Green-tailed towhee Pipilo chlorurus Migrant 

Horned lark Eremophila alpestris Spring 

House finch Carpodacus mexicanus Spring and summer 

Killdeer Charadrius vociferus Spring and summer 

Lark bunting Calamospiza melanocorys Winter 

Lark sparrow Chondestes grammacus Spring and summer 

Loggerhead shrike Lanius ludovicianus Summer 

Long-eared owl Asio otus Summer and winter 

Mallard Anas platrhynchos Spring 

Mourning dove Zenaida macroura Spring and summer 

Nighthawk Chordeiles minor Spring 

Northern mockingbird Mimus polyglottos Summer 

Northern bobwhite Colinus virginianus Spring 

Pyrrhuloxia Cardinalis sinuatus Winter 

Red-tailed hawk Buteo jamaicensis Winter 

Red-winged blackbird Agelaius phoeniceus Year round 

Roadrunner Geococcyx californianus Uncommon 

Sage sparrow Amphispiza belli Uncommon 

Say’s phoebe Sayornis saya Spring 

Scaled quail Callipepla squamata Spring and summer 

Scissor-tailed flycatcher Tyrannus forficatus Migrant 

Scott’s oriole Icterus parisorum Summer and winter 

Swainson’s hawk Buteo swainsoni Summer 

Turkey vulture Cathartes aura Summer 

Vermillion flycatcher Pyrocephalus rubinus Winter and migrant 

Vesper sparrow Pooecetes gramineus Spring 

Western burrowing owl Athene cunicularia hypugaea Spring 

Western kingbird Tyrannus verticalis Summer 
 3-54 

1 Table 3-17. Mammal, Bird, and Amphibian, and Reptile Species Likely to be Present at 

2 the Proposed Site and Vicinity (Continued) 

Common Name Scientific Name 

Amphibians/Reptiles Preferred Habitat 

Coachwhip Masticophis flagellum Mixed grass prairie and desert 

grasslands 

Collared lizard Crotaphytus collaris Desert grasslands 

Eastern fence lizard Sceloporus undulates Mixed grass prairie and desert 

grasslands 

Garter snake Thamnophis sp. Desert grasslands 

Ground snake Sonora semiannulata Desert grasslands 

Longnose leopard lizard Gambelia wislizenii Mixed grass prairie and desert 

grasslands 

Lesser earless lizard Holbrookia maculata Mixed grass prairie and desert 

grasslands 

Longnosed snake Rhinocheilus lecontei Desert grasslands 

Ornate box turtle Terrapene ornate ornata Desert grasslands and shortgrass 

prairie 

Pine-gopher snake Pituophis melanoleucus Shortgrass prairie and desert 

grasslands 

Plains blackhead snake Tantilla nigriceps Shortgrass prairie and desert 

grasslands 

Plains spadefoot toad Spea bombifrons Shallow to standing pools of water 

Rattlesnakes Crotalus sp. Shortgrass prairie and desert 

grasslands 

Six-lined racerunner Cnemidophorus sexlineatus Mixed grass prairie and desert 

grasslands 

Tiger salamander Ambystoma tigrinum Tall-grass and mixed prairie 

Texas horned lizard Phrynosoma cornutum Desert grasslands 

Western whiptail lizard Cnemidophorus tigris Mixed grass prairie and desert 

grasslands 

Source: NRC, 2005; USDA, 2004; eBird, 2011; SORA, 2011 

3 

4 Lea County also provides opportunities to hunt small birds, most notably scaled quail (Callipepla 

5 squamata) and Northern bobwhite (Colinus virginianus). Scaled quail occur primarily in semi6 arid rangelands with mixed scrub communities (shrubs, grasses, and bare ground) (NMGF, 

7 2008b). The vegetation on the proposed IIFP site provides habitat for scaled quail. Northern 

8 bobwhites also occur in southeastern New Mexico, including Lea County (NMGF, 2008b). 

9 Northern bobwhite habitat in New Mexico is characterized by large expanses of native warm10 weather grasses mixed with annual weeds and legumes, with dense, brushy areas for escape 

11 cover and roosting (NMGF, 2008b). The near absence of dense thickets on the proposed IIFP 

12 site suggests that it offers only marginal Northern bobwhite habitat. 
 3-55 

1 3.8.4 Wildlife Travel Corridors for Resident and Migratory Species 

2 3.8.4.1 Migratory Species 

3 Southeastern New Mexico, including Lea County, is within the Central Flyway, one of the four 

4 major North American bird migration corridors between nesting and wintering grounds (CFC, 

5 undated; TPWD, 2007). Birds of prey associated with the Central Flyway include the American 

6 kestrel (Falco sparverius), ferruginous hawk (Buteo regalis), Swainson’s hawk (Buteo 

7 swainsoni) and others. Waterfowl that use the Central Flyway to move between breeding areas 

8 in Canada and wintering areas in Texas and Mexico include the mallard (Anas platrhynchos), 

9 American widgeon (Anas americana), green-winged teal (Anas crecca) and others. Songbirds 

10 that migrate along the Central Flyway include the American goldfinch (Spinus tristis), Western 

11 kingbird (Tyrannus verticalis), lark bunting (Calamospiza melanocorys), vesper sparrow 

12 (Pooecetes gramineus) and others. Common shorebirds associated with the Central Flyway 

13 include the killdeer (Charadrius vociferus), greater yellowlegs (Tringa melanoleuca), spotted 

14 sandpiper (Actitis macularia), least sandpiper (Calidris minutilla) and others (Stokes and Stokes, 

15 1996). Depending on the availability of food and water that may be temporarily present in the 

16 depressions that dot Section 27 during seasonal migrations, migratory birds such as these could 

17 occasionally be present on or in the vicinity of the site. 

18 3.8.4.2 Resident Species 

19 Wildlife corridors are typically linear habitats that link larger habitats. They can serve a region 

20 (e.g., a river followed by migratory waterfowl), a landscape (e.g., a transmission corridor right-of21 way that connects two natural areas), or a local site (e.g., a gully or strip of trees that deer use 

22 to move between bedding and feeding areas). There are no terrain features at the proposed 

23 IIFP site that would serve as wildlife corridors. 

24 3.8.5 Critical Habitats 

25 Under the Endangered Species Act “critical habitat” is defined as: (1) specific areas within the 

26 geographical area occupied by the [listed] species at the time of listing, if they contain physical 

27 or biological features essential to conservation, and those features may require special 

28 management considerations or protection; and (2) specific areas outside the geographical area 

29 occupied by the [listed] species if the agency determines that the area itself is essential for 

30 conservation. 

31 The nearest critical habitat is the Pecos River, approximately 146 km (91 mi) northwest of the 

32 site, which supports the Pecos bluntnose shiner (Notropis simus pecosensis). This fish is listed 

33 as Federally threatened (USFWS, 2010a). 

34 3.8.6 Wildlife Sanctuaries, Wildlife Management Areas, Refuges, and Preserves 

35 Wildlife sanctuaries, management areas, refuges, and preserves are areas designated by the 

36 NM GF as open to wildlife-associated recreation activities beyond the traditional uses of hunting 

37 and fishing. 

38 3.8.6.1 Green Meadow Lake 

39 Green Meadow Lake is a New Mexico-designated Wildlife Area approximately 16 km (10 mi) 

40 northeast from the proposed site (NMGF, Undated 1). Migratory waterfowl using the Central 

41 Flyway may rest at the lake during migrations. 
 3-56 

1 3.8.6.2 Prairie Chicken Wildlife Area 

2 The New Mexico-designated Prairie Chicken Wildlife Area comprises parcels throughout 

3 southeastern New Mexico that provide habitat for the preservation and restoration of the lesser 

4 prairie-chicken (NMGF, Undated 2). The closest Prairie Chicken Wildlife Area is more than 

5 80 km (50 mi) from the proposed site. 

6 3.8.6.3 Lesser Prairie-Chicken Habitat Preservation Area of Critical Environmental 

7 Concern and Proposed Lesser Prairie-Chicken Expansion Corridor 

8 In 2008, the BLM issued a Record of Decision (ROD) to implement a resource management 

9 plan (RMP) for all resources on approximately 343,983 surface ha (850,000 surface ac) of 

10 public land in parts of Chaves, Eddy, Lea, and Roosevelt Counties in southeastern New Mexico. 

11 To meet some of the objectives of this RMP, the BLM will establish a 23,472-ha (58,000-ac) 

12 Lesser Prairie-Chicken Habitat Preservation Area of Critical Environmental Concern (ACEC) to 

13 maintain and enhance habitat for the lesser prairie-chicken and the dunes sagebrush lizard. 

14 The entire RMP area lies west and south of the proposed facility location; the nearest part of the 

15 RMP area is approximately 11 km (7 mi) due south of the site (Figure 3-20) (BLM, 2008). 

16 Additionally, the BLM has proposed a Lesser Prairie-Chicken Expansion Corridor in 

17 southeastern New Mexico in order to maintain a north-south travel way for lesser prairie18 chickens. No final decision has been made about the corridor (BLM, 2010) which is 51.5 km 

19 (32 mi) from the proposed site at its nearest boundary (Figure 3-20). 

20 The IIFP proposed site does not provide optimal habitat for the lesser prairie-chicken and is not 

21 included in the ACEC nor in the proposed corridor. 

22 3.8.7 Special-Status Species 

23 The Endangered Species Act defines an endangered species as any species which is in danger 

24 of extinction throughout all or a significant portion of its range, and a threatened species as any 

25 species which is likely to become an endangered species within the foreseeable future 

26 throughout all or a significant portion of its range. 

27 According to the New Mexico Rare Plant Technical Council there are no special-status plant 

28 species in Lea County (NMRPTC, 1999). 

29 The U.S. Fish and Wildlife Service (USFWS) maintains lists of endangered and threatened 

30 species, candidate species, and species of concern for Lea County (USFWS, 2010b; USFWS, 

31 2010c). The Northern aplomado falcon (Falco femoralis septentrionalis), the black-footed ferret 

32 (Mustela nigripes), and the least tern (Sterna antillarum athalassos) are listed as Federally 

33 endangered species occurring in Lea County (USFWS, 2010b; NMGF, 2010b). 

34 Candidate species are those that the USFWS has sufficient information to propose that they be 

35 added to the Federal list of threatened and endangered species, but the listing action has been 

36 precluded by other higher priority listing activities. Two candidate species are listed as 

37 potentially occurring in Lea County: the lesser prairie-chicken and the dunes sagebrush lizard. 

38 On December 14, 2010, the USFWS issued a proposal to list the dunes sagebrush lizard as a 

39 Federally endangered species (USFWS, 2010d). The USFWS also maintains a list of species 

40 of concern, however, these species are not protected by law. There are eight Federal species 
 3-57 

1 Figure 3-20. Proposed Lesser Prairie-Chicken Corridor Map

2 

3 
 3-58 

1 of concern in Lea County: black-tailed prairie dog (Cynomys ludovicianus), swift fox (Vulpes 

2 velox), American peregrine falcon (Falco peregrinus anatum), arctic peregrine falcon (Falco 

3 peregrinus tundrius), Baird’s sparrow (Ammodramus bairdii), Bell’s vireo (Vireo bellii), western 

4 burrowing owl (Athene cunicularia hypugaea), and the yellow-billed cuckoo (Coccyzus 

5 americanus) (USFWS, 2010b). 

6 Based on the best available information, the swift fox and western burrowing owl could occur on 

7 or visit the proposed site. It is unlikely that the dunes sagebrush lizard (GL Environmental, 

8 2010d) or the lesser prairie-chicken (SORA, 2011) would occur at the site. The black-tailed 

9 prairie dog has not been reported as occurring within Lea County; and the American peregrine 

10 falcon, arctic peregrine falcon, and Baird’s sparrow have been reported only rarely or very rarely 

11 in Lea County. No preferred habitat for the Northern aplomado falcon, least tern, black-footed 

12 ferret, Bell’s vireo, or yellow-billed cuckoo occurs on the proposed site. 

13 Endangered, threatened, candidate species, and species of concern listed by the USFWS and 

14 the State of New Mexico for Lea County are described in the following sections and presented 

15 in Table 3-18. 

16 Table 3-18. Rare, Threatened or Endangered Species Listed for Lea County, New 

17 Mexico 

Common Name Scientific Name 

Federal 

Statusa

State 

Statusa

Mammals 

Black-footed ferret Mustela nigripes E2 - 

Black-tailed prairie dog Cynomys ludovicianus S2 - 

Swift fox Vulpes velox S1 - 

Birds 

American peregrine falcon Falco peregrinus anatum S2 T1

Arctic peregrine falcon Falco peregrinus tundrius S2 T1

Baird’s sparrow Ammodramus bairdii S2 T1

Mammals 

Bald eagle Haliaeetus leucocephalus - T1

Bell’s vireo Vireo bellii S2 T1

Broad-billed hummingbird Cynanthus latirostris magicus - T1

Least ternb Sterna antillarum athalassos E1 E1

Lesser prairie-chicken Tympanuchus pallidicinctus C2 - 

Northern aplomado falcon Falco femoralis septentrionalis E2 E1

Western burrowing owl Athene cunicularia hypugaea S2 - 

Yellow-billed cuckoo Coccyzus americanus S2 - 

Amphibians/Reptiles 

Dunes sagebrush lizard Sceloporus arenicolus PE3 E1

Sources: 1 NMGF, 2010b; 2 USFWS, 2010b; 3 18 USFWS, 2010d a 19 C = Candidate, E = Endangered, T = Threatened, S = Species of Concern, PE = Proposed Endangered, , - = Not 

20 listed. b 21 The least tern is not listed by the USFWS as occurring in Lea County, however, it is listed by the New Mexico 

22 Department of Game and Fish as occurring in Lea County. 
 3-59 

1 3.8.7.1 Federally Endangered Species 

2 Northern Aplomado Falcon 

3 The Northern aplomado falcon is listed as both a Federal and State endangered species. The 

4 preferred habitat in New Mexico for this species consists of open yucca desert land from the Rio 

5 Grande westward and north to Deming and Separ. The few nests known to occur in New 

6 Mexico were in areas of yucca grassland (USGS, 2005b; NMGF, 2010c). This habitat does not 

7 occur on the proposed site. 

8 Black-Footed Ferret 

9 The black-footed ferret is a Federally listed endangered species, but is not listed by the State of 

10 New Mexico. The historic range of the black-footed ferret included all of New Mexico; however, 

11 it was extirpated from most of its range, including New Mexico, by the 1960s. Black-footed 

12 ferrets are being reintroduced to their historic range, and the State of New Mexico has pursued 

13 reintroduction efforts (USFWS, 2008). The black-footed ferret is limited to open habitat, the 

14 same habitat used by prairie dogs: grasslands, steppe, and shrub steppe. The black-footed 

15 ferret has co-evolved with the prairie dog; their ranges and habitat closely overlap; however, the 

16 prairie dog has fewer protective regulations than the ferret (USFWS, 2008; USGS, 2005b). The 

17 preferred habitat does not occur on the proposed site. 

18 Least Tern 

19 The least tern is Federally listed as endangered and is also listed as endangered by the State of 

20 New Mexico. Its historic distribution was coincident with the major river systems of the Midwest 

21 as its habitat includes barren shorelines of lakes, rivers, and reservoirs (USGS, 2005b). The 

22 least tern has not been documented in Lea County, but has been reported as a migrant in Eddy 

23 County, just west of the proposed site, and has been documented breeding at Bitter Lake 

24 National Wildlife Refuge in Chaves County, approximately 161 km (100 mi) northwest of the 

25 proposed site (NMGF, 2010c; USGS, 2005b). No rivers, lakes, or reservoirs occur on the site; 

26 therefore, no habitat for this species is present on the proposed site. 

27 3.8.7.2 Federally Proposed Endangered Species 

28 Dunes Sagebrush Lizard 

29 On December 14, 2010, the USFWS issued a proposal to modify the listing of the dunes 

30 sagebrush lizard from its current status as a Federal candidate species to that of endangered; 

31 this species is already listed as endangered by the State of New Mexico (USFWS, 2010c). 

32 The range of the dunes sagebrush lizard within New Mexico appears to be confined to areas of 

33 active sand dunes vegetated by shinnery oak (Quercus havardii) in the extreme southeastern 

34 portion of the state and adjoining areas of Texas; although adjacent open habitats may be used 

35 in some places (NMGF, 2010c). The range stretches from eastern Chaves County, 

36 southernmost Roosevelt, and northernmost Lea Counties, southward and eastward into 

37 northeastern Eddy and south/central Lea counties. The closest part of the range lies 11.9 km 

38 (7.4 mi) south of the boundary of the facility site (Figure 3-20) (BLM, 2008; Center for Biological 

39 Diversity, 2002). Shinnery oak and sand dunes do not occur on the proposed IIFP site and; 

40 therefore, it is unlikely for the dunes sagebrush lizard to occur at the proposed site 

41 (GL Environmental, 2010d). 
 3-60 

1 3.8.7.3 Federal Candidate Species 

2 Lesser Prairie-Chicken 

3 The lesser prairie-chicken is a candidate species for Federal protection due to habitat loss 

4 (USGS, 2005b). See Section 3.8.6.3 for a discussion on the BLM Lesser Prairie-Chicken ACEC 

5 and proposed Lesser Prairie-Chicken Expansion Corridor. 

6 Lesser prairie-chickens are most common in dwarf shrub-mixed grass vegetation, interspersed 

7 with short-grass or mixed-grass habitats. They are also found in shinnery oak and bunch 

8 sumac and squaw bush (USGS, 2005b). Lea County is historically known to have habitat for 

9 lesser prairie-chickens, but the proposed site is at the southern periphery of their range 

10 (BLM, 2010; SORA, 2011). The IIFP site could provide suitable habitat for the lesser prairie11 chicken, though there are limited water sources on the site (SORA, 2011). 

12 3.8.7.4 Federal Species of Concern 

13 American Peregrine Falcon 

14 The American peregrine falcon is Federal species of concern and is listed as threatened by the 

15 State of New Mexico. It breeds in mountain areas and migrates essentially statewide; however, 

16 this species has only been reported rarely in Lea County (NMGF, 2010b). 

17 Arctic Peregrine Falcon 

18 The arctic peregrine falcon is a Federal species of concern and is listed as threatened by the 

19 State of New Mexico. This species is migratory and is found in a variety of habitats including 

20 forests, grasslands, and the Chihuahuan Desert Scrub (NMGF, 2010c). It is a very rare migrant 

21 through the State of New Mexico, but was reported in Lea County in 2007 (NMGF, 2010b). 

22 Baird’s Sparrow 

23 The Baird’s sparrow is a Federal species of concern and is listed as threatened by the State of 

24 New Mexico. Found in a variety of habitats ranging from desert grasslands to prairies and 

25 mountain meadows, the Baird’s sparrow is a transient species in eastern and southern New 

26 Mexico and is considered rare to uncommon in Lea County (NMGF, 2010b). 

27 Bell’s Vireo 

28 Bell’s vireo is a Federal species of concern and is listed as threatened by the State of New 

29 Mexico. It winters south of the Mexican border and is a rare summer resident in Lea County 

30 (NMGF, 2010b). In New Mexico, this species occurs in riparian and wooded lowland habitats 

31 (NMGF, 2010c), none of which occur on the proposed site. 

32 Black-Tailed Prairie Dog 

33 The black-tailed prairie dog is a Federal species of concern, but it is not listed by the State of 

34 New Mexico. The black-tailed prairie dog commonly occurs in shortgrass prairie habitats 

35 (USGS, 2005b; NMGF, 2010c). However, it has not been reported in Lea County (NMGF, 

36 2010b). 
 3-61 

1 Swift Fox 

2 The swift fox is a Federal species of concern, but it is not listed by the State of New Mexico. It 

3 is a year-round resident throughout the State, inhabiting shortgrass, midgrass and mixed 

4 prairies and adapting to overgrazed pastures, plowed fields, and fencerows (NMGF, 2010c). 

5 Western Burrowing Owl 

6 The Western burrowing owl is a Federal species of concern, but it is not listed by the State of 

7 New Mexico. Habitats include well-drained grasslands, prairies, steppes, deserts, and 

8 agricultural lands. The owls normally migrate south in late fall, but may not migrate if there are 

9 abandoned mammal burrows, which the owl uses for nests (NMGF, 2010c). This species has 

10 been reported only in the summer in Lea County; however, it has been documented as a year 

11 round resident in southern New Mexico (USGS, 2005b; NMGF, 2010c). 

12 Yellow-Billed Cuckoo 

13 The yellow-billed cuckoo population in eastern New Mexico is listed as a Federal species of 

14 concern, while the population in western New Mexico is a Federal candidate species; but it is 

15 not listed by the State of New Mexico. Yellow-billed cuckoos are often associated with riparian 

16 forests and deciduous woodlands (USGS, 2005b; NMGF, 2010c). They have been reported to 

17 occur in Lea County during the fall (USGS, 2005b; NMGF, 2010b). 

18 3.8.7.5 New Mexico Threatened Species 

19 Bald Eagle 

20 The bald eagle was removed from the Federal endangered and threatened species list in 2007; 

21 however, it remains listed as threatened by the State of New Mexico and it still receives 

22 protection under the Bald and Golden Eagle Protection Act, Lacey Act, and Migratory Bird 

23 Treaty Act. It is a rare visitor to Lea County (NMGF, 2010b). 

24 Broad-billed Hummingbird 

25 The broad-billed hummingbird is listed as a threatened species by the State of New Mexico. It 

26 is rare in Eddy County (adjacent to Lea County) and is not known to occur in Lea County. It is 

27 usually associated with riparian woodlands (NMGF, 2010c), none of which occur on the 

28 proposed site. 

29 3.9 Socioeconomics and Environmental Justice 

30 This section describes the socioeconomic resources that have the potential to be affected by 

31 the construction and operation, and decommissioning of the IIFP facility at a rural site near 

32 Hobbs, New Mexico. The section is divided into six major subsections: (1) demography, 

33 including minority and low-income populations (environmental justice); (2) employment and 

34 income; (3) taxes; (4) housing; (5) public utilities; and (6) public services. These subsections 

35 include discussions of spatial (e.g., regional, vicinity, and site) and temporal (e.g., 10-year 

36 increments of population growth) considerations, where appropriate. Supporting analyses are 

37 provided in Appendix D – Socioeconomics. 
 3-62 

1 NRC staff collected and analyzed regional socioeconomic data, including the commuting points 

2 of origin and destination of all workers among Lea County and its neighboring counties, to 

3 determine the appropriate socioeconomic ROI. 

4 The NRC staff considered counties with their land area mostly within the 80-km (50-mi) radius of 

5 the site, or with a small portion of the area within the 80-km (50-mi) radius, but with a large 

6 population center within the 80-km (50-mi) radius, which was assumed to be a reasonable 

7 commuting distance. Two counties in New Mexico and three counties in Texas have these 

8 characteristics: Lea County and Eddy Counties, in New Mexico, and Andrews, Gaines, and 

9 Yoakum Counties, in Texas. 

10 Commuting patterns of working residents in Lea County demonstrate a preference for a work 

11 site in Lea County, and residents of the surrounding counties have demonstrated a reluctance 

12 to drive to a worksite in Lea County. However, Carlsbad and the Waste Isolation Pilot Plant are 

13 in Eddy County, approximately 80 km (50 mi) from the proposed site, and some residents with 

14 the appropriate skill set for the IIFP facility may commute to the proposed IIFP facility. Despite 

15 the limited employment opportunities in Andrews, Gaines, and Yoakum Counties, few residents 

16 of those counties work in Lea County, even with its larger employment base. Therefore, it is 

17 reasonable to assume that most of the IIFP workforce will come from Lea or Eddy Counties. 

18 Changes in population are the key driver of impacts to socioeconomics. Therefore, the 

19 proposed action has the potential to impact socioeconomics (employment, population, income, 

20 housing, infrastructure, and community services) within Lea and Eddy Counties, because those 

21 are the counties most likely to incur population increases due to the proposed action, and it is 

22 unlikely to affect socioeconomic variables in the Texas counties. 

23 Based on this analysis, NRC staff assumes that the socioeconomic ROI for this project is Lea 

24 and Eddy Counties, New Mexico. The majority of the socioeconomic impacts would be 

25 expected to occur in Lea County because the proposed IIFP site is in Lea County, and 

26 because of Lea County’s population characteristics, commuting patterns, and amenities. See 

27 Figure 3-21 for the counties and major populated areas within the ROI. 

28 3.9.1 Demography 

29 3.9.1.1 Populations within the Socioeconomic ROI 

30 The socioeconomic ROI comprises Lea and Eddy Counties, New Mexico. The proposed IIFP 

31 site would be in unincorporated Lea County, New Mexico. The nearest population center, 

32 Hobbs, is approximately 22.5 km (14 miles) east of the proposed site. The nearest residence is 

33 approximately 2.6 km (1.6 mi) northwest of the proposed site (Figure 3-2). 

34 Table 3-19 lists selected population characteristics of the counties in the ROI, and for 

35 comparison, New Mexico. Population characteristics, including race, ethnicity, and population 

36 density of the counties in the ROI broadly reflect those same characteristics in New Mexico. 

37 The ROI 2009 estimated population of 112,938 is about 5.6 percent of the 2009 estimated New 

38 Mexico population (Table 3-19). The racial and Hispanic demographics of the ROI residents 

39 generally reflect the racial and Hispanic demographics of residents in New Mexico as a whole. 

40 However, the ROI has a noticeably greater percentage than the state of persons who identified 

41 themselves as of the white race and a markedly smaller percentage of persons who identified 

42 themselves as “American Indian and Alaskan Native.” Both ROI counties are sparsely 

43 populated, as is New Mexico. New Mexico’s average density is 15 persons per square mile, 
 3-63 

1 Figure 3-21. Region of Influence Map

2 
 3-64 

1 Table 3-19. Select Population Characteristics of Counties within the ROI and the State 

2 of New Mexico 

New Mexico Lea County 

Eddy 

County 

Population, 2009 estimatea 2,009,671 60,232 52,706 

White, percent 83.6 90.5 93.5 

Black, percent 3.1 5.8 2.5 

American Indian and Alaskan Native, percent 9.7 1.4 1.6 

Asian, percent 1.5 0.7 0.8 

Native Hawaiian and other Pacific Islander, percent 0.2 0.1 0.2 

Two or more races, percent 1.9 1.5 1.4 

Hispanic or Latino Origin, percentb 45.6 49.6 43.4 

Average Family Size, 2008c 3.23 2.93 3.04 

Land Area, 2000, square milea 121,356 4,393 4,182 

Persons per square mile, 2000a 15.0 12.6 12.4 

3 Source: 

a 4 USCB, 2010a 

b 5 Hispanics may be of any race, so are also included in applicable race categories 

c 6 USCB, 2010b 

7 

8 

9 and Lea and Eddy counties’ densities are between 12 and 13 persons per square mile. The 

10 average density in the United States is about 80 persons per square mile (USCB, 2010a). The 

11 average family size in Lea County (2.93 people) and in Eddy County (3.04 people) is smaller 

12 than the average family size in New Mexico (3.23 people) (USCB, 2010b). 

13 Table 3-20 provides 2009 estimated population information for Lea and Eddy Counties and their 

14 incorporated municipalities. In 2009, the population of Lea County was estimated to be 60,232 

15 (USCB, 2010c). Slightly more than half of the county’s population resides in Hobbs, the largest 

16 municipality in the county (USCB, 2010d). Hobbs is the largest city in southeastern New Mexico 

17 and serves as a commercial center for the population within the 80-km (50-mi) radius of the 

18 proposed site. The Lea County seat, Lovington, had an estimated 2009 population of 10,108 

19 (USCB, 2010d). Other incorporated communities in the county include Eunice, Jal, and Tatum. 

20 Tables 3-21 and 3-22 provide historic populations, population estimates, and population 

21 projection data, including average annual growth rates, for the counties in the ROI, and for 

22 comparison, New Mexico. Historically, the population growth rates in the ROI counties have 

23 generally lagged the population growth rate of New Mexico. The projected population growth 

24 rates for the counties also lag the projected growth rates for the state. 

25 In 2009, the Eddy County population was estimated to be 52,706 (USCB, 2010a). Carlsbad, the 

26 county seat, is the largest city in the county with approximately half of the county population 

27 (USCB, 2010d). Northeastern sections of Carlsbad are within 80 km (50-mi) of the proposed 

28 site (Figure 3-1) but most of the town is just outside the 80-km (50-mi) radius. Other 

29 incorporated communities in Eddy County include Artesia, Hope, and Loving. 
 3-65 

1 Table 3-20. Population Estimates of ROI Counties and Incorporated Municipalities, 

2 2009 

Political Jurisdiction 

2009 Estimated 

Population 

Percent of County 

Population 

Lea Countya 60,232 -- 

Euniceb 2,809 4.7 

Hobbsb 30,838 51.2 

Jalb 2,074 3.4 

Lovingtonb 10,108 16.8 

Tatumb 767 1.3 

Eddy Countya 52,706 -- 

Artesiab 11,338 21.5 

Carlsbadb 26,259 49.8 

Hopeb 109 0.2 

Lovingb 1,366 2.6 

3 Source: 

a 4 USCB, 2010c 

b 5 USCB, 2010d 

6 

7 Table 3-21. Historic Population in the ROI, 1990 to 2009 

Political Jurisdiction 1990a 2000b 2009b

New Mexico 1,515,069 1,819,046 2,009,671 

Lea County 55,765 55,511 60,232 

Eddy County 48,605 51,658 52,706 

Average Annual Growth Rate 

Political Jurisdiction 1990 to 2000a,b 2000 to 2009b

New Mexico 1.85% 1.11% 

Lea County -0.05% 0.91% 

Eddy County 0.61% 0.22% 

8 Source: 

a 9 USCB, 2000b 

b 10 USCB, 2010c 

11 

12 Table 3-22. Projected Population in the ROI, 2005 to 2035 

Political 

Jurisdiction 2005a

 2010a 2020a 2030a 2035a

New Mexico 1,969,292 2,162,331 2,540,145 2,864,796 3,018,289 

Lea County 57,006 60,896 67,479 72,928 75,716 

Eddy County 52,167 54,145 58,294 60,764 61,605 

Average Annual Growth Rate 

Area 2005 to 2010 2010 to 2020 2020 to 2030 2030 to 2035 

New Mexico 1.89% 1.62% 1.21% 1.05% 

Lea County 1.33% 1.03% 0.78% 0.75% 

Eddy County 0.75% 0.74% 0.42% 0.28% 

13 Source: BBER, 2008 

a 14 Population projections are built on slightly different base year numbers than those presented in Table 3-22. 
 3-66 

1 3.9.1.2 Environmental Justice: Minority and Low Income Populations 

2 3.9.1.2.1 Methodology 

3 On February 11, 1994, the President signed Executive Order 12898, “Federal Actions to 

4 Address Environmental Justice in Minority Populations and Low-Income Populations,” which 

5 directs all Federal agencies to develop strategies that consider environmental justice in their 

6 programs, policies, and activities. Environmental justice is described in the Executive Order as 

7 “identifying and addressing, as appropriate, disproportionately high and adverse human health 

8 or environmental effects of its programs, policies, and activities on minority populations and low9 income populations.” On December 10, 1997, the Council on Environmental Quality (CEQ) 

10 issued Environmental Justice Guidance under the National Environmental Policy Act (CEQ, 

11 1997). The NRC has provided general guidelines on the evaluation of environmental analyses 

12 in Environmental Review Guidance for Licensing Actions Associated with NMSS [Nuclear 

13 Material Safety and Safeguards] Programs (NUREG-1748) (NRC, 2003), and issued a final 

14 policy statement on the Treatment of Environmental Justice Matters in NRC Regulatory and 

15 Licensing Actions (69 FR 52040) and environmental justice procedures to be followed in NEPA 

16 documents prepared by the NRC’s Office of Nuclear Material Safety and Safeguards (NMSS). 

17 NRC’s NMSS environmental justice guidance, as found in Appendix C to NUREG-1748 (NRC, 

18 2003), recommends that the area for assessment for a facility in a rural area be a circle with a 

19 radius of approximately 6.4 km (4 mi) whose centroid is the facility being considered. However, 

20 the guidance also states that the scale should be commensurate with the potential impact area. 

21 Therefore to ensure consistency with the accident analysis, which considers airborne impacts to 

22 populations within an 80-km (50-mi) radius, the NRC staff concludes that an environmental 

23 justice assessment area with an 80-km (50-mi) radius would be appropriate. As such, New 

24 Mexico and Texas and each county with some land area within the 80-km (50-mi) radius of the 

25 proposed IIFP site (i.e., centroid of Section 27) are appropriate areas for comparative analysis. 

26 A minority or low-income community may be considered as either a population of individuals 

27 living in geographic proximity to one another or a dispersed/transient population of individuals 

28 (e.g., migrant workers) where either type of group experiences common conditions of 

29 environmental exposure (NRC, 2003). NUREG-1748 defines minority categories as: American 

30 Indian or Alaskan Native, Asian, Native Hawaiian or other Pacific Islander, African American 

31 (not of Hispanic or Latino origin), some other race, and Hispanic or Latino ethnicity (of any race) 

32 (NRC, 2003). The 2000 Census introduced a multiracial category. Anyone who identifies 

33 themselves as white and a minority is counted as that minority group. Individuals that identify 

34 themselves as more than one minority are counted in a "two or more races" group (NRC, 2003). 

35 Low-income is defined as being below the poverty level as defined by the U.S. Census Bureau 

36 (NRC, 2003). 

37 The NRC-recommended area for evaluating census data is the census block group, which is 

38 delineated by the United States Census Bureau and is the smallest area unit for which race and 

39 poverty data are available (NRC, 2003). The NRC staff used ESRI ArcGIS® 9.3 software which 

40 accessed the 2000 decennial census, to identify block groups with low-income or minority 

41 populations within 80 km (50 mi) of the proposed IIFP site. NRC staff included a block group if 

42 any part of its fell within 80 km (50 mi) of the proposed site; 96 block groups were identified as 

43 being within, or partially within the 80-km (50-mi) radius. 

44 NRC guidance indicates that a significant minority or low-income population exists if at least one 

45 of these conditions exists: 
 3-67 

1 The minority or low-income population of the block group is more than 50 percent of the entire 

2 block group population. 

3 The minority or low-income population percentage of the block group is significantly greater 

4 (typically at least 20 percentage points) than the minority or low-income population percentage 

5 in the geographic areas chosen for comparative analysis. 

6 3.9.1.2.2 Minority Populations 

7 Using the U.S. Census Bureau (USCB) 2000 census data, NRC staff calculated (1) the 

8 percentage of each block group’s population represented by each minority category for each of 

9 the 96 block groups within the 80 km (50-mi) radius, (2) the percentage that each minority 

10 category represented of the entire populations of New Mexico and Texas and (3) the 

11 percentage that each minority category represented of each of the counties that has some land 

12 within the 80-km (50-mi) radius of the proposed site. If the percentage of any minority in any 

13 block group exceeded 50 percent of the block group’s total population or exceeded the 

14 minority’s corresponding county or state percentages by more than 20 percent, then that block 

15 group was identified as having a significant minority population. 

16 Table 3-23 identifies the number of block groups that met the 50 percent criterion or the more17 than-20-percent criterion (some block groups may meet both criteria) for their corresponding 

18 state and/or county. If a block group met one or both of the criterion for either the state or the 

19 county, it was not double-counted. Of the 96 census block groups within the 80-km (50-mi) 

20 radius, 16 have a significant percentage of minority residents. Thirty-two block groups have a 

21 significant percentage of Hispanic ethnicity residents. Figures 3-22 through 3-24 provide 

22 graphical representations of the data presented in Table 3-23. 

23 Seasonal agricultural (migrant) workers may make up a portion of the minority population within 

24 the 80-km (50-mi) radius. Although migrant worker population counts are not available from the 

25 USCB, the U.S. Department of Agriculture has collected information on farms that employ 

26 migrant labor. The number of farms that employ migrant laborers in each county which falls 

27 wholly or partially within the 80-km (50-mi) radius are: in New Mexico Lea County (9), Eddy 

28 County (12), and Chaves County (19) and in Texas Loving County (1), Winkler County (2), 

29 Andrews County (2), Gaines County (27), Yoakum County (9), Terry County (26), and Cochran 

30 County (15 ) (USDA, 2007). The number of these farms which fall wholly or partially within the 

31 80-km (50-mi) radius is not known. 

32 There are no Federally recognized Native American reservations within the 80-km (50-mi) 

33 radius of the proposed IIFP site (NPS, Undated). 

34 3.9.1.2.3 Low-Income Populations 

35 The NRC guidance defines low-income households based on statistical poverty thresholds 

36 (NRC, 2003). 

37 Using the USCB 2000 census data, NRC staff calculated the percentage of each block group’s 

38 population represented by low-income households for each of the 96 block groups within the 

39 80 km (50-mi) radius, and the percentage of low-income households in New Mexico and Texas 

40 and in each of the counties that had some land within the 80-km (50-mi) radius of the site. If the 

41 percentage of any low-income block group exceeded 50 percent of the block group’s total 

42 population or exceeded the corresponding county or State low-income percentages by more 
 3-68 

1 Figure 3-22. African American Map

2 
 3-69 

1 Figure 3-23. Some Other Race Map

2 
 3-70 

1 Figure 3-24. Hispanic Ethnicity Map

2 

3 

4 
 3-71 

1 Table 3-23. Block Groups within 80 km (50 mi) of the Proposed IIFP Site with 

2 Significant Minority or Low-Income Populations (Meeting 50 Percent Criteria or 

3 Exceeding Respective County or State Percentages by 20 Percent) 

County 

Name 

Number 

of Block 

Groups 

African 

American 

American 

Indian or 

Alaskan 

Native Asian 

Native 

Hawaiian 

or Other 

Pacific 

Islander 

Some 

Other 

Race 

Two 

or 

More 

Races 

Hispanic 

Ethnicity 

LowIncome 

Households 

Chaves 2 0 0 0 0 0 0 1 0 

Eddy 3 0 0 0 0 0 0 1 0 

Lea 64 1 0 0 0 14 0 24 10 

Andrews 3 0 0 0 0 0 0 0 0 

Cochran 1 0 0 0 0 0 0 0 0 

Gaines 13 0 0 0 0 0 0 3 0 

Loving 1 0 0 0 0 0 0 0 0 

Terry 1 0 0 0 0 0 0 0 0 

Winkler 1 0 0 0 0 0 0 0 0 

Yoakum 7 0 0 0 0 1 0 3 0 

Total 96 1 0 0 0 15 0 32 10 

State/County 

African 

American 

(%) 

American 

Indian or 

Alaskan 

Native 

(%) 

Asian 

(%) 

Native 

Hawaiian 

or Other 

Pacific 

Islander 

(%) 

Some 

Other 

Race 

(%) 

Two 

or 

More 

Races 

(%) 

Hispanic 

Ethnicity 

(%) 

LowIncome 

Households 

(%) 

New Mexico (State) 1.89 9.54 1.06 0.08 17.04 3.65 42.08 16.78 

Chaves County 1.97 1.13 0.53 0.06 21.25 3.12 43.83 19.12 

Eddy County 1.56 1.25 0.45 0.09 17.67 2.64 38.76 16.72 

Lea County 4.37 0.99 0.39 0.04 23.81 3.27 39.65 19.90 

Texas (State) 11.53 0.57 2.70 0.07 11.69 2.47 31.99 13.98 

Andrews County 1.65 0.88 0.71 0.02 16.79 2.87 40.00 16.74 

Cochran County 4.53 0.83 0.21 0.05 27.35 2.55 44.13 21.67 

Gaines County 2.28 0.76 0.15 0.01 14.17 2.35 35.77 19.08 

Loving County 0.00 0.00 0.00 0.00 8.96 1.49 10.45 0.00 

Terry County 5.00 0.53 0.22 0.02 14.28 3.40 44.09 20.53 

Winkler County 1.85 0.45 0.20 0.00 20.35 2.34 44.00 18.58 

Yoakum County 1.39 0.71 0.12 0.01 25.48 1.65 45.93 18.20 

4 Source: USCB, 2000a; USCB, 2000b; USCB, 2000c; USCB, 2000d; USCB, 2000e; USCB, 2000f; 

5 

6 than 20 percent, then that block group was identified as having a significant low-income 

7 population. Again, if the block group met one or both criteria, for either the state or county, it 

8 was not double-counted. 

9 Table 3-23 lists the number of block groups in each county within the 80-km (50-mi) radius that 

10 meets the 50 percent criterion or the more than 20 percent criterion for its corresponding State 

11 or county. Ten census block groups within the 80-km (50-mi) radius have a significant 

12 percentage of low-income households. Figure 3-25 locates the low-income block groups. 
 3-72 

1 Figure 3-25. Low-Income Household Map

2 

3 
 3-73 

1 3.9.2 Employment and Income 

2 3.9.2.1 Employment 

3 Table 3-24 summarizes employment trends in the ROI from 2001 to 2008. From 2001 to 2008, 

4 growth in employment in the ROI was greater than population growth. The number of jobs in 

5 the ROI grew from 54,649 (29,463 for Lea County plus 25,186 for Eddy County) in 2001(BEA, 

6 2011a; BEA, 2011b) to 68,314 in 2008 (BEA, 2010), an increase of 25 percent. The ROI 

7 population increased from 105,562 to 110,903 (59,129 for Lea County plus 51,774 for Eddy 

8 County) (USCB, 2010c), an increase of 5 percent. Within the ROI, 2008 employment was 

9 dominated by jobs in mining (20.6 percent), government and government enterprises 

10 (10.4 percent), retail trade (10.1 percent), and construction (8.3 percent). With the exception of 

11 employment in farming, a sector that represents less than 0.5 percent of all jobs in the ROI, the 

12 number of jobs in all industrial sectors grew from 2001 to 2008 (BEA, 2010). A major employer 

13 in the ROI is the DOE’s Waste Isolation Pilot Plant, in Eddy County. Nearly 600 individuals are 

14 employed at the facility (ECP, 2008). From 2001 to 2008, the ROI unemployment rate 

15 decreased from 4.6 to 3.0 percent. However, from 2008 to June of 2010, the rate increased 

16 from 3.0 to 7.0 percent. 

17 Table 3-25 presents information about labor statistics in the ROI, and for comparison, New 

18 Mexico. The size of the ROI labor force grew from 47,199 to 57,708 (22.3 percent) between 

19 2001 and 2008, but shrank in 2009 to 57,590 and declined again in 2010, to 56,945 

20 (BLS, 2010a). The unemployment rate in the ROI has consistently remained below the 

21 unemployment rate in the State. As a point of comparison, the unemployment rate in the United 

22 States in June 2010 was 9.6 percent (BLS, 2010b). 

23 3.9.2.2 Income 

24 Table 3-26 presents income statistics for the ROI counties, their major population centers, and 

25 New Mexico. In 2008, various measures of income in Eddy County were higher and the rates of 

26 poverty in Eddy County lower than in New Mexico. With the exception of median household 

27 income, the various measures of income in Lea County were lower and the rates of poverty 

28 higher in Lea County than in New Mexico. In 2008, the poverty threshold ranged from $10,326 

29 to $47,915, depending on family characteristics. Families and individuals residing in Lea 

30 County were more likely to be living below the poverty level than those living in Eddy County. 

31 3.9.3 Taxes 

32 3.9.3.1 Income Taxes 

33 Corporate Income Taxes 

34 New Mexico imposes a corporate income tax on the total net income (including New Mexico and 

35 non-New Mexico income) of every domestic and foreign corporation doing business in or from 

36 the State, or which has income from property or employment within the State. The percentage 

37 of New Mexico income is then applied to the gross tax. For corporations with a total net income 

38 exceeding $1,000,000 annually, corporate income tax is $56,000 plus 7.6 percent of net income 

39 over $1,000,000 (NMTRD, 2010a). 

40 New Mexico also levies a corporate franchise tax of $50 per year (NMTRD, 2010a). 
3-74 

Table 3-24. Employment in ROI, by Industry, 2001 to 2008 1 

Lea 

County 

2001a

Lea 

County 

2008b

Lea 

County, 

Percent 

Change, 

2001 to 

2008 

Eddy 

County 

2001c

Eddy 

County 

2008b

Eddy 

County, 

Percent 

Change, 

2001 to 

2008 

ROI 

Jobs 

2008 

ROI, 

Percent 

Change in 

Jobs, 2001 

to 2008 

Total Employment 29,463 37,622 27.7% 25,186 30,692 21.9% 68,314 25.0% 

Farm Employment 1,026 725 -29.3% 975 798 -18.2% 1,523 -23.9% Nonfarm Employment 28,437 36,897 29.7% 24,211 29,894 23.5% 66,791 26.9% Private Employment 24,622 33,176 34.7% 20,604 26,007 26.2% 59,183 30.9% Forestry, fishing, and related activities 108 101 -6.5% 163 177 8.6% 278 2.6% Mining 5,484 8,339 52.1% 3,042 4,585 50.7% 12,924 51.6% Utilities 247 489 98.0% 134 145 8.2% 634 66.4% Construction 2,131 3,460 62.4% 1,506 2,597 72.4% 6,057 66.5% Manufacturing 428 805 88.1% 897 922 2.8% 1,727 30.3% Wholesale Trade 1,199 1,255 4.7% 555 669 20.5% 1,924 9.7% Retail Trade 3,371 3,393 0.7% 2,972 3,126 5.2% 6,519 2.8% Transportation and Warehousing 996 1,588 59.4% 972 1,097 12.9% 2,685 36.4% Information 251 382 52.2% 345 309 -10.4% 691 15.9% Finance and Insurance 722 879 21.7% 701 909 29.7% 1,788 25.7% Real Estate and Rental and Leasing 779 1,130 45.1% 645 890 38.0% 2,020 41.9% Professional, Scientific, and Technical Services 603 1,019 69.0% 715 1,315 83.9% 2,334 77.1% Management of Companies and Enterprises 121 137 13.2% 54 219 305.6% 356 103.4% Administrative and Waste Services 1,446 2,039 41.0% 1,563 1,924 23.1% 3,963 31.7% Educational Services (D) (D) NA 97 118 21.6% NA NA Health Care and Social Assistance (D) (D) NA 2,450 2,835 15.7% NA NA 

2 
3-75 

Table 3-24. Employment in ROI, by Industry, 2001 to 2008 (Continued) 1 

Lea 

County 

2001a

Lea 

County 

2008b

Lea County, 

Percent 

Change, 

2001 to 2008 

Eddy 

County 

2001c

Eddy 

County 

2008b

Eddy 

County, 

Percent 

Change, 

2001 to 2008

ROI 

Jobs 

2008 

ROI, 

Percent 

Change in 

Jobs, 2001 

to 2008 

Arts, Entertainment, and Recreation 219 605 176.3% 208 207 -0.5% 812 90.2% Accommodation and Food Services 1,685 2,200 30.6% 1,898 2,175 14.6% 4,375 22.1% Other Services, except Public Administration 1,652 1,921 16.3% 1,687 1,788 6.0% 3,709 11.1% Government and Government Enterprises 3,815 3,721 -2.5% 3,607 3,887 7.8% 7,608 2.5% Federal, Civilian 119 105 -11.8% 488 764 56.6% 869 43.2% Military 178 160 -10.1% 165 139 -15.8% 299 -12.8% State and Local 3,518 3,456 -1.8% 2,954 2,984 1.0% 6,440 -0.5% State Government 286 289 1.0% 741 750 1.2% 1,039 1.2% Local Government 3,232 3,167 -2.0% 2,213 2,234 0.9% 5,401 -0.8% 

Source: 2 a BEA, 2010 3 b BEA, 2011b 4 c BEA, 2011a 5 NA Not Applicable 6 (D) Information not shown (by BEA) to avoid disclosure of confidential information, but estimates for this item are included in the totals 7 

8 
 3-76 

1 Table 3-25. Labor Statistics, ROI and New Mexico, 2001 to 2010 

Lea County Eddy County ROI New Mexico 

2001 (annualized) Labor Force 23,702 23,497 47,199 863,682 

2008 (annualized) Labor Force 29,895 27,813 57,708 961,259 

2009 (annualized) Labor Force 28,890 28,700 57,590 955,904 

2010 (June) Labor Force 28,103 28,842 56,945 962,423 

Percent Change 2001 to 2008 26.1% 18.4% 22.3% 11.3% 

Percent Change, 2001 to 2010 18.6% 22.7% 20.6% 11.4% 

2001 Unemployment Rate 4.3% 5.0% 4.6% 4.9% 

2008 Unemployment Rate 2.9% 3.1% 3.0% 4.5% 

2009 Unemployment Rate 7.6% 5.5% 6.6% 7.2% 

June, 2010 Unemployment Rate 8.0% 6.1% 7.0% 8.5% 

2 Source: BLS, 2010a 

3 

4 Table 3-26. Income Statistics, ROI Counties and Population Centers, and New Mexico, 

2008a 5 

Lea County Eddy County New Mexico 

Median Household Income $43,638 $45,858 $43,202 

Median Family Income $47,853 $57,658 $51,724 

Per Capita Income $20,319 $25,151 $22,781 

Families below Poverty level, percent 15.7 10.2 13.7 

Individuals below Poverty Level, percent 18.9 14.4 17.9 

6 Source: USCB, 2010b 

a 7 All dollar values are expressed in 2008 inflation-adjusted dollars 

8 

9 Individual Income Taxes 

10 New Mexico imposes an individual income tax on the net income of every resident and 

11 nonresident employed or engaged in business in or from the State or deriving any income from 

12 any property or employment within the State. The rates vary depending upon filing status and 

13 income. 

14 The top tax bracket is 4.9 percent (NMTRD, 2010b).

15 3.9.3.2 Sales Tax/Gross Receipts Tax 

16 New Mexico is one of a minority of states that has a gross receipts tax structure instead of a 

17 sales tax structure. Gross receipts are the total amount of money or value of other 

18 considerations received from (NMTRD, 2011): 

19 • Selling property in New Mexico 

20 • Leasing or licensing property used in New Mexico 

21 • Granting a right to use a franchise used in New Mexico 
 3-77 

1 • Performing services in New Mexico 

2 • Selling research and development services performed outside New Mexico, the 

3 product of which is initially used in New Mexico 

4 Although the gross receipts tax is imposed on businesses, it is common for a business to pass 

5 the gross receipts tax on to the purchaser either by separately stating it on the invoice or by 

6 combining the tax with the selling price (NMTRD, 2011). 

7 The gross receipts tax rate varies throughout the state from 5.125 percent to 8.6875 percent, 

8 depending on the location of the business. It varies because the total rate combines rates 

9 imposed by the state, counties, and, if applicable, municipalities where the businesses are 

10 located. The business pays the total gross receipts tax to the state, which then distributes the 

11 counties' and municipalities' portions to them (NMTRD, 2011). 

12 The current gross receipts taxes in Lea and Eddy Counties are presented in Table 3-27. 

13 Table 3-27. Gross Receipts Tax Rates in the ROI, as of July, 2010 

Lea County Ratesa Eddy County Rates 

Eunice 6.8125% Artesia 7.1875% 

Hobbs 6.8125% Carlsbad 7.4375% 

Jal 6.8125% Hope 6.6250% 

Lovington 6.8750% Loving 6.8125% 

Lovington Industrial Park 5.5% Remainder of County 5.75% 

Tatum 6.8125% -- -- 

Remainder of County 5.5% -- -- 

14 Source: NMTRD, 2011 

a 15 Rates include State, county, and municipal gross receipts taxes, combined 

16 

17 3.9.3.3 Property Taxes 

18 Four governmental entities in New Mexico are authorized to tax: the state, counties, 

19 municipalities, and school districts (NRC, 2005). Property assessment rates are 33.3 percent of 

20 appraised values (NRC, 2005; Eddy County, 2007). The tax applied to the assessed property 

21 value is a combination of state, county, municipal, and school district levies (NRC, 2005). The 

22 Lea County tax rate for nonresidential property outside the city limits of Hobbs is $24.949 per 

23 $1,000 of net taxable value of a property (Lea County, 2009). Rates for nonresidential 

24 properties are higher within the city limits of Hobbs. Residential property tax rates are lower for 

25 properties outside of Hobbs, and higher for those within Hobbs. 

26 New Mexico and its local governments offer industrial revenue bonds (IRBs) as a way to 

27 encourage company relocations and expansions that provide jobs and economic opportunities 

28 for residents and communities. IRBs allow projects to qualify for certain tax incentives, including 

29 a property tax exemption on most real and personal property constituting a project’s property, 

30 and possible exemptions from gross receipts tax and use tax related to the acquisition of 

31 equipment and other personal property for use in the business to be conducted at the project 

32 (City of Albuquerque, 2011). International Isotopes, the parent corporation of IIFP, has an IRB 

33 agreement with Lea County, New Mexico (IIFP, 2011). As a result, IIFP is generally exempt 

34 from property taxes. However, the school district and the New Mexico Junior College are not 
 3-78 

1 part of this IRB agreement. Table 3-28 contains annual property tax revenue data for the local 

2 entities that would have the authority to levy a property tax on the proposed IIFP facilities. 

3 Table 3-28. IIFP Annual Property Tax Information 

Property Taxing Entity 

Total Annual 

Tax Revenues 

Estimated IIFP 

Facility in Lieu of 

Property Tax 

Payment 

IIFP Facility 

Estimated in Lieu of 

Property Tax 

Payment as Percent 

of Total Annual Tax 

Revenues 

Hobbs Municipal School District $71,126,000a $78,300 - $123,300 <1% 

New Mexico Junior College $37,201,924b $139,200 - $219,200 <1% 

4 Sources: 

a 5 NCES, 2008 

b 6 NCES, 2009 

7 

8 3.9.4 Housing 

9 Table 3-29 summarizes housing data for Lea County, Eddy County and the largest city within 

10 each county, Hobbs and Carlsbad, respectively. A variety of types, prices, and settings 

11 comprise the housing inventory in the socioeconomic ROI. In 2008 there were 46,971 housing 

12 units in Lea and Eddy Counties (USCB, 2010b). The two largest population centers in the 

13 counties, Hobbs and Carlsbad, had approximately half of the total ROI housing inventory 

14 (USCB, 2010b). Within the ROI, approximately 12.4 percent (5,823 units) of the units were 

15 vacant (USCB, 2010b). Of the 41,148 occupied units, 29,021 were owner-occupied 

16 (70.5 percent) and 12,127 (29.5 percent) were renter-occupied (USCB, 2010c). The median 

17 value of an owner-occupied unit was $82,200 in Lea County and $85,600 in Eddy County 

18 (USCB, 2010b). For comparison, the median value of an owner-occupied house in New Mexico 

19 was $154,900 in 2008 (USCB, 2010b). 

20 In 2008, the median monthly rent was $661 in New Mexico and slightly less in both Lea and 

21 Eddy Counties (USCB, 2010b). Mobile homes accounted for 16.9 percent of the housing in Lea 

22 County and 14.0 percent of the housing in Eddy County (USCB, 2010e). Mobile homes made 

23 up 16.7 percent of the housing inventory in New Mexico (USCB, 2010e). The housing inventory 

24 in the ROI grew by 1.1 percent from 2008 to 2009, while the growth in the ROI’s population was 

25 0.2 percent (USCB, 2010a; USCB, 2010d). 

26 Table 3-29. Housing Characteristics in ROI Counties and Population Centers, 2008 

County/ 

Population 

Center 

Housin

g Units 

2008a

Occupied 

Units, 

2008a

OwnerOccupied 

Units, 

2008a

Renteroccupied, 

2008a

Vacant 

Housing 

Units, 

2008a

Percent 

Units Vacant 

of All Units, 

2008a

Mobile 

Homes, 

2008b

Lea County 24,495 21,653 14,912 6,741 2,842 11.6% 4,134 

Hobbs 12,299 10,854 6,998 3,856 1,445 11.7% 1,201 

Eddy County 22,476 19,495 14,109 5,386 2,981 13.3% 3,142 

Carlsbad 11,565 10,073 6,954 3,119 1,492 12.9% 556 

ROI Total 46,971 41,148 29,021 12,127 5,823 12.4% 7,276 

27 Source: 

a 28 USCB, 2010b 

b 29 USCB, 2010f 
 3-79 

1 3.9.5 Public Utilities 

2 3.9.5.1 Major Public Water Suppliers 

3 EPA lists two major public water suppliers in Lea County and three major public water suppliers 

4 in Eddy County (EPA, 2010b). Major public water systems are those that serve more than 

5 3,300 people. Table 3-30 presents water production and use statistics for these suppliers. 

6 Most of the major water suppliers in the ROI have excess capacity. 

7 Table 3-30. Major Public Water Suppliers in ROI, 2007 – 2009 

Water System Namea

County 

Serveda

Population 

Serveda

Primary 

Water Source 

Typea

Average 

Daily Use 

(MGD)b

Maximum 

Capacity 

(MGD)b

Hobbs Municipal Water Supply Lea 33,000 Groundwater 7.0 N/A 

Lovington Municipal Water 

Supply Lea 9,643 Groundwater 2.5 6 

Artesia Municipal Water System Eddy 14,000 Groundwater 2.3 8.64 

Carlsbad Municipal Water 

System Eddy 27,000 Groundwater 3.8 28.8 

Otis Mutual Domestic Water 

Consumer’s Association Eddy 5,000 Groundwater 1.0 NA 

8 Source: 

a 9 EPA, 2010b 

b 10 NMED, 2010b 

11 MGD = million gallons per day 

12 

13 3.9.5.2 Major Public Wastewater Treatment Facilities 

14 The New Mexico Environment Department (NMED) lists four major public wastewater treatment 

15 facilities in Lea and Eddy Counties (NMED, 2010c). Major wastewater treatment facilities are 

16 those that serve more than 3,000 people. Table 3-31 presents wastewater treatment production 

17 and capacity statistics for these facilities. All of the major wastewater treatment facilities in the 

18 ROI have excess capacity. 

Table 3-31. Major Wastewater Treatment Facilities in ROIa 19 

Facility Nameb

2009 Population 

Servedb

Average Daily 

Production 

(MGD) 

Maximum 

Permitted 

Capacity (MGD)b

City of Artesia 11,208 1.3c 3.0 

City of Carlsbad 26,352 2.5d 8.5 

City of Hobbs 31,151 3.4e 7.2 

City of Lovington 10,206 0.8f 2.7 

20 Source: 

a 21 Includes permitted, municipal wastewater treatment plants serving at least 3,000 persons. b 22 NMED, 2010c 

c 23 Artesia, 2010 

d 24 Carlsbad, 2010 

e 25 Hobbs, 2010 

f 26 Lovington, 2010 

27 
 3-80 

1 3.9.6 Community Services 

2 3.9.6.1 Education 

3 Table 3-32 summarizes information about public school districts and schools in the ROI. Lea 

4 County has 5 public school districts, with 36 schools for early childhood education (Age 3) 

5 through Grade 12. The total enrollment in the county public schools was 12,588 students in 

6 2008 (NCES, 2010a). There are also three private schools in the county with a total 2008 

7 enrollment of 111 students (NCES, 2010b). In addition, there are two colleges in the county, 

8 both in Hobbs. New Mexico Junior College had a 2009 enrollment of 2,300 and University of 

9 the Southwest had an enrollment of 528, with an undergraduate enrollment of 317 

10 (NCES, 2010c). 

11 Table 3-32. Public School Districts in the ROI, 2008 

County Schools 

Number of 

Schools in 

District 

Number of 

Students 

Lea County 

Eunice Municipal Schools 3 589 

Hobbs Municipal Schools 17 8,038 

Jal Public Schools 3 405 

Lovington Public Schools 10 3,247 

Tatum Municipal Schools 3 309 

Eddy County 

Carlsbad Municipal Schools 15 3,581 

Artesia Public Schools 10 6,058 

Loving Municipal Schools 3 620 

12 Source: NCES, 2010a 

13 Eddy County has 28 schools in 3 public school districts with a 2008 enrollment of 10,259 

14 students (NCES, 2010a). There is also a private school in Carlsbad with a 2008 enrollment of 

15 68 students (NCES, 2010b). New Mexico State University has a campus in Carlsbad with an 

16 enrollment of 2,050 (NCES, 2010c). 

17 3.9.6.2 Fire Protection 

18 In 2010, there were 468 active career and volunteer firefighters in the ROI (USFA, 2010). 

19 Twenty fire departments, operating out of 37 fire stations, are in the ROI (USFA, 2010). The 

20 proposed IIFP site would be within the jurisdiction of the City of Hobbs Fire Department 

21 (HFD, 2010), which is staffed with 70 career firefighters (USFA, 2010). Lea County and Eddy 

22 County have mutual aid agreements among all the municipal and independent fire departments 

23 to assist with additional response services (HFD, 2010; LPD, 2010). Table 3-33 provides 

24 information about fire protection in the ROI. 

25 Table 3-33. Fire Protection in the ROI, 2010 

County 

2009 County 

Populationa

Active 

Firefighters 

2010b

Ratio of Residents 

to Active 

Firefighters, 2010 

Number of Fire 

Stations, 2010b

Lea 60,232 176 342 9 

Eddy 52,706 292 181 28 

ROI Total 112,938 468 241 37 

26 Sources: 

a

 USCB, 2010a; b 27 USFA, 2010 
 3-81 

1 3.9.6.3 Law Enforcement 

2 In 2009, there were 89 county and 196 municipal law enforcement officers serving the two ROI 

3 counties (FBI, 2009a; FBI, 2009b; LPD, 2010). Law enforcement services in the ROI are 

4 provided by the Lea County and Eddy County Sheriff Departments and the Artesia, Carlsbad, 

5 Eunice, Hobbs, Jal, Lovington, and Tatum municipal police departments (FBI, 2009a; FBI, 

6 2009b). Hope and Loving also maintain police departments (LPD, 2010). The Lea County 

7 Sheriff’s Department has jurisdiction in the unincorporated portion of Lea County, including the 

8 proposed site (HFD, 2010; LPD, 2010). The New Mexico State Police could provide a second 

9 level of response to any sheriff or police department via existing mutual aid agreements (HFD, 

10 2010; LPD, 2010). Table 3-34 provides information about law enforcement in the ROI. 

11 3.9.6.4 Hospitals and Physicians 

12 Lea County has two general medical and surgical hospitals. The Lea Regional Medical Center 

13 in Hobbs is the closest hospital to the proposed site. It has 214 staffed beds (AHA, 2007). 

14 Nor-Lea General Hospital, in Lovington, has 12 staffed beds (AHA, 2007). Eddy County also 

15 has two general medical and surgical hospitals. The Carlsbad Medical Center has 127 staffed 

16 beds and the Artesia General Hospital, in Artesia, has 20 staffed beds (AHA, 2007). The ROI 

17 has 146 practicing physicians; 69 physicians in Lea County representing 24 specialties and 

18 77 physicians representing 25 specialties in Eddy County (AMA, 2010). Both Lea County and 

19 Eddy County are considered to be medically underserved areas (HRSA, Undated). 

20 Table 3-34. Law Enforcement in ROI Counties and Incorporated Places, 2009 

County/Citya,e

Population 

2009a,e

Law Enforcement 

Officers 

2009b,c

Ratio of residentsto-Law Enforcement 

Officers, 2009 

Lea County -- 43 -- 

Eunice 2,809 7 -- 

Hobbs 30,838 70 -- 

Jal 2,074 5 -- 

Lovington 10,108 23 -- 

Tatum 767 3 -- 

Lea County Totals 60,232 151 399 

Eddy Countyb -- 46 -- 

Artesia 11,338 33 -- 

Carlsbad 26,259 50 -- 

Hoped 109 1d -- 

Lovingd 1,366 4d -- 

Eddy County Totals 52,706 134 393 

21 Sources: 

a 22 USCB, 2010a 

b 23 FBI, 2009a 

c 24 FBI, 2009b 

d 25 LPD, 2010 

e 26 USCB, 2010d 

27 
 3-82 

1 3.10 Traffic and Transportation 

2 3.10.1 Roadways 

3 Figure 3-26 shows the major highways near the proposed IIFP site. The site is approximately 

4 1.6 km (1 mi) north of US 62/180 and immediately east of NM 483, in close proximity to the 

5 intersection of the two roadways. 

6 From the east, US 62/180 crosses into New Mexico from Texas approximately 29 km (18 mi) 

7 from the IIFP site, runs through the City of Hobbs, intersects NM 483 at the IIFP site, and 

8 continues to Carlsbad, NM. Near the proposed IIFP site, US 62/180 is called Carlsbad Highway 

9 and is a 4-lane divided highway that provides access to the proposed site from the east and 

10 west. 

11 NM 483 is a 2-lane north-south highway that connects Lovington, New Mexico to US 62/180. 

12 East of the proposed site north-south roadways NM 8 and NM 18 provide access to US 62/180 

13 from Eunice, New Mexico and several unincorporated areas. NM 132 provides access to US 

14 62/180 in Hobbs from points in Texas. NM 529 is an east-west roadway that intersects 

15 US62/180 just west of the proposed IIFP site (Figure 3-26). 

16 Table 3-35 provides annual average daily traffic (AADT) data for the roadways in the vicinity of 

17 the proposed IIFP site (Figure 3-26). These roadways are used as trucking routes. The 

18 numbers in the left column correspond to the numbered locations on Figure 3-26. 

19 Table 3-35. AADT Volumes for Roadways that Access the Proposed IIFP Site 

 Roadway Location AADT Year 

1 US 62/180 NM 8 Junction 7,868a 2008 

2 NM 483 US 62/180 Junction 955b 2008 

3 NM 132 US 18/NM 218 Junction 4,604b 2008 

4 NM 8 0.256-mi South of US 62/180 1,302b 2008 

5 NM 18 US 62/180 Junction 12,407a 2007 

6 NM 176 NM 8 Junction 2,124a 2008 

7 NM 529 West of US 62/180 Junction 2,393b 2008 

Source: NMDOT, 2009 

a

 The AADT was derived from recent coverage counts. 

b The AADT was derived using an Annual Growth Factor, generalized from coverage counts within the traffic segment 

and updated with loop and growth factors. 

20 

21 3.10.2 Railroads 

22 The Texas-New Mexico Railroad is an active rail line through Hobbs, New Mexico, 

23 approximately 16.2 km (10 mi) east of the proposed IIFP site. It is a shortline railroad operating 

24 between Monahans, Texas and Lovington, New Mexico. The rail line is predominantly used for 

25 freight transport associated with the oil and gas industry, and typical freight includes chemicals, 

26 minerals, construction aggregate, industrial waste, and scrap. There is a freight dock and 

27 warehouse in the Hobbs area. Train frequency is daily six days per week (IPH, 2010). 

28 
 3-83 

1 Figure 3-26. AADT Location Map

2 

3 
 3-84 

1 3.10.3 Airports 

2 The Lea County Regional (Hobbs) Airport is approximately 13 km (8 mi) from the proposed IIFP 

3 site just northwest of the Hobbs city limits. The airport currently supports only general aviation, 

4 but may support domestic flights in the future (AIRNAV, 2010). Two additional airports are in 

5 Lea County: The Lea County-Zip Franklin Memorial Airport is 5 km (3 mi) west of Lovington 

6 (approximately 26 km [16 mi] from the IIFP site) and the Lea County-Jal Airport is 6 km (3.7 mi) 

7 northeast of Jal (approximately 64 km [40 mi] from the IIFP site). These airports support 

8 general aviation operations (AIRNAV, 2010). 

9 3.11 Noise 

10 The definition of noise is “unwanted or disturbing sound.” Sound measurements are described 

11 in terms of frequencies and intensities. The decibel (dB) is used to describe the sound pressure 

12 level. The A-scale on a sound level meter best approximates the audible frequency response of 

13 the human ear, and is commonly used in noise measurements. Sound pressure levels 

14 measured on the A-scale of a sound meter are abbreviated dB(A). In noise measurements, 

15 sound pressure levels are typically averaged over a given length of time, because 

16 instantaneous levels can vary widely. 

17 The intensity of sound decreases with increasing distance from the source. Typically, 

18 sound levels for a point source will decrease by 6 dB(A) for each doubling of distance. This 

19 may vary depending on the terrain, topographical features, and frequency of the noise 

20 source.

21 Generally, sound level changes of 3 dB(A) are barely perceptible, while a change of 5 dB(A) is 

22 readily noticeable by most people. A 10 dB(A) increase is usually perceived as a doubling of 

23 loudness, and conversely, noise is perceived to be reduced by one-half when a sound level is 

24 reduced by 10 dB(A). 

25 Sound levels can vary for indoor and outdoor noise sources. For example, a jet flying overhead 

26 at 1,000’ will produce a sound level of 100 dB(A), the same as an inside subway train. A typical 

27 outdoor commercial area is equivalent to a normal speech conversation indoors, at 65 dB(A), 

28 and a quiet rural nighttime environment will mimic an empty concert hall, at 25 dB(A). 

29 3.11.1 Noise Level Standards 

30 Noise level standards are established by Federal agencies including the U.S. Department of 

31 Housing and Urban Development (HUD) (24 CFR 51), the Environmental Protection Agency 

32 (EPA, 1974), Federal Highway Administration (23 CFR 772), and the Occupational Safety and 

33 Health Administration (OSHA) (29 CFR 1910). 

34 Neither the city of Hobbs, Lea County, nor New Mexico have ordinances or regulations 

35 governing noise. There are no Native American Tribes within 10 km (6 mi) of the proposed site. 

36 Therefore, the facility is not subject to state, tribal, or local noise ordinances. 

37 The EPA has defined a goal of 55 dB(A) for average day-night sound levels in outdoor spaces 

38 (EPA 1974). OSHA standards prescribe the maximum noise levels that employees can be 

39 exposed to within a facility. For an 8-hour work period, sound levels must remain below 

40 90dB(A) or noise abatement measures must be taken, in order to comply with OSHA [29 CFR 
 3-85 

1 1910.95(b)(2)]. HUD guidelines are that noise levels at 65 dB(A) or below are acceptable in a 

2 residential setting in normal situations. 

3 3.11.2 Noise Receptors in the Vicinity of the Proposed Facility 

4 The determination of noise impacts is based on the relationship between the ambient noise 

5 levels and the established noise abatement criteria for the project area. Noise sensitive areas 

6 are created to represent common noise environments within the same activity category, and are 

7 represented by receptors, which represent a discrete or representative location within the noise 

8 sensitive area. Activity categories include land uses such as residences, hotels, motels, active 

9 sport areas, schools, places of worship, hospitals, parks and others. No noise sensitive areas 

10 are within 10 km (6 mi) of the site, based on a review of aerial photographs. 

11 The nearest commercial facilities are Xcel Energy’s Cunningham Generating Station, 

12 approximately 1.6 km (1 mi) west of the proposed site, Xcel Energy’s Maddox Generating 

13 Station approximately 3.7 km (2.3 mi) east of the proposed site, and the Colorado Energy 

14 Station approximately 2.4 km (1.5 mi) northeast of the proposed site. The nearest residence is 

15 approximately 2.6 km (1.6 mi) northwest of the site. No recreational facilities are within 10 km 

16 (6 mi) of the proposed site. 

17 3.11.3 Noise in the Vicinity of the Proposed Facility 

18 Noise sources in the vicinity of the site include ambient noise from the natural setting, highway 

19 noise from NM 483, and occasional noise associated with the overhead and underground 

20 utilities. The noise from the proposed facility would be associated with construction and 

21 operation activities and associated employee traffic. During operations, intermittent noise could 

22 be expected from delivery/disposal of the depleted uranium cylinders and other materials, 

23 commuting workers’ vehicles, and operating equipment such as forklifts. Noise levels near the 

24 closed-loop cooling towers could be relatively high, but otherwise, most noise sources would be 

25 within buildings and would not be audible outside. Baseline ambient noise levels are the basis 

26 for comparison with predicted noise levels from construction and operation. It is typical in this 

27 type of topography and setting for background ambient noise levels to be between 50 and 

28 60 dB(A). 

29 Noise levels at uranium deconversion facilities in Paducah, KY and Piketon, OH would be 

30 comparable. DOE reported estimated or actual noise levels for those facilities (during 

31 operation) to range from 40 to 46 dB(A) at the closest receptors, which are residences 

32 approximately 1.6 km (1 m) from the proposed facility; similar to the distance to sensitive 

33 receptors at the proposed site (DOE, 2004a; DOE 2004b). 

34 3.12 Public and Occupational Health 

35 This section describes the natural and manmade sources of radiation and chemicals and the 

36 levels of exposure that may occur in the vicinity of the proposed IIFP facility. 

37 3.12.1 Background Radiological Exposure 

38 Figure 3-27 depicts the major sources of background radiation in the United States. As shown 

39 on Figure 3-27, humans are exposed to ionizing radiation from both natural and manmade 

40 sources. In the United States, each source contributes on average approximately one-half of an 

41 individual’s total annual radiation dose. The total annual exposure to individuals from both 
 3-86 

1 natural and manmade sources of radioactivity is approximately 6.2 millisieverts (620 millirem) 

2 (NCRP, 2009). 

3 A major proportion of natural radiation comes from naturally occurring airborne sources such as 

4 radon and thoron (an isotope of radon). The proposed IIFP site is in an area characterized by 

5 radon concentrations of 2 to 4 picocuries per liter (pCi/L) and is defined as of moderate radon 

6 potential. Moderate radon potential indicates that one-third to one-half of the structures have 

7 more than 0.148 becquerel per liter (Bq/L) or 4 pCi/L of indoor radon. In May 2004, direct 

8 background radiation was measured by the NMED Radiation Control Bureau to be 8 to 10 

9 microrad per hour, which corresponds to 0.70 to 0.88 millisieverts (mSv) (70 to 88 millirem 

10 [mrem]) per year. The measured range falls within the average annual direct background 

11 radiation for the United States (NRC, 2005). Additionally cosmic radiation, which primarily 

12 consists of positively charged ions from protons to larger nuclei from sources outside our solar 

13 system, is continuously penetrating the earth’s atmosphere, adding to the overall amount of 

14 natural background exposure each individual receives. As shown on Figure 3-27, the total 

15 contribution from natural background radiation to each individual is approximately 3.1 mSv 

16 (310 mrem) (NCRP, 2009). 

17 Manmade sources include x-rays for medical purposes and consumer products such as smoke 

18 detectors. The National Council on Radiation Protection and Measurements (NCRP) released a 

19 report, Ionizing Radiation Exposure of the Population of the United States, (NCRP Report No. 

20 160; NCRP 2009) in 2009 that updated the findings of the previously issued NCRP Report No. 

21 93 (NCRP, 1987). The 2009 NCRP report found significant increases in radiation exposures 

22 related to medical procedures and treatments. The approximate doses to individuals for 

23 medical procedures such as x-rays comprise approximately 48 percent of the total dose 

24 received by individuals living in the United States (NCRP, 2009). Natural sources include 

25 cosmic sources, radionuclides within a person’s body, radionuclides in soils, and radon and 

26 thoron inhalation. 

27 DOE established radiological monitoring programs in southeastern New Mexico prior to the 

28 Waste Isolation Pilot Plant project to determine the level of background radiation. DOE 

29 estimated an annual dose in southeastern New Mexico of approximately 0.65 mSv (65 millirem) 

30 from atmospheric particulate matter, ambient radiation, soil, surface water and sediment, 

31 groundwater, and biota (NRC, 2005). These doses are within expected ranges and do not 

32 indicate any unexpected environmental concentrations in the area. Based on natural and 

33 manmade sources, residents living near the proposed IIFP facility could be expected to receive, 

34 on average, an annual dose of approximately 6.2 mSv (620 millirem). 

35 3.12.2 Background Chemical Characteristics 

36 The 16-ha (40-ac) area that would contain the proposed facility is undeveloped land. There is 

37 no known past activity on this land that would make its background chemical characteristics 

38 different than other undeveloped land. No site-specific chemical data are available. 

39 
 3-87 

1 Figure 3-27. Major Sources and Levels In The Vicinity of the Proposed FEP/DUP 

2 Background Radiation Exposure 

3 

4 Source: data are from NCRP, 2009. Data for this table have been used with permission of the National Council on 

5 Radiation Protection and Measurements, (http://NCRPpublications.org).

6 

7 3.13 References 

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5 Radiation Exposure of the Population of the United States. NCRP Report No. 93. 

6 September 1, 1987. 

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9 MD. March 3, 2009. 

10 (Nicholson and Clebsch, 1961) Nicholson, A. and A. Clebsch. 1961. Geology and Ground11 Water Conditions in Southern Lea County, New Mexico. New Mexico Bureau of Mines and 

12 Mineral Resources Ground-Water Report 6. ADAMS Accession No. ML103080877. 

13 (NMBGMR, 2003) New Mexico Bureau of Geology and Mineral Resources. 2003. Geologic 

14 Map of New Mexico. ADAMS Accession No. ML103080881. 

15 (NMBGMR, 2010) New Mexico Bureau of Geology and Mineral Resources, 2010. 

16 Physiographic Map of New Mexico. Available at http://geoinfo.nmt.edu/tour/. Accessed March 

17 7, 2011. ADAMS Accession No. ML112710476. 

18 (NMDOT, 2009) New Mexico Department of Transportation. Consolidated Highway Database 

19 (CHDB). Website no longer accessible. Accessed April 10, 2009. ADAMS Accession No. 

20 ML112860287. 

21 (NMED, 2010a) New Mexico Environment Department. 2010. Inventory of New Mexico 

22 Greenhouse Gas Emissions: 2000 – 2007. Prepared by the New Mexico Environment 

23 Department. March 15, 2010. Available at http://www.nmenv.state.nm.us/cc/documents/ 

24 GHGInventoryUpdate3_15_10.pdf. Accessed March 11, 2011. ADAMS Accession No. 

25 ML112710489. 

26 (NMED, 2010b) New Mexico Environment Department. 2010. “RE: FOIA Request.” Personal 

27 Communication between M. Huber (New Mexico Environment Department) and N. Hill (TtNUS). 

28 September 22, 2010. ADAMS Accession No. ML112850086. 

29 (NMED, 2010c) New Mexico Environment Department, Ground Water Quality Bureau. 2010. 

30 Ground Water Regulated Facilities, List of Current Discharge Permits, updated 07/29/2010. 

31 Available at http://www.nmenv.state.nm.us/gwb/NMED-GWQB-Permits.htm. Accessed August 

32 31, 2010. ADAMS Accession No. ML112710484. 

33 (NMEMNRD, 2010a) New Mexico Energy, Minerals, and Natural Resources Department. 2009 

34 Annual Report. Available at http://www.emnrd.state.nm.us/main/documents/EMNRD2009 

35 AnnualReportWeb.pdf. Accessed July 28, 2010. ADAMS Accession No. ML103080893. 

36 (NMEMNRD, 2010b) New Mexico Energy, Minerals, and Natural Resources Department. 2010. 

37 New Mexico Oil & Gas Wells. Available at http://mapserve.nmt.edu/Website/ 

38 NMOG/viewer.htm. Accessed August 12, 2010. 

39 (NMGF, 2008a) New Mexico Department of Game and Fish. 2008. “2007-2008 Pronghorn 

40 Antelope Hunter Harvest Report.” New Mexico Dept. of Game and Fish, Santa Fe, NM. 
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1 Available at http://www.wildlife.state.nm.us/recreation/hunting/harvest/documents/07-

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5 Biology, Distribution, and Management Recommendations.” New Mexico Dept. of Game and 

6 Fish, Santa Fe, NM. Available on line at http://www.wildlife.state.nm.us/publications/documents/ 

7 QuailHabitat.pdf. Accessed August 17, 2010. ADAMS Accession No. ML103090080. 

8 (NMGF, 2009) New Mexico Department of Game and Fish. 2009. “New Mexico Pronghorn 

9 Management.” Presentation to the New Mexico State Game Commission. Available at 

10 http://www.wildlife.state.nm.us/commission/presentations/documents/PronghornManagement.p

11 df. Accessed August 17, 2010. ADAMS Accession No. ML103090060 

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14 recreation/hunting/harvest/documents/2009-2010_ DeerHarvestReport.pdf. Accessed October 

15 14, 2010. ADAMS Accession No. ML103090088. 

16 (NMGF, 2010b) New Mexico Department of Game and Fish. 2010. Biota Information System 

17 of New Mexico Database Query for Lea County. Available at http://www.bison18 m.org/reports.aspx?rtype=13&category=&county='025',&gapveg=&habitat=&landuse=&otherdist

19 =&statenm=&status='101','102','105','106','107','112','201','202','215'. Accessed August 17, 

20 2010. ADAMS Accession No. ML103090102. 

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22 of New Mexico.” Available at http://www.bison-m.org/speciesbooklet.aspx. Accessed October 

23 14, 2010. ADAMS Accession No. ML103090099. 

24 (NMGF, Undated 1) New Mexico Department of Game and Fish. Undated. Green Meadows 

25 Lake NM State Wildlife Area. Available at http://www.wildlife.state.nm.us/conservation/ 

26 wildlife_management_areas/documents/GreenMeadowLk.pdf. Accessed August 9, 2010. 

27 ADAMS Accession No. ML103090353. 

28 (NMGF, Undated 2) New Mexico Department of Game and Fish. Undated. Prairie Chicken 

29 Wildlife Areas. Available at http://www.wildlife.state.nm.us/recreation/gain/documents/ 

30 maps/PCAs.pdf. Accessed August 13, 2010. ADAMS Accession No. ML103090360. 

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32 New Mexico Historic Preservation: A Plan for 2002-2006. Santa Fe, NM. Available at 

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34 ADAMS Accession No. ML103080080. 

35 (NMHPD 2005) New Mexico Historic Preservation Division, Department of Cultural Affairs. 

36 August 15, 2005. New Mexico Register, Volume XVI, Number 15. Title 4, Cultural Resources; 

37 Chapter 10, Cultural Properties and Historic Preservation; Part 15, Standards for Survey and 

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12 Underground Water Basin Guidelines for Review of Water Right Applications. Adopted May 25, 

13 2009. Accessed July 29, 2010. ADAMS Accession No. ML103080986. 

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22 (NMT, 2010) New Mexico Tech Institute of Mining and Technology. 2010. New Mexico Oil and 

23 Gas. Available at http:// mapserve.nmt.edu/Website/NMOG/viewer.htm. Accessed August 12, 

24 2010. ADAMS Accession No. ML112710538. 

25 (NMTRD, 2010a) New Mexico Taxation and Revenue Department. 2010. FYI-350. For Your 

26 Information. Corporate Income Tax and Corporate Franchise Tax. Rev. 7/10. Available at 

27 http://www.tax.newmexico.gov/. Accessed August 31, 2010. ADAMS Accession No. 

28 ML103430069. 

29 (NMTRD, 2010b) New Mexico Taxation and Revenue Department. 2010. Personal Income 

30 Tax. Available at http://www.tax.newmexico.gov/All-Taxes/Pages/Personal-Income-Tax.aspx. 

31 Accessed August 31, 2010. 

32 (NMTRD, 2011) New Mexico Taxation and Revenue Department. 2011. “Gross Receipts Tax.” 

33 Available at http://www.tax.newmexico.gov/All-Taxes/Pages/Gross-Receipts-Tax.aspx. 

34 Accessed March 31, 2011. 

35 (NMWQCC, 2002) New Mexico Water Quality Control Commission. 2002. “Water Quality and 

36 Water Pollution in New Mexico.” A report prepared for submission to the Congress of the 

37 United States by the State of New Mexico pursuant to Section 305(b) of the Federal Clean 

38 Water Act. Santa Fe. NMED/SWQ-02/1. Available at http://www.nmenv.state.nm.us/ 

39 swqb/305b/2002/2002_305b_Report-Introduction.pdf. Accessed October 11, 2011. 
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1 (NPS, Undated) National Park Service, U. S. Department of the Interior. Undated. “Indian 

2 Reservations in the Continental United States,” Available at http://www.nps.gov/. Accessed 

3 September 2, 2010. ADAMS Accession No. ML103430075. 

4 (NRC, 2003) U.S. Nuclear Regulatory Commission. 2003. Environmental Review Guidance for 

5 Licensing Actions Associated with NMSS Programs. Final Report. NUREG-1748. August 

6 2003. Division of Waste Management, Washington, D.C. ADAMS Accession No. ML 

7 ML032450279. 

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9 the Proposed National Enrichment Facility in Lea County, New Mexico. Final Report. NUREG 

10 1790. June 2005. ADAMS Accession No’s. ML051730238 (v1) and ML051730292 (v2). 

11 (NRCS, 2010) U.S. Department of Agriculture, Natural Resource Conservation Service. 2010. 

12 Custom Soil Resource Report for Lea County, New Mexico. August 16, 2010. ADAMS 

13 Accession No. ML103080906. 

14 (Ocotillo Park Golf Course, 2010) Ocotillo Park Golf Course. 2010. Ocotillo Park website, 

15 Directions. Available at http://home.valornet.com/lyle/location.htm. Accessed November 11, 

16 2010. ADAMS Accession No. ML112710544. 

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18 and J.M. Baker. 2001. Mines, Mills and Quarries in New Mexico. Mining and Minerals Division, 

19 New Mexico Energy, Minerals, and Natural Resources Department and New Mexico Bureau of 

20 Geology and Mineral Resources New Mexico Institute of Mining and Technology. ADAMS 

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23 Limits of Place: A Historic Resource Study of Carlsbad Caverns and Guadalupe Mountains 

24 National Parks and the Surrounding Areas. Department of the Interior, National Park Service, 

25 Washington, DC. 1998. ADAMS Accession No. ML103080082. 

26 (Sanford, et. al., 2002) Sanford, A.R., K. Lin, I. Tsai, I., and L.H. Jaksha. 2002. Earthquake 

27 Catalogs for New Mexico and Bordering Areas: 1969-1998. New Mexico Bureau of Geology 

28 and Mineral Resources, Circular 210. 

29 (Sanford, et. al., 2006) Sanford, A., T. Mayeau, J. Schlue, R. Aster, and L. Jaksha. 2006. 

30 Earthquake Catalogs for New Mexico and Bordering Area II: 1999-2004. November 2006. In 

31 New Mexico Geology, Volume 28, Number 4. 

32 (Scholle, 2000) Scholle, P. 2000. An Introduction and Virtual Geologic Field Trip to the 

33 Permian Reef Complex, Guadalupe and Delaware Mountains, New Mexico-West Texas. 

34 Available at http://geoinfo.nmt.edu/staff/scholle/guadalupe.html. Accessed July 27, 2010. 

35 (SORA, 2011) SORA. 2011. Lesser Prairie-Chicken Survey on the International Isotope 

36 Flourine Products Project Site-2011. Prepared for International Isotopes, Inc., May 24, 2011. 

37 ADAMS Accession No. ML112720317. 

38 (Stephens & Assoc., 2009) Stephens & Associates, Inc. 2009. Preliminary 40-Year Water 

39 Plan, City of Hobbs, New Mexico. October 30, 2009. Prepared for City of Hobbs, New Mexico. 

40 ADAMS Accession No. ML103080960. 
 3-99 

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2 Little, Brown, and Company. Boston. 

3 (Sublett and Peery, 2009) L. Sublett and R. Peery. 2009. 40-Year Development Plan, Lea 

4 County, New Mexico. John Shomaker & Associate, Inc. July 2, 2009. ADAMS Accession No. 

5 ML112710546. 

6 (Tillery, 2008) Tillery, A., 2008. Current (2004 – 2007) Conditions and Changes in 

7 Groundwater Levels from Predevelopment to 2007, Southern High Plain Aquifer, Southeast 

8 New Mexico-Lea County Underground Water Basin. U.S. Geological Survey Scientific 

9 Investigations Map 3044. Available at http://pubs.usgs.gov/sim/3044. Accessed July 28, 2010. 

10 ADAMS Accession No. ML103080935. 

11 (TPWD, 2007) Texas Parks and Wildlife Department. 2007. Migratory Flyways of North 

12 America: Central Flyway. Available at http://www.tpwd.state.tx.us/huntwild/wild/birding/ 

13 migration/flyways/central/. Accessed August 16, 2010. 

14 (USACE, 2011) U.S. Army Corps of Engineers. 2011. Approved Jurisdictional Determination 

15 Form. SPA-2011-00030-LCO. 2011. ADAMS Accession No. ML112710549. 

16 (USCB, 2000a) U. S. Census Bureau. 2000. Summary File 1 for New Mexico: Census 2000. 

17 Available at http://www2.census.gov/census_2000/datasets/Summary_File_1/New_Mexico/. 

18 Accessed July 23, 2010. ADAMS Accession No. ML112710551. 

19 (USCB, 2000b) U. S. Census Bureau. 2000. Summary File 1 for Texas: Census 2000. 

20 Available at http://www2.census.gov/census_2000/datasets/Summary_File_1/Texas/. 

21 Accessed July 23, 2010. ADAMS Accession No. ML112710551. 

22 (USCB, 2000c) U. S. Census Bureau. 2000. Summary File 3 for New Mexico: Census 2000. 

23 Available at http://www2.census.gov/census_2000/datasets/Summary_File_3/New_Mexico/. 

24 Accessed July 23, 2010. ADAMS Accession No. ML112710554. 

25 (USCB, 2000d) U. S. Census Bureau. 2000. Summary File 3 for Texas: Census 2000. 

26 Available at http://www2.census.gov/census_2000/datasets/Summary_File_1/Texas/. 

27 Accessed July 23, 2010. ADAMS Accession No. ML112710554. 

28 (USCB, 2000e) U. S. Census Bureau. 2000. P92. Poverty Status in 1999 of Households by 

29 Household Type by Age of Householder. Detailed Tables. Census 2000 Summary File 3 (SF 

30 3) Sample Data. Available at http://factfinder.census.gov/. Accessed July 26, 2010. 

31 (USCB, 2000f) U. S. Census Bureau. 2000. P3. Race and P4. Hispanic or Latino, and Not 

32 Hispanic or Latino by Race (Total Population). Detailed Tables. Census 2000 Summary File 1 

33 (SF 1) 100-Percent Data. Available at http://factfinder.census.gov/. Accessed September 7, 

34 2010. 

35 (USCB, 2010a) U. S. Census Bureau. 2010. State and County Quick Facts, “Lea County and 

36 Eddy County New Mexico.” Revised August 16. Available at http://quickfacts.census.gov/. 

37 Accessed September 21, 2010. ADAMS Accession No. ML103430121. 

38 (USCB, 2010b) U. S. Census Bureau. 2010. American Fact Finder, “Fact Sheet, Lea County 

39 New Mexico, Eddy County New Mexico, Hobbs New Mexico, and Carlsbad New Mexico,” 
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2 ADAMS Accession No. ML103430104. 

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4 Annual Estimates of the Resident Population for Counties of New Mexico: April 1, 2000 to July 

5 1, 2009.” Available at http://www.census.gov/. Accessed August 26, 2010. ADAMS Accession 

6 No. ML 103430109. 

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8 Annual Estimates of the Resident Population for Incorporated Places of New Mexico: April 1, 

9 2000 to July 1, 2009.” Available at http://www.census.gov/. Accessed August 26, 2010. 

10 ADAMS Accession No. ML 103430116. 

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12 American Community Survey 3-Yar Estimates.” Available at http://factfinder.census.gov/servlet/ 

13 ADPTable?_bm=y&-geo_id=05000US35025&-qr_no. Accessed August 29, 2010. ADAMS 

14 Accession No. ML103430131. 

15 (USCB, 2010f) U. S. Census Bureau. 2010. State and County Quick Facts, “New Mexico and 

16 Lea County, New Mexico,” Revised August 16. Available at http://quickfacts.census.gov/. 

17 Accessed September 21, 2010. ADAMS Accession No. ML103430126. 

18 (USDA, 2004) U. S. Department of Agriculture. 2004. Assessment of Grassland Ecosystem 

19 Conditions in the Southwestern United States. Volume 1. Gen. Tech. Rep. RMRS-GTR-135-

20 vol. 1. Fort Collins, CO. Available at http://www.fs.fed.us/rm/pubs/rmrs_gtr135_1.pdf’. 

21 Accessed on July 27, 2010. ADAMS Accession No. ML103090363. 

22 (USDA, 2007) U.S. Department of Agriculture. 2007. 2007 Census of Agriculture. Table 7: 

23 Hired Farm Labor. Available at http://www.agcensus.usda.gov/. Accessed August 30, 2010. 

24 ADAMS Accession No. ML103430132. 

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26 Available at http://www.usfa.dhs.gov/. Accessed September 21, 2010. ADAMS Accession No. 

27 ML103430147. 

28 (USFWS, 2008) United States Fish and Wildlife Service. 2008. Black-footed Ferret (Mustela 

29 nigripes) 5-year Status Review: Summary and Evaluation. South Dakota Field Office, Pierre, 

30 South Dakota. Available at http://www.fws.gov/ecos/ajax/docs/five_year_review/doc2364.pdf. 

31 Accessed October 24, 2011. ADAMS Accession No. ML112710563. 

32 (USFWS, 2010a) United States Fish and Wildlife Service. 2010. FWS Critical Habitat for 

33 Threatened and Endangered Species Mapper. Available at http://criticalhabitat.fws.gov/crithab/. 

34 Accessed January 19, 2011. ADAMS Accession No. ML112710570. 

35 (USFWS, 2010b) United States Fish and Wildlife Service. 2010. New Mexico Ecological 

36 Services Field Office, “Listed and Sensitive Species in Lea County.” New Mexico Ecological 

37 Service Field Office. Available at http://www.fws.gov/southwest/es/NewMexico/ 

38 SBC_view.cfm?spcnty=Lea. Accessed on August 9, 2010. ADAMS Accession No. 

39 ML103090370. 
 3-101 

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4 Mexico. August, 10, 2010. ADAMS Accession No. ML102370576. 

5 (USFWS, 2010d) United States Fish and Wildlife Service. 2010. Endangered and Threatened 

6 Wildlife and Plants; Endangered Status for Dunes Sagebrush Lizard, 75 FR 239, pages 77801 – 

7 77817. December 14, 2010. ADAMS Accession No. ML112710578. 

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9 Database. Available at http://tin.er.usgs.gov/mrds/find-mrds.php. Accessed August 11, 2010. 

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12 Animal-Habitat Models for the Southwestern United States. Version 1.0, 200. Center for 

13 Applied Spatial Ecology, New Mexico Cooperative Fish and Wildlife Research Unit, New Mexico 

14 State University. Available at http://fws-nmcfwru.nmsu.edu/swregap/habitatreview/ Review.asp. 

15 Accessed on October 15, 2010. ADAMS Accession No. ML103090472. 

16 (USGS, 2010a) United States Geological Survey. National Water-Quality Assessment 

17 (NAWQA) Program. High Plains Regional Ground Water (HPGW) Study. Available at 

18 http://co.water.usgs.gov/nawqa/hpgw/HPGW_home.html. Accessed August 15, 2010. ADAMS 

19 Accession No. ML103080991. 

20 (USGS, 2010b) U.S. Geological Survey. National Biological Information Infrastructure, Gap 

21 Analysis Program (GAP). February 2010. National Land Cover, Version 1. 2010. Available at 

22 http://www.nbii.gov/portal/server.pt/community/maps_and_data/1850. Accessed on October 15, 

23 2010. ADAMS Accession No. ML103090471. 

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25 Basin Oil Production and Reserves. Available at http://ceed.utpb.edu/energy26 resources/petroleum-library/permian-basin-statistics/graphs-and-data-on-permian-basin-oil27 production-and-reserves/. Accessed August 17, 2010. ADAMS Accession No. ML103080937. 

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29 Hobbs New Mexico”. Available at http://wrcc.dri.edu/narratives/NEWMEXICO.htm. Accessed 

30 August 18 2010. ADAMS Accession No. ML103080182. 

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32 Mexico Institute of Mining and Technology, New Mexico Center for Energy Policy. ADAMS 

33 Accession No. ML103080942. 

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37 ADAMS Accession No. ML103080947. 

 4-1 

1 4.0 ENVIRONMENTAL IMPACTS 

2 This chapter describes the potential environmental impacts associated with the construction, 

3 operation, and decommissioning of the proposed IIFP facility. Section 4.1 addresses both 

4 construction and operations impacts from the proposed action. Plant decommissioning at the 

5 termination of the license is included as part of the proposed action. Cumulative impacts of the 

6 proposed action and past, present, and reasonably foreseeable future actions are presented in 

7 Section 4.2. The no-action alternative is discussed in Section 4.3. 

8 4.1 Proposed Action 

9 As defined in Chapter 2 of this draft EIS, the proposed action is to construct, operate, and 

10 decommission a chemical plant for the deconversion of commercially generated DUF6

11 inventories into depleted uranium oxide and other deconversion products. 

12 The impacts discussions are organized by the subject areas described in Chapter 3, 

13 “Description of the Affected Environment.” NRC staff significance criteria, SMALL, 

14 MODERATE, and LARGE, are used throughout the analyses. These are defined as follows 

15 (NRC, 2003): 

16 SMALL: The environmental effects would not be detectable or are so minor that they would 

17 neither destabilize, nor noticeably alter any, important attribute of the resource. 

18 MODERATE: The environmental effects would be sufficient to noticeably alter, but not 

19 destabilize, important attributes of the resource. 

20 LARGE: The environmental effects would be clearly noticeable and are sufficient to destabilize 

21 important attributes of the resource. 

22 Section 4.1.1 addresses environmental impacts of construction and Section 4.1.2 addresses 

23 environmental impacts of operations. 

24 4.1.1 Environmental Impacts of Construction 

25 The impacts of construction on each of the major resource areas described in Chapter 3 are 

26 presented in this Section. Impacts of preconstruction activities (defined and identified in 

27 Chapter 2) are evaluated as cumulative impacts in Section 4.2. 

28 4.1.1.1 Land Use 

29 Impacts on land use result from commitment of the land for the proposed use and therefore, its 

30 potential exclusion from other possible uses. Land use impacts occur when the presence of a 

31 project would limit possible future land uses near the proposed project. For example, land use 

32 impacts could occur if the project restricts future access to mineral resources. 

33 The current land uses on the proposed 259-ha (640-ac) site are cattle grazing, and access to 

34 and maintenance of utility rights-of-way and monitoring wells. The proposed site is not subject 

35 to local or county zoning, land use planning, or associated review process requirements, and 

36 there are no potential conflicts of land use plans, policies, or controls (Appendix A). The 

37 conversion of 16 ha (40 ac) of the 259-ha (640-ac) site from its current land use to the 
 4-2 

1 proposed facility without disturbing the remaining 240 ha (600 ac) would not conflict with any 

2 existing Federal, State, local, or Tribal land uses or restrict current or planned mineral resources 

3 exploitation (Appendix A). 

4 Construction of the proposed IIFP facility would modify the current land use by restricting cattle 

5 grazing on the entire 259-ha (640-ac) site. Currently, approximately 93 percent of land in Lea 

6 County is used as range land for grazing (approximately 1.0-million ha [2.6-million ac]). 

7 Restricting grazing on the 259-ha (640-ac) site would result in a loss of 0.02 percent of the land 

8 available for grazing. The proposed facility footprint was selected by IIFP to avoid, to the extent 

9 possible, existing utility rights-of-way so that the change in land use would not limit access to or 

10 maintenance of the rights-of-way. In addition, it is not likely that any of Xcel Energy’s 

11 Cunningham Station’s monitoring wells (CU-6, CU-8, and CU-9) in Section 27 (the proposed 

12 IIFP site) would be affected by the construction of the facility or the associated infrastructure 

13 such as the access road. NRC staff expects the remainder of the proposed IIFP site 

14 (Section 27) to be left in its present condition, largely undeveloped for the duration of the 

15 facility’s operation and decommissioning. 

16 Consequently, the NRC staff finds that the impacts to land use from the construction of the 

17 facility within the 259-ha (640-ac) site would be SMALL, due to the abundance of other nearby 

18 grazing land and the ability to continue to access utility rights-of-way. 

19 4.1.1.2 Historic and Cultural Resources 

20 This section describes the potential environmental impacts on historic and cultural resources 

21 resulting from construction of the proposed IIFP facility. As Chapter 3 states, historic and 

22 cultural resources include archaeological sites, historic structures, and places of cultural 

23 importance to groups for maintaining their heritage. Cultural resources are nonrenewable; that 

24 is, once altered, the information contained in cultural resources cannot be recovered. NRC staff 

25 identified separate Areas of Potential Effect (APEs) for archaeology and architecture; and for 

26 construction versus operations. For construction impacts, the APE for archaeology is 

27 considered to include the 16-ha (40-ac) IIFP facility, approach road, and parking lot where 

28 disturbance would occur. For construction impacts, the APE for historic architectural resources, 

29 would include the IIFP facility (limits of disturbance), and any areas where noise or construction 

30 activity would be heard or visible. 

31 NRC staff identified no historic properties, districts, resources or significant culturally important 

32 or archaeological sites within the cultural resources APE during files research at the New 

33 Mexico State Historic Preservation Office (NM SHPO), and tribal consultation. The field survey 

34 conducted by IIFP’s archaeological consultant also identified no significant cultural resources 

35 although it found three isolated artifact occurrences – a brown chert San Jose projectile point 

36 fragment, a gray quartzite hammerstone, and three glass vessel fragments. The artifacts were 

37 recorded with the SHPO, but are not National Register-eligible as determined by the 

38 archaeological consultant for the State Land Office. 

39 As discussed in Section 3.3.4, on October 14, 2010, the New Mexico Trust Land Archaeologist 

40 in the office of the State of New Mexico Commissioner of Public Lands recommended a finding 

41 of no effect to historic properties, districts, resources or significant historic/precontact 

42 archaeological sites because the cultural resource survey found no significant cultural resources 

43 in the proposed IIFP site, and no historic properties have been identified within the APE. The 

44 NM SHPO concurred with this determination on October 25, 2010 (Appendix B). 
 4-3 

1 NRC staff also consulted with Native American Tribes which were identified from a list 

2 maintained by the NM SHPO, consistent with the NHPA Section 106. The NRC staff received 

3 three responses (Appendix B). On July 13, 2010, the Ysleta del Sur Pueblo stated that the 

4 Pueblo believes the project will not adversely affect traditional, religious, or culturally significant 

5 sites, but requested consultation should human remains or artifacts regulated by the Native 

6 American Graves Protection and Repatriation Act be discovered. On June 15, 2011, the Tribal 

7 Historic Preservation Officer for the Comanche Tribe noted that he had no comments on the 

8 project. On July 13, 2011, the Shawnee Tribe’s Tribal Historic Preservation Department 

9 concurred that no known historic properties would be impacted by the project, but also 

10 requested consultation if archaeological materials are encountered during construction or 

11 operation of the facility. 

12 Based on the history of the region, its lack of permanent surface water, and the results of 

13 previous investigations, no significant archaeological, cultural, or historic resources are present 

14 on the site. Therefore, the NRC staff finds that impacts to historic properties, districts, 

15 resources or significant historic/precontact archaeological sites during construction would be 

16 SMALL. 

17 4.1.1.3 Visual Resources 

18 As discussed in Section 3.4, the scenic value of the proposed IIFP site is low (“least valued”) 

19 and is further diminished by the presence, within 5 km (3 mi), of four industrial facilities, three of 

20 which are visible from the proposed site. Consequently, the NRC staff concludes that the 

21 impacts to visual resources during construction would be SMALL. 

22 4.1.1.4 Climatology, Meteorology, and Air Quality 

23 4.1.1.4.1 Greenhouse Gases 

24 This section presents an assessment of the effect of construction of the proposed IIFP facility on 

25 the concentration of CO2 and other greenhouse gases in the atmosphere. 

26 During construction, air emissions would come from (1) construction vehicles and equipment, 

27 (2) personal vehicles of the construction workforce, (3) delivery vehicles bringing materials and 

28 equipment to the proposed site, and (4) vehicles transporting construction-related wastes from 

29 the proposed site to area landfills and treatment/disposal facilities. 

30 NRC staff used NONROAD (EPA, 2005) and MOVES (EPA, 2009a) computer models to 

31 calculate the estimated emissions for construction vehicles and equipment at 1,320 metric tons 

32 (1,455 tons) of CO2 equivalent emissions (Table 4-1). During construction, an estimated 

33 140 workers would commute to and from the proposed site with an assumed average (round34 trip) distance of 64 km (40 mi) daily for 250 days per year (IIFP, 2011b). This is based on the 

35 assumption that the workforce would live in the nearby population centers of Hobbs, Lovington, 

36 and Carlsbad, New Mexico. A weighted average of the distance to each population center and 

37 the 2000 population was used to determine average daily trip distance (IIFP, 2011a). Over the 

38 12-month construction period, the workforce commuting distance would be 2,253,082 km 

39 (1,400,000 mi). It was also estimated that over the course of the construction period, there 

40 would be 20 truck deliveries each day each traveling 64 km (40 mi). The EPA MOVES (EPA, 

41 2009a) was used to calculate estimated CO2 equivalents from all anticipated construction traffic 

42 as 790 metric tons (871 tons) (Table 4-2). 
 4-4 

1 Finally, onsite storage and dispensing of fuels during construction would result in minor 

2 greenhouse gas emissions; however, because neither the specific volume nor the chemical 

3 speciation’s of these evaporative losses are known, resulting greenhouse gas emissions have 

4 not been estimated. 

5 Total CO2 emissions expected during the 12-month construction period are 2,110 metric tons 

6 (2,326 tons); 1,320 metric tons (1,455 tons) from construction equipment and 790 metric tons 

7 (871 tons) from workforce commuting and deliveries. Using calendar year 2000 as a reference 

8 point (the latest year for which New Mexico greenhouse gas emission data are available), and 

9 as shown in Table 3-1, total net CO2 emissions for New Mexico for the year 2000 were 

10 62 million metric tons (68 million tons) of CO2 equivalents. For the United States for that same 

11 year, total net CO2 emissions were 5,977 million metric tons (6,588 million tons) (EPA, 2010a). 

12 By comparison, during the 12 months of construction, the proposed IIFP facility CO2 emissions 

13 are projected to be 2,110 metric tons (2,326 tons) or 0.003 percent of New Mexico’s statewide 

14 output and 0.00004 percent of the projected nationwide CO2 emissions for the same period. 

15 Therefore, the NRC staff concludes that impacts from the construction of the proposed IIFP 

16 facility from the emissions of CO2 and other greenhouse gases would be SMALL. 

17 Table 4-1. CO2 Emissions from Construction Equipment 

Activity Annual CO2 Emissions 

(ton) (MT) 

Construction Equipment 1,455 1,320 

18 MT = metric ton 

19 

20 Table 4-2. Emissions from Workforce Commuting and Delivery Activities 

21 During Construction 

Activity 

Total Distances for 12 months Annual CO2 Emissions 

(mi) (km) (ton) (MT) 

Commuting traffic (workforce) 1,400,000 2,300,000 660 599 

Delivery Truck traffic 200,000 320,000 211 191 

Total for workforce commuting 

and deliveries 1,600,000 2,600,000 871 790 

22 MT = metric ton 

23 

24 4.1.1.4.2 Air Quality 

25 Air quality impacts from the operation of construction equipment during facility construction were 

26 evaluated based on the construction schedules and parameters provided by IIFP. 

27 Impacts to ambient air resources would occur from the construction of the proposed IIFP facility. 

28 As discussed in more detail below, the impacts would not be significant. Because the proposed 

29 IIFP site is located in an air quality control region that is designated as attainment with Federal 

30 and state ambient air quality standards, a General Conformity evaluation is not required. 

31 Construction of the proposed project would produce criteria pollutants (i.e., CO, NO2, PM10, 

32 PM2.5, SO2, lead, and volatile organic compounds (VOCs), an ozone precursor) and hazardous 
 4-5 

1 air pollutants (HAPs) emissions from construction equipment, delivery vehicles, commuter 

2 vehicles, and onsite refueling activities. Particulate emissions in the form of fugitive dust from 

3 soil transfers, land grading, and vehicle and equipment travel on unpaved roads would also be 

4 generated. 

5 The NRC staff used emission factors to estimate annual emissions from the construction of the 

6 proposed IIFP facility. Emission factors for highway vehicles (i.e., worker commute vehicles and 

7 delivery vehicles) were determined using the EPA MOVES Model (EPA, 2009a). Emission 

8 factors for non-road vehicles (including construction engines and equipment) were determined 

9 using the EPA NONROAD model (EPA, 2005). Emission factors for all other sources 

10 associated with construction were obtained from the EPA document AP-42, “Compilation of Air 

11 Pollutant Emission Factors” (EPA, 1995a). 

12 Emissions from each type of non-road equipment are a function of equipment-specific factors, 

13 including engine horsepower, load factor, and hours of operation. IIFP estimated that the 

14 construction project would be completed in approximately 12 months based on the assumption 

15 that construction would occur 10-hrs per day, 5 days per week, and would involve conventional 

16 construction equipment (e.g., dozers, graders, excavators, dump trucks, lifts). IIFP compiled a 

17 list of construction equipment that identifies for each month of construction, the quantity and 

18 average monthly hours of operation for each piece of equipment (See Table 4-3). 

19 Emissions from highway vehicles (i.e., worker commute vehicles and delivery vehicles) are a 

20 function of the vehicle-specific factors, including type of vehicle and age, fuel type, and vehicle 

21 miles traveled. The NRC staff used Lea County, New Mexico-specific default values for vehicle 

22 type, age, and fuel type to determine highway vehicle emission factors. IIFP estimated that over 

23 the 12-month construction period, 140 workers would commute to and from the proposed site 

24 an average daily trip distance of 64 km (40 mi) for 250 days each year; and delivery trucks 

25 would make 20 delivery trips per day (at an average round trip distance of 64 km [40 mi]) to 

26 transport materials and equipment and remove wastes (IIFP, 2011a). 

27 Fugitive dust generated during land clearing and soil transfer operations is dependent on a 

28 number of factors including silt and moisture content of the soil, wind speed, and disturbed area. 

29 To estimate fugitive dust emissions, IIFP used the EPA emission factor of 1.2 tons/acre/month 

30 of activity (EPA, 1995a). This emission factor represents total suspended particulates 

31 (i.e., particles less than 30 microns in diameter). IIFP assumed that the emission factor would 

32 drop to 0.3 tons/acre/month after the first month of construction, when the majority of earth 

33 moving activities would be complete. Multiplication factors of 0.15 and 0.075 were used to 

34 adjust the emission factor for PM10 and PM2.5, respectively. IIFP also assumed that water would 

35 be applied to disturbed areas. This would reduce fugitive dust emissions by about 50 percent 

36 (IIFP, 2011a). 

37 Small quantities of VOCs and HAPs emissions would be released from the refueling and onsite 

38 maintenance of construction equipment. Diesel fuel would be stored on site during construction 

39 and would be hand pumped into construction equipment and support vehicles. Annual VOCs 

40 and HAPs fugitive emissions are a function of diesel fuel consumption. 
4-6 

Table 4-3. Construction Equipment and Hours of Operation by Type and Month 1 Equipment Max HP 

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 

No. Hr No. hr No. hr No. hr No. hr No. hr No. hr No. hr No. hr No. hr No. hr No. hr 

Tractor/ backhoe 150 2 160 1 80 1 80 1 80 1 80 1 80 1 80 1 80 1 80 1 80 1 80 1 80 Grader 400 1 160 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Excavator 500 1 160 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Dump Truck 300 2 160 2 160 2 160 1 100 1 100 1 100 1 100 1 100 1 100 1 100 1 100 1 100 Dozer 400 1 160 0 0 0 0 0 0 0 0 1 160 1 160 0 0 0 0 0 0 0 0 0 0 Air Compressor 325 1 80 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 Concrete Pump 125 0 0 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 Crane 175 0 0 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 Fuel Truck 250 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 Water Truck 250 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 Forklifts 200 1 50 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 Flatbed, 2-ton 200 1 80 1 80 1 80 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 Generator 33 0 0 1 80 1 80 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 Welder 50 1 30 2 60 2 60 5 160 5 160 5 160 5 160 3 160 3 160 3 160 3 160 3 160 Source: IIFP, 2011a 2 No. = number 3 

4 
 4-7 

1 The estimated maximum annual pollutant emissions from construction activities are presented 

2 in Table 4-4. Actual construction emissions are expected to be less, because conservative 

3 assumptions used in the modeling of construction activities tend to overestimate impacts. The 

4 applicant’s environmental report described Best Management Practices (BMPs) they would use 

5 to reduce impacts to various resources at the proposed IIFP site, including those to minimize 

6 the impacts of construction activities on air quality. These BMPs are described in Chapter 5, 

7 Mitigation Measures and Commitments. 

8 Table 4-4. Estimated Maximum Annual Emissions from Construction of the IIFP 

9 Facility 

Source 

CO 

metric 

tons 

(tons) 

NO2 

metric 

tons 

(tons) 

PM2.5 

metric 

tons 

(tons) 

PM10 

metric 

tons 

(tons) 

SO2 

metric 

tons 

(tons) 

VOC 

metric 

tons 

(tons) 

HAP 

metric 

tons 

(tons) 

Construction 

Equipment 

4.00 8.55 0.639 0.660 0.268 0.778 ----- 

(4.41) (9.43) (0.705) (0.727) (0.295) (0.858) ----- 

Delivery 

Vehicles 

2.05 0.926 0.0394 0.0476 0.00224 0.174 0.174 

(2.26) (1.02) (0.0434) (0.0524) (0.00247) (0.192) (0.192) 

Personal 

Vehicles 

10.9 1.46 0.0266 0.0494 0.0116 1.03 1.03 

(12.1) (1.61) (0.0293 (0.0545) (0.0128) (1.14) (1.14) 

Fugitive 

Emissions ----- ----- 3.67 7.35 ----- 0.00161 0.0016 

(4.05) (8.10) (0.00177) (0.00177) 

Total 17.7 10.9 4.38 8.11 0.282 1.99 1.21 

18.7 (12.1) (4.83) (8.93) 0.31 (2.19) (1.33) 

10 Source: See Appendix C 

11 CO = carbon monoxide 

12 NO2 = nitrogen dioxide 

13 PM2.5 = particulate matter less than 2.5 microns in diameter 

14 PM10 = particulate matter less than 10 microns in diameter 

15 SO2 – sulfur dioxide 

16 VOC = volatile organic compounds 

17 HAP = hazardous air pollutants 

18 

19 To estimate the impact to local air quality, the NRC staff compared the anticipated criteria 

20 pollutant and VOCs emissions from the proposed IIFP construction activities to baseline 

21 emissions from Lea County, New Mexico. As shown in Table 4-5, emissions from the proposed 

22 construction activities at the IIFP site would represent a very small portion of the annual criteria 

23 pollutant emissions in Lea County. 

24 NRC staff used EPA’s SCREEN3 model (EPA 1995b) to estimate the maximum concentrations 

25 of pollutants at the proposed IIFP site property line that would be associated with construction 

26 activities. As shown in Table 4-6, the estimated incremental increases in ambient background 

27 concentrations due to the proposed construction activities would be above the National NAAQS 

28 for NO2, PM2.5, and PM10 emissions. HAPs and VOCs are not included in Table 4-6 because 

29 there are no regulatory metrics for comparison (HAPs and VOCs emissions are regulated by 

30 source controls and permit requirements). 
 4-8 

1 Table 4-5. Comparison of Maximum Annual Emissions from Construction of the IIFP 

2 Facility to Lea County Baseline Conditions 

Source 

CO 

metric 

tons (tons) 

NO2 

metric 

tons (tons) 

PM2.5

metric 

tons (tons) 

PM10

metric 

tons (tons) 

SO2

metric 

tons (tons) 

VOC 

metric 

tons (tons) 

Site Construction 17.0 

(18.70) 

10.90 

(12.10) 

4.38 

(4.83) 

8.11 

(8.93) 

0.28 

(0.31) 

1.99 

(2.19) 

Lea County 

Baseline (a) 

21,244 

(23,417) 

27,119 

(29,894) 

2,892 

(3,188) 

25,048 

(27,611) 

7,334 

(8,084) 

4,436 

(4,890) 

Net Increase 

over Baseline 

0.080% 0.040% 0.151% 0.032% 0.004% 0.045% 

3 Source: EPA, 2009b 

4 Source: See Appendix C 

5 CO = carbon monoxide 

6 NO2 = nitrogen dioxide 

7 PM2.5 = particulate matter less than 2.5 microns in diameter 

8 PM10 = particulate matter less than 10 microns in diameter 

9 SO2 – sulfur dioxide 

10 VOC = volatile organic compounds 

11 HAP = hazardous air pollutants 

12 

13 Table 4-6. Comparison of Predicted Maximum Downwind Concentrations Due to 

14 Construction Activities to NAAQS 

Pollutant 

Averaging 

Time 

NAAQS 

μg/m3

Incremental 

Concentration 

Increase 

μg/m3

 

Incremental 

Concentration Increase 

as Percentage of 

NAAQS 

CO 1-hr 

8-hr 

10,000 

40,000 

116 

81.3 

1.2% 

0.20% 

NO2 1-hr 

Annual 

100 

188 

269 

26.9 

269% 

14% 

PM2.5 24-hr 

Annual 

35 

15 

142 

35.5 

406% 

237% 

PM10 24-hr 150 277 185% 

SO2 1-hr 

3-hr 

200 

1,300 

8.5 

7.7 

4.3% 

0.6% 

15 Source: See Appendix C 

16 

17 As discussed above, the estimated emissions during construction of the proposed IIFP facility 

18 represent a very small fraction of the current emissions in Lea County. Because conservative 

19 assumptions that tend to overestimate impacts were used to produce these estimates, actual 

20 emissions from the construction activities are expected to be lower. Pollutant emissions from 

21 construction activities have the potential to change the existing ambient air quality in the vicinity 

22 of the proposed IIFP facility. Overall, the construction impacts would be localized and short23 term. Therefore, the NRC staff concludes that the air quality impacts resulting from the 

24 construction of the proposed IIFP facility would be MODERATE for NO2, PM2.5, and PM10

25 emissions and SMALL for CO, and SO2 emissions. BMPs identified by the applicant to use 

26 during construction to reduce impacts to air quality are described in Chapter 5, Mitigation 
 4-9 

1 Measures and Commitments. The NRC staff finds that the BMPs committed to by IIFP for the 

2 proposed facility would be sufficient to maintain impacts as MODERATE to SMALL. 

3 4.1.1.5 Geology, Minerals, and Soil 

4 Section 3.6 describes the geology, minerals, and soils at the proposed IIFP site. Alluvium 

5 and/or caliche would be removed during site preparation. If the materials are of the appropriate 

6 quality they would be used for roads or facility foundations at the site. The existing caliche pit 

7 described in Section 3.6.3 could be a source of caliche for site roads. Impact to topography and 

8 bedrock would be limited to clearing and excavating areas for facility and road construction. 

9 These impacts would be largely limited to the 16-ha (40-ac) facility, with the exception of the 

10 roadway construction that would extend beyond the facility, through the 259-ha (640-ac) site, to 

11 NM 483. 

12 The proposed IIFP site has been explored for oil and gas and caliche. The site has very limited 

13 leasable, locatable, or marketable mineral resources. Therefore, the proposed IIFP construction 

14 activities would not result in loss of mineral resources. 

15 As discussed in Section 3.6.2, the site is in an area of limited seismic and volcanic activity 

16 (Crone and Wheeler, 2000; Machette et al. 2000; Yarger, 2009), and the statistical probability of 

17 risk of earthquake damage is very low. Because excavation depth is limited to near-surface 

18 geology, construction activities are not expected to cause seismic or fault-related impacts. 

19 Soil erosion due to stormwater runoff and wind erosion must be managed during construction. 

20 As described in Section 3.6.4, the proposed site does not contain any prime farmland; therefore, 

21 prime farmland would not be impacted. During construction, BMPs would be employed to limit 

22 soil loss and mitigate any impacts. These would include: 

23 • Soil stabilization (e.g. temporary and permanent seeding), 

24 • Structural controls (e.g. hay bales and sediment fences), and 

25 • Management practices (e.g. construction sequencing, materials delivery sequencing, 

26 and physical delineation of disturbed areas). 

27 Construction excavation would be limited to near-surface geology at the 16-ha (40-ac) facility, 

28 and would result in minimal loss of mineral resources. BMPs identified in the applicant’s 

29 environmental report would be used to limit soil loss. Therefore, the NRC staff finds that the 

30 BMPs committed to by IIFP would be sufficient to ensure that construction impacts of the 

31 proposed IIFP facility to geology, minerals, and soil would be SMALL. 

32 4.1.1.6 Water Resources 

33 This section discusses the potential impacts of construction of the proposed IIFP facility on 

34 water resources. 

35 4.1.1.6.1 Groundwater 

36 As discussed in Section 3.7.1.2, the site is within the Lea County underground water basin 

37 (UWB). The Ogallala aquifer is the primary water supply source in the Lea County UWB, and is 

38 proposed as the water supply source for the proposed IIFP project. The aquifer is encountered 

39 at a depth of approximately 9.1 m (30 ft) beneath the proposed site (GL Environmental, 2010). 
 4-10 

1 Excavation through the dense caliche at the site could be required for sewer systems, roads, 

2 pads, and building foundations. Excavation depths are not expected to exceed the depth to 

3 groundwater (GL Environmental, 2010; IIFP, 2009a). 

4 4.1.1.6.1.1 Groundwater Use 

5 As discussed in Section 3.7.1.2, all the groundwater wells in the site vicinity obtain water from 

6 the Ogallala aquifer. The closest domestic groundwater supply well is (L-07469) approximately 

7 1.6 km (1 mi) northwest of the proposed site (IIFP, 2011a). The well depth is 48.8 m (160 ft) 

8 and the depth to water is 21.3 m (70 ft) (NMOSE, 2010). 

9 No municipal water line runs near the proposed site. The construction activities for the facility 

10 would require relatively low volumes of water. Up to two groundwater production wells would be 

11 installed in the Ogallala aquifer to supply all the water for the proposed facility. One of these 

12 production wells would be installed on the site by Lea County prior to the property transfer. This 

13 well would be designed to meet the production needs for both proposed Phase 1 and 2 

14 operations. This well would be drilled to a depth estimated to be between 61 to 76.2 m (200 to 

15 250 ft) below ground surface with an estimated pumping capacity of 1,325 L/min (350 gpm). A 

16 second production well may be needed during IIFP operations for emergency preparedness 

17 purposes. This well, if required, would be installed by IIFP during construction. If the second 

18 production well is installed, it would be located to minimize interference with the first production 

19 well (INIS, 2011). All new monitoring and production wells installed at the site would be 

20 installed in accordance with the New Mexico Office of the State Engineer and Lea County Water 

21 Users Association regulations. 

22 IIFP states that during construction, water use is projected to equal 3,600 L/day (960 gpd) on 

23 average, and 12,500 L/day (3,300 gpd) maximum (IIFP, 2011a). Groundwater may be used 

24 during construction for personal use, construction activities, and dust suppression. 

25 Groundwater pumped from the site well would be a consumptive loss because the groundwater 

26 would either be consumed or evaporated. For more information on groundwater appropriations 

27 and use restrictions refer to Section 4.1.2.6.1. 

28 As discussed in Section 3.7.1.2.1, because current pumping is in excess of the Ogallala’s 

29 recharge rate, the aquifer has experienced significant drawdown in the last several decades. In 

30 2009, the New Mexico Office of the State Engineer (NM OSE) prepared guidelines on the 

31 procedures for processing water rights applications filed with the Lea County UWB. The NM 

32 OSE developed administrative guidelines in order to promote the orderly development of water 

33 resources in the Lea County UWB, while meeting statutory obligations regarding existing water 

34 rights, availability of unappropriated water, conservation of water with the State, and public 

35 welfare of the State through a 40-year planning period beginning on January 1, 2005 and 

36 ending on January 1, 2045. 

37 On March 10, 2009, the NM OSE issued an order closing the Lea County UWB to the filing of 

38 groundwater applications (NMOSE, 2009a). In 1999, in order to meet the projected 

39 groundwater demands of Lea County, 138 applications were filed by the Lea County Water 

40 Users Association to appropriate 6,389 ha-m (51,797 ac-ft) per year of groundwater, which was 

41 essentially all the unappropriated groundwater in the Lea County UWB (Leadshill-Herkenhoff 

42 et al., 2000). 

43 A portion of the applications to appropriate groundwater, totaling 4,215.2 ha-m (34,173 ac-ft) per 

44 year, have been assigned to Lea County during (at least) the 40-year planning period to allow 
 4-11 

1 the County to hold the subject water rights unused until the rights can be put to beneficial use at 

2 projects currently under construction, select future projects, and homes and businesses in 

3 unincorporated areas. The proposed IIFP site has been included in Lea County’s 40-Year 

4 Water Development Plan as an area of proposed development where up to 21.6 ha-m 

5 (175 ac-ft) per year of the Lea County’s water rights would be put to beneficial use. The 

6 estimated quantity of additional groundwater that Lea County would need by the end of the 

7 40-yr planning period for all projects that currently exist, are being constructed, or have a high 

8 likelihood of being constructed in the near future is 1,173.5 ha-m (9,514 ac-ft) per year 

9 (Leadshill-Herkenhoff et al., 2000). 

10 Groundwater rights for the facility would be obtained from the Lea County unallocated water 

11 rights under State Engineer Office Water Right File No. L-04719-A for industrial water use. The 

12 proposed facility would obtain a joint Lea County and New Mexico Office of State Engineer 

13 (NM OSE) Water Rights Agreement for 6.2 ha-m (50 ac-ft) per year (far less than the 21.6 ha-m 

14 [175 ac-ft] per year estimation in the Lea County Water Development Plan). The site would use 

15 approximately 0.5 percent of the estimated annual 40-year planning period groundwater 

16 demand of 9,514 ac-ft per year for Lea County, and only 0.15 percent of the 4,215.2 ha-m 

17 (34,173 ac-ft) per year of unappropriated water rights that have been assigned to Lea County. 

18 The proposed site production well(s) could be the sole source of water during construction; or 

19 the applicant could use water from tanker trucks. Groundwater from onsite wells, or tankers 

20 filled from the Hobbs city water system, would be required during Phase 1 construction, mostly 

21 for dust suppression, fill compaction, and concrete formation. Unlike preconstruction, where 

22 water is assumed to be brought in on tanker trucks, IIFP may have operating wells at some 

23 point during construction. This water is not anticipated to be recycled and reused like plant 

24 process water during operations (discussed in Section 4.1.2.6.1), however the volumes required 

25 during construction would be less than a third of the volumes required during operations. 

26 Regardless if water comes from onsite wells or from the Hobbs municipal system via tanker 

27 trucks, the water use is accounted for in, and consistent with, Lea County’s water use plan. 

28 Therefore, the NRC staff finds that groundwater use impacts during construction would be 

29 SMALL. 

30 4.1.1.6.1.2 Groundwater Quality 

31 The Ogallala aquifer beneath the site is unconfined, and is recharged by natural precipitation 

32 that percolates to the groundwater table. As a consequence, any contaminants (e.g., diesel 

33 fuel, hydraulic fluid, antifreeze, or lubricants) spilled during construction and not controlled by 

34 spill control measures could affect the unconfined aquifer, although migration of contaminants 

35 would be slowed by the approximately 9.1-m (30-ft) thick indurated caliche layer that overlies 

36 the aquifer at the site (GL Environmental, 2010). 

37 Any spills of diesel fuel, hydraulic fluid, antifreeze, or lubricants during construction would be 

38 cleaned up quickly in accordance with the proposed facility’s Spill Prevention Control and 

39 Countermeasure Plan, to prevent the contaminant from entering the groundwater. 

40 All construction activities would comply with the site’s National Pollutant Discharge Elimination 

41 System (NPDES) General Permit to discharge stormwater associated with construction and the 

42 associated stormwater pollution prevention plan. Surface water flow from rain events would be 

43 directed to the site’s proposed catch basins. 
 4-12 

1 During construction activities, portable sanitary facilities would be used until a permanent 

2 sanitary waste treatment facility is functional. The waste collected from these temporary 

3 facilities would be disposed of offsite by a licensed sanitary waste disposal contractor. 

4 No process waste effluent will be generated during this construction phase. 

5 Therefore, the NRC staff finds that impacts to groundwater quality due to construction-related 

6 activities would be SMALL. 

7 4.1.1.6.2 Surface Water 

8 As discussed in Section 3.7.2, no permanent surface water, including jurisdictional waters, is 

9 present on the proposed IIFP site. Therefore, the NRC staff finds that impacts to surface water 

10 quality or quantity due to construction-related activities would be SMALL. 

11 4.1.1.7 Ecological Resources 

12 This section discusses the potential impacts of construction of the proposed IIFP facility on 

13 ecological resources. Most of the potential ecological disturbances due to habitat loss from land 

14 clearing of the proposed IIFP site would occur during preconstruction, and thus is evaluated as 

15 a cumulative impact. Other potential ecological disturbances could include: noise and vibrations 

16 from heavy equipment and traffic, fugitive dust, and the presence of construction personnel. 

17 Approximately 16 ha (40 ac) of land would be affected by construction, which represents less 

18 than 10 percent of the total 259 ha (640 ac) site. Leaving a majority of the site undisturbed 

19 would allow mobile resident wildlife within the disturbed areas an opportunity to relocate to the 

20 undisturbed areas. These undisturbed areas are expected to be left undisturbed for the life of 

21 the proposed facility. Some wildlife may suffer stresses or mortality during construction. 

22 Human encounters with some wildlife could increase due to loss of habitat. No construction 

23 facilities or equipment would be 61 m (200 ft) high or taller, so no aviation safety lights will be 

24 required (FAA, 1992). Security lighting will be directed downward, and construction will not 

25 require night shifts so night-migrating and nocturnal animals would not be affected. 

26 As described in Section 3.7.2, there are no wetlands or permanent stream systems, and 

27 therefore no riparian habitat within the facility footprint. 

28 As described in Section 3.8, no Federal or state-listed threatened or endangered species are 

29 likely to be found on the site as their preferred habitats are not found on the site. No unique or 

30 critical habitats occur on the site. No threatened or endangered species are known from the site 

31 or in the vicinity. No commercially or recreationally important species use the habitat at the site 

32 exclusively. 

33 Maintenance practices such as the use of chemical herbicides, roadway maintenance, and 

34 clearing practices could be employed during construction. Land clearing would destroy the 

35 Western Great Plains Shortgrass Prairie and Apacherian-Chihuahuan Mesquite Upland Scrub 

36 vegetation communities within the 16 ha (40 ac) facility footprint. However, neither of these 

37 vegetation communities provides unique habitat in the area and the impacted area of 16 ha 

38 (40 ac) constitutes a small fraction of these vegetation communities in the vicinity of the 

39 proposed IIFP site (see Figure 3-19). Therefore, the NRC staff finds that the loss of 16 ha 

40 (40 acres) of either habitat type would have a SMALL impact on native vegetation in the vicinity 

41 of proposed action. 
 4-13 

1 During construction, the presence of humans, the presence of construction equipment and 

2 associated noise and vibrations, and general construction activities could result in animals 

3 currently using the property, such as birds, foxes and other small mammals, to avoid the 

4 construction area. Many other species, such as rodents, and some reptiles, are small, have 

5 limited mobility, occur in habitats that provide concealment, or spend at least a portion of their 

6 lives underground. During site clearing and grading activities, it is likely that some individuals of 

7 these species will not survive the construction activities. Rodents and larger mammals and 

8 reptiles may be killed along access roads by vehicles moving to and from the site. There are 

9 many square miles of undeveloped land surrounding the IIFP site (i.e., Section 27) which have 

10 native vegetation and habitats suitable for native species. As discussed in Section 3.8.3 the 

11 species of wildlife present or that could be present are typical of those found in the habitat in the 

12 surrounding area. Because the area surrounding the proposed IIFP site is largely undeveloped 

13 (see Section 3.2), there is sufficient suitable habitat in the vicinity of the project to support 

14 displaced animals. Therefore the NRC staff finds that impacts to ecological resources from 

15 construction of the proposed facility would be SMALL. 

16 4.1.1.8 Socioeconomic Resources and Environmental Justice 

17 This section analyzes the potential social and economic (socioeconomic) impacts associated 

18 with construction of the proposed IIFP facility. As discussed in Section 3.9, most socioeconomic 

19 impacts would occur within a two-county area (Lea and Eddy Counties, New Mexico), where the 

20 majority of the construction workforce would live and spend their wages. These two counties 

21 comprise the socioeconomic Region of Interest (ROI) in these analyses which are based on 

22 IIFP’s estimate of a peak of 140 construction workers (IIFP, 2011a). Construction would begin 

23 in 2012 and be completed in 2013. Wage and salary spending would have a small positive 

24 economic benefit in the ROI, and expenditures associated with materials, equipment, and 

25 supplies would produce local and State tax revenue. The migration of workers and their families 

26 into the area would slightly increase the population of the ROI and affect housing availability and 

27 community services such as education, fire protection, law enforcement, medical resources, and 

28 the availability of public utilities. 

29 The major factor influencing socioeconomic impacts of construction is the number of 

30 construction workers who would relocate to the area with their families. An NRC staff study, 

31 Migration and Residential Location of Workers at Nuclear Power Plant Construction Sites 

32 (BMI, 1981) evaluated behaviors and characteristics of construction workers at nuclear power 

33 plant construction sites. It provides a methodology for estimating in-migrating workforce sizes 

34 and residential distribution patterns at nuclear power plant construction sites. There is no 

35 evidence that the fundamental nuclear construction workforce characteristics and behaviors 

36 have changed appreciably since the study’s publication. The proposed IIFP facility is a nuclear 

37 fuel cycle facility, and, as such would require construction methods, quality control, and safety 

38 procedures similar to those used for constructing nuclear power plants. Therefore, the current 

39 analysis assumed that the construction behaviors and characteristics identified in the BMI study 

40 would be a fair representation of the expected IIFP construction workforce, and therefore the 

41 worker migration patterns and family characteristics described in the BMI study remain valid 

42 assumptions. The BMI study indicates the following construction worker characteristics: 

43 • Between 15-35 percent of the construction workforce would migrate into the ROI. 

44 • Approximately 70 percent of in-migrating construction workers are likely to bring families 

45 (this may be an overestimate for a construction job with a duration of one year, however, 

46 to be conservative, the NRC staff maintained this assumption). 
 4-14 

1 • Average family size of a construction worker is 3.25 persons. 

2 • Average number of school-aged children per construction worker family is 0.8. 

3 • Approximately 50 percent of the in-migrating construction workforce will remain in the 

4 ROI following construction. 

5 IIFP anticipates the peak number of construction workers would be 140. In 2008, construction 

6 and mining employment provided more than 28 percent of all non-farm employment in the ROI. 

7 They are two of the largest employment sectors in the ROI. Because of the presence of 

8 workers with construction experience, the NRC staff estimates that 80 percent of the total 

9 construction workforce would already reside within the ROI and 20 percent would migrate into 

10 the ROI. An estimate of 20 percent in-migrants is within the range of the in-migrating 

11 construction workforce identified in the BMI study when there is already an existing, viable 

12 construction workforce within the ROI. Table 4-7 depicts workforce in-migration, family, and 

13 workforce retention characteristics based on the BMI study and the maximum workforce for the 

14 construction of the proposed IIFP facility. These projections are used throughout this analysis. 

15 4.1.1.8.1 Population 

16 As presented in Section 3.9.1.2, the population within the ROI was 112,938 persons in 2009. 

17 Construction of the proposed IIFP facility would directly employ a maximum of 140 people, of 

18 which 80 percent would be ROI residents. The other 20 percent (28 workers) would migrate 

19 into the socioeconomic ROI (Table 4-7). Of the 28 employees that would migrate into the ROI, 

20 70 percent (20 workers) would bring their families (Table 4-7). Eight construction workers would 

21 not bring families. Using an average family size of 3.25 from the BMI study, the total 

22 construction workforce in-migration would result in 72 new residents (Table 4-7) in the two23 county ROI. An increase of 72 residents would result in a 0.06 percent increase in the ROI 

24 population. 

25 4.1.1.8.2 Employment and Income 

26 Workers already residing in the ROI would fill 80 percent of the construction jobs or 112 jobs 

27 (see Table 4-7). These workers represent 0.2 percent of the June 2010 labor force within the 

28 ROI. If all 112 of the jobs were filled by unemployed workers, the unemployment rate in the ROI 

29 would decrease by 0.2 percent. The remaining 28 jobs would be filled by workers migrating into 

30 the ROI (Table 4-7). The in-migrating workers would increase the labor force by 0.05 percent. 

31 The U.S. Department of Commerce Bureau of Economic Analysis (BEA), Economic and 

32 Statistics Division uses an economic model called RIMS II, which incorporates buying and 

33 selling linkages among regional industries and uses a multiplier specific to an industry to 

34 estimate the economic impact within the region. The multiplier is the number of times the final 

35 increase in consumption exceeds the initial dollar spent. In this analysis, the NRC staff uses the 

36 multiplier for the construction industry in the ROI to estimate the number of indirect jobs that 

37 would result from the in-migration associated with the construction of the proposed IIFP facility. 

38 Indirect jobs are often non-technical and non-professional positions in the retail and service 

39 sectors. The 12 indirect jobs that would be created (Table 4-8) would likely be filled by ROI 

40 residents. If all 12 jobs were filled by unemployed workers, those workers would represent 

41 0.3 percent of the unemployed labor force in June 2010. 
 4-15 

1 Table 4-7. Assumptions for Workforce Characterization during Peak Construction 

2 Period 

Workforce characterization 

Peak number of workers on site during construction 1 140 

Workforce migration 

Percent of construction workers migrating into ROI 2 20% 

Total number of construction workers migrating into ROI during construction peak 3 28 

Families 

Percent of construction workers who bring families 2 70% 

Percent of construction workers who do not bring families 3 30% 

Average construction worker family size (worker, spouse, children) 2 3.25 

Number of construction workers who would move into ROI and bring families 20 

Post-construction workforce retention 

Number of construction workers who would move into ROI and would not bring families 8 

Number of construction worker family members who would move into ROI 44 

Total number of workers and family members migrating into ROI (new population in ROI) 72 

School-age children 

Number of school-age children per family 2 0.8 

Number of school-age children in ROI 16 

Percent of in-migrating workers that would leave ROI, post-construction 2 50% 

Number of in-migrating workers that would leave ROI, post-construction 14 

Total number of in-migrating workers and family members that would leave ROI, postconstruction 36 

Number of school-age children of in-migrating workers that would leave ROI, postconstruction 8 

3 Source: 

1 4 IIFP, 2011a 

2 5 BMI, 1981 

3 6 See Appendix D 

7 Note: there are slight variations in the calculations due to rounding, 

8 

9 Table 4-8. Direct and Indirect Employment 

Construction workforce peak (Table 4-7) 140 

Number of construction workers who migrate into ROI (20 percent of 

construction workforce peak) (Table 4-7) 

28 

Employment multiplier for construction in ROI (BEA, 2010) 0.4324 

Indirect jobs resulting from in-migrating construction workers 

(i.e., 28x0.4324=12) 

12 

10 

11 Expenditures for goods and services to support construction activities would occur both inside 

12 and outside the ROI. Approximately $70 million to $94 million in capital costs would be spent 

13 for construction (IIFP, 2009a). Also, construction workers would spend a portion of their 
 4-16 

1 earnings on goods and services within the ROI. Construction worker wages are estimated to 

2 average $32,700 annually (IIFP, 2011a). 

3 The NRC staff finds that due to the size of the available workforce in the ROI, the effect of 

4 construction on employment and income within the ROI would be SMALL and beneficial. 

5 4.1.1.8.3 Taxes 

6 Construction-related activities, purchases, and workforce expenditures would generate several 

7 types of taxes, including individual income taxes, gross receipts taxes, and property taxes. 

8 Increased tax collections are viewed as a benefit to the State of New Mexico, Lea County, the 

9 Hobbs Municipal School District, the New Mexico Junior College, the communities in Lea 

10 County, and other locales where plant-related spending would occur. 

11 Income Taxes 

12 New Mexico imposes a tax on the net income of every resident and nonresident employed or 

13 engaged in business in or from the State or deriving any income from any property or 

14 employment within the State. The rates vary depending upon filing status and income 

15 (Section 3.9.3). Construction wages would be taxed as income and the NRC staff finds that 

16 those tax payments would have a SMALL, beneficial impact. 

17 IIFP would not pay corporate income tax during construction. 

18 Gross Receipts Taxes 

19 New Mexico has a gross receipts tax structure instead of a sales tax structure. Like sales taxes, 

20 gross receipts taxes are generated by the purchase of goods and services. The gross receipts 

21 tax rate varies throughout the state from 5.125 percent to 8.6875 (Section 3.9.3). 

22 IIFP estimates (in 2009 dollars) that construction capital costs would be between $70 million 

23 and $94 million. Some portion of those expenditures would occur within the ROI and adjacent 

24 counties. The expenditures would generate gross receipts tax revenues for both the counties 

25 and New Mexico (IIFP, 2009a). The NRC staff finds that these revenues would be SMALL and 

26 beneficial. Because IIFP would have an industrial revenue bond with Lea County, some 

27 expenditure would be exempt from gross receipts taxes. 

28 Regional spending on goods and services by the construction workforce would generate gross 

29 receipts tax revenues for Lea County and Eddy County municipalities, the two counties, New 

30 Mexico, and other locales where spending occurs. The NRC staff finds that this increase in 

31 gross receipt taxes would create a SMALL, beneficial impact. 

32 Property Taxes 

33 Property taxes in Lea County are derived using property assessment values (33.3 percent of 

34 appraised values) and the tax rates of the taxing entities. The annual payment in lieu of tax 

35 (PILT) to the Hobbs Municipal School District is based on a tax rate of $7.60 per $1,000 of 

36 assessed value (IIFP, 2011a). The annual PILT to the New Mexico Junior College is based on 

37 a tax rate of $4.30 per $1,000 of assessed value (IIFP, 2011a). Based on the estimated 

38 assessed value of the IIFP land and attachments to the land and on the equipment and 

39 materials, the estimated PILTs during the construction would be $261,000 in 2012 and 
 4-17 

1 $293,400 in 2013 (IIFP, 2011a). According to Table 3-28, the Hobbs Municipal School District’s 

2 total 2007-2008 revenues were about $71 million and the New Mexico Junior College’s total 

3 2008-2009 revenues were about $37 million. Therefore, the NRC staff finds that the property 

4 tax impact of construction would be SMALL (less than 1 percent of the school revenues in all 

5 cases) but nonetheless, beneficial. 

6 4.1.1.8.4 Housing 

7 In 2008, 5,823 vacant housing units were within the ROI (Section 3.9.4). Construction would 

8 result in an influx of approximately 28 construction workers (Table 4-7), all of whom would need 

9 housing. Housing the 28 in-migrating construction workers would require 0.5 percent of the 

10 vacant housing units within the ROI. The in-migrating workers would not adversely affect the 

11 existing housing inventory. In addition, the ROI has temporary housing in hotel/motel rooms 

12 available for short-term leasing and areas available for trailers and recreational vehicles that 

13 some workers may elect to live in. 

14 Because the existing vacant housing inventory would be sufficient to accommodate the 

15 expected population increase associated with the proposed IIFP construction project, the NRC 

16 staff finds that the impact of construction on housing would be SMALL. 

17 4.1.1.8.5 Public Utilities 

18 Public Water 

19 All onsite potable, process, and fire water needed during the construction of the IIFP facility 

20 would be provided by one or two wells installed in the Ogallala aquifer (IIFP, 2009a). During 

21 construction, 72 people (Table 4-7) would relocate to the ROI and likely find housing within an 

22 area that is served by a public water utility. The major public water suppliers in the ROI serve 

23 88,643 people (Table 3-30) and most have excess capacity. The in-migration during 

24 construction would result in a 0.08 percent increase in people who rely on the ROI’s public 

25 water supply. The NRC staff finds that the impact of construction on public water supplies 

26 would be SMALL, because the excess capacity of water suppliers in the ROI is sufficient to 

27 support the in-migrating workforce. The construction site would not be connected to a public 

28 water supply. 

29 Public Wastewater 

30 There would be no onsite disposal of any solid or liquid waste during construction of the IIFP 

31 facility. The proposed IIFP site would not be connected to any public wastewater or sewage 

32 system (IIFP, 2011a). All wastes generated during construction, including sanitary wastes, 

33 would be shipped offsite for disposal. During construction, 72 people (Table 4-7) would relocate 

34 to the ROI and likely find housing within areas that are served by a public wastewater system. 

35 The major public wastewater treatment facilities in the ROI serve approximately 78,917 people 

36 (Table 3-31) and all have excess capacity. Construction in-migration would result in a 

37 0.09 percent increase in people who rely on the ROI’s public wastewater systems. Therefore, 

38 the NRC staff concludes that the impact of construction on public wastewater would be SMALL. 
 4-18 

1 4.1.1.8.6 Community Services 

2 Education 

3 In 2008, there were 8 public school districts, containing 64 schools, educating 22,847 students 

4 in the ROI (Section 3.9.6.1). Construction would result in an influx of approximately 28 

5 construction workers, 20 of whom would bring their families (Table 4-7). Each in-migrating 

6 family is estimated to have 0.8 school-aged children (Table 4-7); therefore, 16 children could 

7 require public school during construction (Table 4-7). The new student enrollment resulting 

8 from construction would represent an increase of 0.07 percent in the 2008 enrollment in the 

9 ROI. The increase in public school enrollment would be less than 1 percent of total enrollment 

10 and would be essentially undetectable. Therefore, the NRC staff concludes that the impact of 

11 construction on education would be SMALL. 

12 Fire Protection 

13 The in migrating workforce would increase the population in the ROI less than 0.1 percent 

14 (Section 4.1.1.8.1) and would result in filling 0.5 percent of the available housing. Therefore, 

15 there would not be a detectable increase in the demand for fire protection. Existing fire 

16 protection personnel, facilities, and equipment would be sufficient to support the population 

17 increase. Therefore, the NRC staff concludes that the impact of construction would be SMALL. 

18 Law Enforcement 

19 The in migrating workforce would increase the ROI population less than 0.1 percent 

20 (Section 4.1.1.8.1) and would not change the ability of existing law enforcement services to 

21 meet the needs of the population. Existing law enforcement personnel, facilities, and equipment 

22 would be sufficient to support the population increase; therefore, the NRC staff concludes that 

23 the impact of construction of the proposed IIFP facility would be SMALL. 

24 Hospitals and Physicians 

25 An ROI population increase of less than 0.1 percent (Section 4.1.1.8.1) would not measurably 

26 increase the demand for hospital and physician services. Therefore, the NRC staff concludes 

27 that the impact of construction on hospitals and physician services would be SMALL. 

28 4.1.1.8.7 Environmental Justice 

29 Environmental Justice refers to a Federal executive order that directs all Federal agencies, 

30 including the NRC, to identify and address disproportionately high and adverse human health 

31 and environmental effects on minority or low-income populations. Section 3.9.1.2 defines and 

32 identifies the minority and low-income populations within the 80-km (50-mi) radius of the 

33 proposed IIFP site. There are 96 block groups that fall completely or partially within the 80-km 

34 (50-mi) radius of the proposed site. Of the 96 block groups, 1 has a significant African 

35 American population, 15 have significant “some other race” populations, 32 have significant 

36 Hispanic populations, and 10 have significant low-income populations. The locations of these 

37 block groups are shown on Figures 3-22, 3-23, 3-24 and 3-25. The following discussion 

38 summarizes project impacts on the general population and addresses whether or not minority 

39 and low-income populations would experience disproportionately high and adverse impacts. 

40 The primary resource areas that could be affected by construction are soil, groundwater quality, 

41 groundwater quantity, air quality, ecology, and socioeconomics. 
 4-19 

1 • Land Use – The primary land use on the proposed IIFP site is cattle grazing. Less than 

2 10 percent of the 259-ha (640-ac) site area would be disturbed during construction, and 

3 cattle grazing would not be permitted on the site. Construction would not conflict with 

4 any existing Federal, State, local, or Indian Tribe land use plans, or planned 

5 development in the area. The NRC staff finds that the land use impacts resulting from 

6 construction and conversion from agricultural (grazing) land use to industrial use would 

7 be SMALL due to the abundance of other nearby grazing land (Section 4.1.1.1 Land 

8 Use). 

9 • Soils – The largest potential for impacts on soils during construction would result from 

10 clearing and grading, which loosens soil and increases the potential for erosion by wind 

11 and water. BMPs would be implemented during construction to limit soil loss. The NRC 

12 staff finds that the construction impacts on soils would be SMALL and confined to the 

13 site (Section 4.1.1.5 Geology, Minerals, and Soils). 

14 • Groundwater quality – Groundwater beneath the proposed IIFP site is unconfined and 

15 recharged by natural precipitation, therefore, uncontrolled spills during construction 

16 could temporarily and locally affect the aquifer. However, a site-specific Spill Prevention 

17 Control and Countermeasure Plan would be developed with procedures to manage 

18 spills. Therefore, the NRC staff finds that impacts on groundwater quality would be 

19 SMALL, localized, and temporary (Section 4.1.1.6 Water Resources). 

20 • Groundwater quantity – No municipal water line runs near the proposed IIFP facility. 

21 Water brought in tanker trucks from Hobbs, or one or two wells onsite would supply all of 

22 the water for the construction activities. Average and peak site water requirements for 

23 construction are expected to be approximately 6.05 L/min (1.6 gpm) and 20.5 L/min 

24 (5.42 gpm), respectively. Because the IIFP site is not located in a critical management 

25 area (CMA, the legal drawdown limit for any wells on the property would be on average 

26 0.06 m/yr (0.20 ft/yr). It is unlikely that the two wells would ever exceed the Lea County 

27 Underground Water Basin drawdown limit (Section 4.1.2.6 Water Resources). 

28 Therefore, the NRC staff finds that impacts to groundwater quantity would be SMALL. 

29 • Air quality – Section 4.1.1.4 reports that site boundary concentrations of some criteria air 

30 pollutants would be higher than the NAAQS. Therefore, the NRC staff finds that Phase 

31 1 construction impacts to air quality would be SMALL to MODERATE and localized. 

32 • Ecology – Approximately 16 ha (40 ac) of land would be disturbed, which represents 

33 less than 10 percent of the total 259 ha (640 ac) site. Construction would destroy or 

34 displace local wildlife. No impacts to rare or unique habitats, threatened or endangered 

35 species, or commercially or recreationally valuable species would result from 

36 construction. The NRC staff finds that potential impacts to ecological resources during 

37 construction would be SMALL and localized (Section 4.1.1.7 Ecological Resources), 

38 based on the small area that would be impacted, compared to the available comparable 

39 habitat within the region. 

40 • Socioeconomics – Construction would require a maximum of 140 workers, 28 of whom 

41 would migrate into the ROI, 20 of whom would bring families. The potential in-migrating 

42 population would increase the population within the ROI by 0.1 percent. The NRC staff 

43 concludes that this small increase in the population within the ROI would have a SMALL 

44 impact on employment, taxes, housing, community services, and public utilities (Section 

45 4.1.1.8 Socioeconomics). 

46 The NRC staff concludes that the impacts of construction on each of these resource areas 

47 would be SMALL (SMALL to MODERATE for air quality) and localized. Furthermore, the 
 4-20 

1 nearest minority or low-income population meeting the NRC definition is 22.5 km (14 mi) from 

2 the proposed site. Therefore, because potential impacts to all resource area impacts would be 

3 SMALL or MODERATE and localized, and the identified minority and low-income populations 

4 are not in close proximity to the proposed site, the NRC staff finds that impacts would not be 

5 disproportionately high and adverse for any populations in the region, including minority or low6 income populations. 

7 4.1.1.9 Traffic and Transportation 

8 This section identifies the traffic and transportation impacts within the region during 

9 construction. The transportation mode for personnel, construction equipment, and materials 

10 deliveries would be exclusively by roadways to the proposed IIFP site. There are no plans to 

11 extend the railroad in Hobbs to transport goods or materials to the proposed site. Although 

12 routine rail freight and air freight is expected to be used for shipping materials or equipment to 

13 the region, this freight would be offloaded elsewhere and arrive at the site on trucks. 

14 The principal highway routes that would handle this traffic include NM 483, which borders the 

15 site to the west, and US 62/180, which provides an east-west route to the nearest population 

16 centers. All traffic would access the site via NM 483, and most traffic would use US 62/180 to 

17 NM 483 to access the site. Some portion of the workforce may access the site from the north, 

18 using NM 83 to access NM 483 north of the site. At the junction of NM 483 and US 62/180, 

19 traffic would go east to Hobbs, Eunice and other Lea County municipalities or southwest to 

20 Eddy County. After the intersection of NM 483 and US 62/180 traffic associated with the site 

21 would be increasingly dispersed. 

22 Peak construction would use 140 workers (IIFP, 2011b). Therefore, if each employee 

23 commutes alone, there would be an increase of 140 vehicles on NM 483. IIFP estimated 

24 20 delivery or waste disposal trucks each day, for an additional 40 additional trips during one 

25 construction shift. 

26 The Highway Capacity Manual 2000 (TRB 2000) indicates that the capacity of a two-lane 

27 highway is 1,700 passenger cars per hour for a single direction and 3,400 passenger cars per 

28 hour for both directions. The annual average daily traffic count (AADT) on NM 483, a two-lane 

29 highway, at the intersection of US 62/180 in 2008 was 955 vehicles per day (NMDOT, 2009). If 

30 all the vehicles on NM 483 in one day used the road in a single hour, and if the construction 

31 workforce used the road to access the site during that same hour, a maximum of 1,095 vehicles 

32 would be on the road. This is less than the design capacity of a two-lane highway. Traffic 

33 impacts on NM 483 due to 20 truck trips per shift would have a smaller impact than the scenario 

34 described here. The maximum construction traffic on US62/180, which is a four-lane highway, 

35 also would have a smaller impact that that of the scenario analyzed here. Therefore, the NRC 

36 staff concludes that impacts to traffic from construction would be SMALL. 

37 The potential for traffic accidents increases with increased traffic. Assuming that the majority of 

38 the workers and trucks would travel from Hobbs (a distance of 23.3 km [14.5 mi ]) and Lovington 

39 (24.9 km [15.5 mi]), and a small percentage would come from Carlsbad (80 km [50 mi]), the 

40 NRC staff estimates an average one-way commute distance of 32 km (20 mi). Delivery trucks 

41 would travel an average round trip distance of 80 km (50 mi). A 64-km (40-mi) daily commute 

42 by 140 commuting workers and an 80-km (50-mi) commute by 20 truck results in 10,600 km 

43 (6,600 mi) traveled each day for 250 work days per year during the peak construction period. In 

44 New Mexico in 2010, vehicle accidents resulted in 51.73 injuries and 1.73 fatal accidents per 

45 160 million vehicle-km (100 million vehicle-mi) (UNM, 2010). Based on these rates, statistically, 
 4-21 

1 there would be one injury (risk of less than 0.85 injury crashes per year) and no fatalities (risk of 

2 less than 0.03 fatal crashes per year) as a result of the construction traffic. 

3 Therefore, the NRC staff concludes that impacts to traffic due to construction would be 

4 temporary and SMALL. 

5 4.1.1.10 Noise 

6 As discussed in Section 3.11, noise from the construction of the proposed facility would be 

7 restricted to daylight hours, temporary, and attenuated with distance. Four industrial facilities 

8 are within 5 km (3.1 mi) of the site. The nearest residence is approximately 2.6 km (1.6 mi) 

9 northwest of the site and there are no recreational facilities within 8.0 km (5.0 mi) of the 

10 proposed site. Because the construction equipment noise will attenuate within a short distance 

11 of the proposed IIFP site, the nearest residence and other land uses would not be adversely 

12 affected by construction noise. The NRC staff finds that impacts due to noise would be SMALL, 

13 based on the distances to surrounding residences and recreational areas and the rate at which 

14 noise is attenuated with distance. 

15 4.1.1.11 Public and Occupational Health Impacts 

16 This section analyzes the potential impacts on public and occupational health from the proposed 

17 IIFP facility construction. The analysis is divided into two main sections: nonradiological 

18 impacts and radiological impacts. 

19 The proposed action involves a major construction activity with the potential for industrial 

20 accidents, material-handling accidents, and construction accidents that could result in temporary 

21 injuries, long-term injuries and/or disabilities, and fatalities. 

22 The number of potential fatal and nonfatal occupational injuries from construction of the 

23 proposed IIFP facility were estimated based on injury rate data from the U.S. Department of 

24 Labor’s Bureau of Labor Statistics. As shown in Table 4-9, six nonfatal injuries and less than 

25 one fatality are expected during construction. Additionally, because of the commitment that IIFP 

26 is making to a safe design basis for facilities and programs, its safety culture, and adherence to 

27 the Integrated Safety Management System program and procedures, the occupational injury 

28 rates during construction of the proposed IIFP facility could be better than the industry average. 

29 Therefore, the NRC staff concludes that impacts to human health from occupational injuries 

30 during construction would be SMALL. 

31 Table 4-9. Nonfatal/Fatal Occupational Injuries Projected for IIFP Facility Construction 

Category Injury Rate Expected Occurrences1

Nonfatal Injuries 4.3 injuries per 100 workers per year2 6.0 

Fatal Injuries 9.7 fatalities per 100,000 workers per year3 less than 1 (1.4 x 10-2) 1 32 Expected occurrences are based on an average of 140 workers during the construction of the facility for 12 months 

33 (IIFP, 2011a). 

2 34 The expected nonfatal injury rate (total recordable cases) is from BLS (2010a). 3 35 The fatal injury rate is from BLS (2010b). 

36 

37 In addition to the potential occupational injuries that could result during construction, impacts to 

38 the public from air pollutants have been considered. Air pollutants would be generated by the 

39 internal combustion engines used in heavy equipment. As discussed in Section 4.1.1.4, the 
 4-22 

1 estimated air quality impacts from the air emissions during construction for the proposed IIFP 

2 facility would not measurably change the existing ambient air quality in the vicinity of the 

3 proposed IIFP facility. As a result, the NRC staff finds that the impacts to human health from air 

4 pollutants would be SMALL. 

5 4.1.1.12 Waste Management 

6 Construction of the proposed IIFP facility would generate waste materials that would be 

7 collected and transported offsite for recycling or disposal. Refuse and construction debris 

8 typical of industrial construction projects would be the predominant wastes generated during the 

9 construction phase (IIFP, 2011a). IIFP conservatively assumes that small quantities of low level 

10 radioactive wastes are also expected to be generated during the construction phase. This is 

11 because IIFP plans to install previously-used process vessels and standard unit operations 

12 equipment shipped from the decommissioned Sequoyah uranium conversion facility in Gore, 

13 Oklahoma, to the proposed IIFP facility (IIFP, 2011a; IIFP, 2011b). Because this equipment has 

14 been used for processing of radioactive materials, refuse and construction debris from its 

15 transport and installation could be disposed of as LLW as a precaution. 

16 The anticipated construction wastes include paper, plastic, cardboard, packaging materials, 

17 wood scraps, metal scraps, roofing and insulation scraps, masonry and ceramic materials, and 

18 empty paint and coating containers. Small quantities of organic solvent-based residuals 

19 remaining from application of specialty paints, architectural coatings, sealants, and adhesives, 

20 and wastes from certain other materials that are used for construction may be required to be 

21 managed as hazardous waste. The specific compositions and quantities for these construction 

22 waste types would depend on the final facility design (IIFP, 2011a). Tables 4-10 through 4-12 

23 provide the estimated annual quantities of solid, hazardous, and LLW currently anticipated by 

24 IIFP to be generated during construction, respectively. 

25 The general design/build contractor selected for the proposed IIFP facility would have 

26 responsibility for the day-to-day supervision of onsite waste collection and storage and for 

27 arranging for removal of these wastes from the IIFP site. Good work practices would be used to 

28 collect and sort the wastes for recycling or disposal (e.g., using designated roll-off containers 

29 and collection areas for different types of wastes). Solid (nonhazardous, nonradioactive) wastes 

30 would be transported offsite to an approved local landfill. Hazardous waste generated 

31 throughout the construction phase would be temporarily stored onsite and then shipped to an 

32 offsite facility appropriate for handling the waste composition, in accordance with established 

33 recycling and hazardous waste management programs. Any radiological waste would be 

34 shipped offsite to licensed LLW disposal facilities (IIFP, 2011a). The management of 

35 stormwater at the proposed IIFP facility is discussed in Section 4.1.1.6. 

36 The proposed IIFP facility would be located in the New Mexico Environment Department 

37 (NMED) district comprising Chaves, Eddy, Lincoln, and Lea Counties. At present disposal 

38 rates, the remaining disposal life of the three permitted solid waste landfills (Roswell Municipal 

39 Landfill, Sand Point Landfill, and Lea County Landfill) in that district ranges from 16 years to 

40 63 years (NMED, 2009). This district also has an “industrial waste only” landfill, Lea Land, Inc. 

41 Industrial Landfill, with an anticipated remaining disposal life of more than 100 years (NMED, 

42 2009). Nonhazardous wastes from the proposed IIFP facility would likely be transported to the 

43 Lea County landfill for disposal. The landfill accepts residential, commercial, private and public 

44 waste material from generators within a 161-km (100-mi) radius. The landfill is operated by the 

45 Solid Waste Authority of Lea County under NMED Permit # Stormwater Management
 4-23 

1 Table 4-10. Solid Waste Generation - Construction 

Waste Type Estimated Annual Amount 

Air filters (vehicle) 23 – 45 kg 

(50 – 100 lbs) 

Cardboard / packing 140 – 230 kg 

(300 – 500 lbs) 

Fiber drums 140 – 230 kg 

(300 – 500 lbs) 

Total 300 – 500 kg 

(650 – 1,100 lbs) 

2 Source: IIFP, 2011a 

3 

4 Table 4-11. Hazardous Waste Generation - Construction 

Waste Type Estimated Annual Amount 

Adhesives, resins, caulking residues 45 – 90 kg 

(100 – 200 lbs) 

Lead (batteries) 45 –110 kg 

(100 – 250 lbs) 

Oil filters 45 – 90 kg 

(100 – 200 lbs) 

Paints, thinners, solvents, organic residues 45 – 230 kg 

(100 – 500 lbs) 

Pesticides 45 – 68 kg 

(100 – 150 lbs) 

Petroleum products, oils, lubricants residues 45 – 230 kg 

(100 – 500 lbs) 

Total 270 – 820 kg 

(600 – 1,800 lbs) 

5 Source: IIFP, 2011a 

6 

7 Table 4-12. Low Level Radioactive Waste Generation - Construction 

Material Estimated Annual Amount 

Scrap metal 1,800 – 2,700 kg 

(4,000 – 6,000 lbs) 

Spent blasting sand 45 kg 

(100 lbs) 

Wood trash (pallets) 450 – 680 kg 

(1,000 – 1,500 lbs) 

Total 2,300 – 3,400 kg 

(5,100 – 7,600 lbs) 

8 Source: IIFP, 2011a 

9 

10 (SWM) -13030. The Lea County landfill receives approximately 74,800 metric tons 

11 (82,500 tons) annually (NMED, 2009). Nonhazardous waste generated from the proposed IIFP 

12 construction activities would result in a negligible increase (less than 0.5 metric ton or 

13 0.0007 percent) in the waste that the Lea County landfill receives annually from all other 

14 sources. Therefore, the NRC staff finds that the solid waste management impacts resulting 

15 from construction of the IIFP facility would be SMALL. 
 4-24 

1 Hazardous wastes generated during construction would be packaged and shipped offsite to 

2 licensed hazardous waste treatment and disposal facilities in accordance with Federal and State 

3 regulations (IIFP, 2011a). The projected annual hazardous waste generation would likely 

4 classify the proposed IIFP facility as small quantity generator (over 100 kg/mo [220 lb/mo] but 

5 less than 1,000 kg/mo [2,200 lb/mo]) during construction. Hazardous waste generators in New 

6 Mexico accounted for 978,000 metric tons (1,079,000 tons) of hazardous waste in 2009, with all 

7 but 3,700 metric tons (4,084 tons) originating at one facility operated by the Navajo Refining 

8 Company (EPA, 2010b). Less than 0.9 metric tons (1 ton) per year of hazardous wastes would 

9 be expected from construction of the proposed IIFP facility. The IIFP facility would, during 

10 construction, be one of the smaller hazardous waste generators in New Mexico and would 

11 contribute less than 0.00009 percent to the overall hazardous waste generated in the State. 

12 Therefore, the NRC staff concludes that the quantity of construction-generated hazardous waste 

13 material would result in SMALL impacts that could be managed effectively. 

14 Radiological waste generated during construction, due to the use of previously-used radiological 

15 processing equipment, would be shipped offsite to licensed LLW disposal facilities (IIFP, 

16 2011a). As shown in Table 4-12, up to 3.4 metric tons (3.8 tons) per year of LLW could be sent 

17 for disposal. That corresponds to approximately 22.5 drums per year. This LLW volume 

18 represents 0.008 percent of the annual commercial waste volume currently received at the 

19 EnergySolutions facility in Clive, Utah (NRC, 2010). All LLW generated will be Class A wastes 

20 as defined by 10 CFR 61.55 (IIFP, 2009a). The Clive facility accepts the majority of the United 

21 States’ Class A LLW (as detailed in 10 C.F.R. § 61.55, Waste Classification, enforced by NRC) 

22 and is estimated to have capacity to accept this waste at current volume levels for more than 

23 20 years (GAO, 2004). Thus, the NRC staff finds that the quantity of construction-generated 

24 LLW would result in SMALL impacts to LLW disposal capacity. 

25 4.1.2 Environmental Impacts of Operation 

26 The impacts of operations of the facility described in Chapter 2 on each of the major resource 

27 areas described in Chapter 3 (Affected Environment) are presented in this section. Impacts of 

28 the proposed Phase 2 facility activities identified in Chapter 2 are evaluated as cumulative 

29 impacts in Section 4.2. 

30 4.1.2.1 Land Use 

31 This section describes the potential impacts on land use during operation of the proposed IIFP 

32 facility. 

33 During operations the primary current land use at the site, which is cattle grazing, would be 

34 eliminated by a fence surrounding the entire 259-ha (640-ac) site. Except for the 16-ha (40-ac) 

35 facility footprint, the remainder of the site (240 ha or 600 ac) would be remain undeveloped for 

36 the duration of the license. Operation of the proposed IIFP facility would be consistent with the 

37 industrial nature of land in the vicinity which supports four energy production facilities (Xcel 

38 Energy’s Cunningham Station and Maddox Station, Colorado Energy Station, and the DCP 

39 Midstream Linam Ranch Plant). The proposed IIFP facility and retention of the remaining 

40 portion of the site as undeveloped land would not conflict with any existing Federal, State, local, 

41 or Native American tribal land use plans. The use of land for the facility would not interfere with 

42 any planned development in the area (Appendix A). The facility’s location within Section 27 was 

43 selected to avoid, to the extent possible, utility rights-of-way, and operation of the facility will not 

44 prohibit access to the rights-of-way for maintenance. None of the Cunningham Station’s 

45 monitoring wells in Section 27 would be affected by the operation of the facility 
 4-25 

1 (GL Environmental, 2010). Because many square miles around the facility have similar habitat, 

2 and because the industrial nature of the facility would be consistent with local land use, the NRC 

3 staff concludes that land use impacts associated with operation of the proposed facility would be 

4 SMALL. 

5 4.1.2.2 Historic and Cultural Resources 

6 This section describes the potential environmental impacts on historic and cultural resources 

7 resulting from operation of the proposed IIFP facility. Impacts to historic or cultural resources 

8 would most likely occur during ground-disturbing activities associated with construction. 

9 Therefore, because operations would not require additional land disturbance, the NRC staff 

10 concludes that any impacts to historic properties, districts, resources or significant 

11 historic/precontact archaeological sites during facility operation would be SMALL. 

12 4.1.2.3 Visual Resources 

13 This section discusses the potential visual and scenic impacts that could result from operation of 

14 the proposed IIFP facility. Visual impacts could occur as a result of tall or massive structures 

15 being imposed on a landscape, or if plumes visible from a long distance were emitted from a 

16 facility. 

17 The tallest proposed building would be 21.3 m (70 ft) high and emission stacks would be less 

18 than 30.5 m (100 ft) tall (IIFP, 2009a); well under the 61-m (200-ft) threshold that requires lights 

19 for aviation safety (FAA, 1992). The facility will not be visible from any recreational or historic 

20 facilities, and will not degrade the existing viewscape which includes four other industrial 

21 facilities. In addition, security lighting would be directed downward to minimize light pollution 

22 (IIFP, 2009a), therefore, the NRC staff concludes that impacts to visual resources would be 

23 SMALL. 

24 4.1.2.4 Climate, Meteorology and Air Quality 

25 4.1.2.4.1 Greenhouse Gases 

26 This section presents an assessment of the effect operation of the proposed IIFP facility could 

27 have on the concentrations of CO2 and other greenhouse gases in the atmosphere. 

28 During operation, greenhouse gas emissions would result from workforce commuting, deliveries 

29 of feedstock and consumable materials to the proposed facility, return of empty feedstock 

30 containers to their points of origin, transfer of wastes to designated offsite disposal facilities and 

31 operation of a gas-fired boiler. An incidental amount of greenhouse gas emissions would result 

32 from the onsite storage and dispensing of fossil fuels to support operations, but is not evaluated 

33 here. 

34 A workforce of 140 is assumed to commute a round-trip distance of 64 km (40 mi), assuming 

35 250 round trips per year and taking no credit for carpooling or busing. Annually, the workforce 

36 would commute approximately 2,200,000 km (1,400,000 mi). 

37 Deliveries and returns of DUF6 cylinders and waste shipments are estimated at 2,650 round 

38 trips per year. Thus, an average of approximately 10 truck round trips would occur daily during 

39 a 5-day work week. The DUF6 feed materials for the facility would be transported by 

40 18-wheeled trucks via highway only and are expected to come from several facilities across the 
 4-26 

1 country: the URENCO USA facility approximately 53 km (33 mi) away; Global Laser 

2 Enrichment 2,600 km (1,616 mi) away; and the Eagle Rock Enrichment Facility approximately 

3 1,796 km (1,116 mi) away. Waste from the IIFP facility would likely be transported to one of 

4 several disposal facilities. One low-level waste disposal facility is the EnergySolutions facility in 

5 Clive, Utah approximately 1,572 km (977 mi) from the IIFP site. Hazardous and mixed low-level 

6 radioactive wastes could be disposed at Waste Control Specialists which is approximately 

7 61 km (38 mi) from the IIFP facility. Because it is difficult to anticipate the proportion of 

8 shipments among the DUF6 feed materials suppliers and waste disposal sites, an average of the 

9 distances to the five facilities was used to establish a conservative scenario with respect to 

10 GHG emissions. An average roundtrip distance of 2,433 km (1,512 mi) was assumed. The 

11 resulting annual travel distance is 6,447,450 km (4,006,800 mi). Table 4-13 shows the 

12 estimated total transportation-related CO2 emission associated with proposed IIFP facility 

13 operations. The total CO2 emissions expected during IIFP facility operations from commuting of 

14 the operational workforce, deliveries of feedstock to the proposed facility, return of empty 

15 feedstock containers to their points of origin and delivery of operational wastes to designated 

16 offsite disposal facilities are 4,433 metric tons (4,886 tons) per year. NRC staff estimated these 

17 levels based on modeling summarized and presented in Appendix C (Air Emissions) of this draft 

18 EIS. 

19 Table 4-13. Annual Transportation-Related CO2 Emissions During IIFP Facility 

20 Operations 

Activity 

Total 

Workers 

RT Distance Working 

Days/ 

Year 

Total Distances per 

Year 

Annual CO2

Emissions 

(mi) (km) (mi) (km) (ton) (MT) 

Commuting 

traffic 

140 40 64 250 1,400,000 2,300,000 660 599 

Operational 

deliveries and 

waste removal 

shipments 

N/A 1,512 2,433 N/A 4,000,000 6,400,000 4,226 3,833 

Subtotal of CO2

emissions as a 

result of 

transportation 

related impacts 

from IIFP facility 

operations 

_ _ _ _ _ _ 4,886 4,433 

21 

22 The proposed IIFP facility would also require a gas-fired boiler (the facility would install two 

23 boilers for redundancy, but only one at a time would operate). The estimated emissions of CO2

24 equivalents from the boilers are 1,345 metric tons (1,483 tons) per year (IIFP, 2009a). 

25 Therefore, the total CO2 emissions expected from facility operations are 5,778 metric tons 

26 (6,369 tons) per year. 

27 Using calendar year 2000 as a reference point (the latest year for which New Mexico GHG 

28 emission data are available), and as shown in Table 3-1, total net CO2 emissions for New 

29 Mexico for the year 2000 were 62 million metric tons (68 million tons) of CO2 equivalents. For 

30 the United States for that same year, total net CO2 emissions were 5,977 million metric tons 

31 (6,588 million tons) (EPA, 2010a). By comparison, during any typical year of IIFP facility 
 4-27 

1 operation, CO2 emissions are projected to be 5,778 metric tons (6,369 tons), approximately 

2 0.009 percent of the New Mexico statewide output or 0.0001 percent of the nationwide 

3 emissions for calendar year 2000. Therefore, the NRC staff concludes that impacts from the 

4 operation of the proposed IIFP facility from the emissions of CO2 and other greenhouse gases 

5 would be SMALL. 

6 4.1.2.4.2 Air Quality 

7 Air quality would be affected during operation of the proposed uranium deconversion facility. As 

8 discussed in more detail below, the impact levels would not be significant. 

9 4.1.2.4.2.1 Criteria Pollutant Emissions 

10 Operation of the proposed project would produce criteria pollutant (i.e., CO, NO2, PM10, PM 2.5, 

11 SO2, and VOC, an ozone precursor) emissions from natural-gas fired boilers, an emergency 

12 diesel generator, a fire-water pump, a hydrogen generator, and commuter/delivery vehicles. 

13 IIFP used emission factors obtained from the EPA document AP-42, “Compilation of Air 

14 Pollutant Emission Factors” (EPA, 1995a) to estimate emissions from the natural gas boilers, 

15 emergency diesel generator, and fire water pump. Emissions from each equipment type are a 

16 function of equipment-specific factors, including engine horsepower, load factor, and hours of 

17 operation. During operations one boiler would operate continuously, providing 3000 pounds of 

18 steam per hour for the heating and autoclave feed systems. The diesel generator and fire water 

19 pump are assumed to be operated for emergency and testing purposes only (IIFP, 2011c). IIFP 

20 used equipment manufacturer data to estimate emissions from the hydrogen generator. 

21 Operation of the hydrogen generator would be on demand (IIFP, 2011a). Title V of the 1990 

22 Clean Air Act Amendments requires facilities defined as "major stationary sources" to obtain a 

23 Title V operating permit. A major stationary source is any facility that has the potential to emit 

24 more than 100 tons of any criteria pollutant per year. As shown in Table 4-14, emissions 

25 resulting from operations at the proposed IIFP facility would be well below the 100 tons per year 

26 threshold. Therefore, the proposed project would not require a Title V operating permit. 

27 NRC staff used emission factors to estimate annual criteria pollutant emissions from highway 

28 vehicles (i.e., worker commute vehicles and delivery vehicles). The emission factors were 

29 determined using the EPA MOVES Model (EPA, 2009a). Emissions from highway vehicles 

30 (i.e., worker commute vehicles and delivery and waste transport vehicles) are a function of the 

31 vehicle-specific factors, including type of vehicle and age, fuel type, and vehicle miles traveled. 

32 NRC staff used Lea County, New Mexico-specific default values for vehicle type, age, and fuel 

33 type to determine highway vehicle emission factors. IIFP estimates that during operations 

34 140 workers would commute to and from the proposed site, an average daily trip distance of 

35 64 km (40 mi), for 250 days each year. Delivery and waste transport trucks (presumed to be 

36 diesel-fueled, long-haul semi-trailer trucks averaging 10 mpg) would make on average, 10 trips 

37 per day (at an average round-trip distance of 2,433 km [1,512 mi]) to transport materials and 

38 remove wastes. Table 4-15 shows the estimated annual emissions as a result of a commuting 

39 workforce and material transport. 

40 To estimate the impact to local air quality, NRC staff compared the total anticipated direct 

41 (facility) and indirect (highway vehicle) criteria pollutant and VOC emissions from the proposed 

42 IIFP facility to baseline emissions from Lea County, New Mexico. As shown in Table 4-16, 

43 emissions from the proposed project would represent a very small portion of the annual criteria 
 4-28 

1 Table 4-14 Estimated Maximum Annual Criteria Pollutant Emissions from Phase 1 

2 Operation of the IIFP Facility 

Source 

CO 

metric tons 

(tons) 

NO2 

metric tons

(tons) 

PM2.5 

metric tons

(tons) 

PM10 

metric tons

(tons) 

SO2 

metric tons 

(tons) 

VOC 

metric tons

(tons) 

Boilers 0.93 1.09 0.08 0.08 0.01 0.06 

(1.03) (1.20) (0.09) (0.09) (0.01) (0.07) 

Generators 0.032 0.149 0.011 0.011 0.010 0.00308 

(0.035) (0.164) (0.012) (0.012) (0.011) (0.00340) 

Firewater 

Pump 

0.003 0.013 8.98 x 10-4 9.0 x 10-4 8.4 x 10-4 2.63 x 10-4

(0.003) (0.014) (9.9 x 10-4) (9.9 x 10-4) (9.3 x 10-4) (2.90 x 10-4)

Hydrogen 

Generator 

0.21 0.02 0 0 0 0 

(0.23) (0.02) 0 0 0 0 

Total 1.18 1.27 0.093 0.093 0.020 0.067 

(1.30) (1.40) (0.103) (0.103) (0.022) (0.074) 

3 Source: IIFP, 2011b 

4 

5 Table 4-15. Estimated Maximum Annual Criteria Pollutant Emissions from Highway 

6 Vehicles during Phase 1 Operation of the IIFP Facility 

Source 

CO 

metric tons 

(tons) 

NO2 

metric tons

(tons) 

PM2.5 

metric tons

(tons) 

PM10 

metric tons

(tons) 

SO2 

metric tons 

(tons) 

VOC 

metric tons

(tons) 

Commuter 

Vehicles 

10.9 1.46 0.0266 0.0495 0.0116 1.03 

(12.1) (1.61) 0.(0293) 0.(0545) (0.0128) (1.14) 

Delivery 

Vehicles 

41.0 18.6 0.789 0.953 0.0449 3.50 

(45.2) (20.5) (0.870) (1.05) (0.0495) (3.85) 

Total 51.9 20.0 0.816 1.00 0.0565 4.53 

(57.3) (22.1) (0.899) (1.10) (0.0623) (4.99) 

7 Source: IIFP, 2011b 

8 

9 Table 4-16. Comparison of Maximum Annual Emissions from Phase 1 Operations to 

10 Lea County Baseline Conditions 

Source 

CO 

metric tons 

(tons) 

NO2 

metric tons 

(tons) 

PM2.5

metric tons 

(tons) 

PM10

metric tons 

(tons) 

SO2

metric tons 

(tons) 

VOC 

metric tons 

(tons) 

Operations 53.1 21.3 0.908 1.09 0.0774 4.60 

(58.6) (23.5) (1.00) (1.21) (0.0853) (5.06) 

Lea County 

Baselinea

 

21,244 

(23,417) 

27,119 

(29,894) 

2,892 

(3,188) 

25,048 

(27,611) 

7,334 

(8,084) 

4,436 

(4,890) 

Net Increase 

over Baseline 

0.25% 0.079% 0.031% 0.0044% 0.0011% 0.10% 

a 11 Source: EPA, 2009b 
 4-29 

1 pollutant emissions in Lea County. Because conservative assumptions that tend to 

2 overestimate impacts were used, actual emissions from operations would be less. 

3 IIFP used EPA’s SCREEN3 model (EPA, 1995b) to estimate the maximum concentrations of 

4 pollutants at the IIFP site property line that would be associated with operations. As shown in 

5 Table 4-17, the estimated incremental increases in ambient background concentrations due to 

6 the proposed operations would be below allowable PSD Class II increments and well below the 

7 National NAAQS. VOCs are not included in Table 4-17 because there are no regulatory metrics 

8 for comparison (VOC emissions are regulated by source controls and permit requirements). 

9 Table 4-17. Predicted Property Boundary Concentrations Due to Phase 1 Operations, 

10 NAAQS and Allowable Class II PSD Increments 

Pollutant 

Averaging 

Time 

NAAQS 

(μg/m3) 

Allowable 

Class II PSD 

Increment 

(μg/m3) 

Incremental 

Concentration 

Increase 

(μg/m3

) 

Incremental 

Concentration 

Increase as 

Percentage of 

NAAQS 

CO 1-hr 

8-hr 

10,000 

40,000 

NA 5.8 0.06% 

NA 4.1 0.010% 

NO2 Annual 100 25 0.059 0.6% 

PM2.5 24-hr 

Annual 

35 

15 

9 0.17 0.5% 

4 0.042 0.3% 

PM10 24-hr 150 8 0.17 0.11% 

SO2 1-hr 

3-hr 

200 

1,300 

NA 0.096 0.05% 

512 0.086 0.007% 

11 Source: IIFP, 2011a; EPA, 2009a 

12 

13 4.1.2.4.2.2 Nonradioactive Process Effluents 

14 Radioactive and nonradioactive gaseous effluents would be generated during operation of the 

15 proposed IIFP facility (IIFP, 2011a). Radioactive gaseous effluents are addressed in 

16 Section 4.1.2.11. 

17 IIFP estimated annual nonradioactive process emissions for operation (IIFP, 2011a). 

18 Nonradioactive gaseous effluents would include HF, SiF4, BF3 CaF2, calcium hydroxide 

19 [Ca(OH2)], and B2O3. Gaseous effluents from the DU6 to DU4, SiF4 and BF3 processes 

20 (comprised mostly of nitrogen, air, some relatively low amounts of the product gases and other 

21 trace fluorides) would undergo treatment in the plant KOH scrubbing system to remove 

22 approximately 99.9 percent of the fluoride components before being released to the atmosphere 

23 via a monitored stack (IIFP, 2011a). The plant KOH scrubbing system is described in 

24 Section 2.1.6.4.1. 

25 The nonradioactive process annual emissions are shown in Table 4-18. The combined 

26 estimated annual fluoride releases, including HF (52.6 kg [116 lb]), SiF4 (3.7 kg [8.2 lb]), BF3

27 (64.1 kg [141 lb]), and CaF2 (3.55 kg [7.82 lb]), are 124 kg (273 lbs). The annual total 

28 expressed as an hourly rate is 0.014 kg/hr (0.031 lb/hr). This pound per hour rate is well below 

29 the New Mexico threshold of 0.167 lb/hr for fluoride emissions. 
 4-30 

1 Table 4-18. Annual Nonradioactive Gaseous Emissions from the Operation of the 

2 Proposed IIFP Facility Emission 

Estimated Releases Total Emissions 

Plant KOH 

Scrubbing System 

Stack 

DUF4 Dust Collector 

Stack 

FEP Dust Collector 

DUF4 Vacuum 

Transfer Dust 

Collector 

CaF2 Dust Collector 

Lime Silo Dust 

Collector B

O2 3 Silo 

Total Emission 

kg/yr (lb/yr) 

HF 3.03 

(6.69) 

41.54 

(91.59) 

0.35 

(0.77) 

7.77 

(17.13) - - - 52.6 

(116.18) 

SiF4

0.0 

(0.01) - 3.71 

(8.19) - - - - 3.7 

(8.20) 

BF3

1.28 

(2.83) - 62.48 

(137.75) - - - - 64 

(140.58) 

U - 0.03 

(0.07) 

0.03 

(0.06) 

0.25 

(0.55) - - - 0.31 

(0.68) 

CaF2 - - - - 3.55 

(7.82) - - 3.55 

(7.82) 

Ca(OH)2 - - - - - 60.78 

(134.00) - 60.78 

(134.00) 

B2O3 - - - - - - 4.93 

(10.87) 

4.93 

(10.87) 

Totals 4.50 

(9.93) 

41.58 

(91.66) 

66.57 

(146.77) 

8.02 

(17.68) 

3.55 

(7.82) 

60.78 

(134.00) 

4.93 

(10.87) 

189.75 

(418.33) 

3 Source: IIFP, 2011a. 

4 

5 4.1.2.4.2.3 Summary 

6 As discussed above, the estimated criteria pollutant emissions for Phase 1 operation of the 

7 proposed IIFP facility represent a very small fraction of the current emissions in Lea County. 

8 Because conservative assumptions that tend to overestimate impacts were used, actual 

9 emissions from operations would be less. In addition, pollutant emissions, including 

10 nonradioactive process effluents, would not change the existing ambient air quality in the vicinity 

11 of the IIFP facility. The NRC staff, therefore, concludes that air quality impacts during operation 

12 of the proposed IIFP facility would be SMALL to MODERATE. 

13 4.1.2.5 Geology, Minerals, and Soil 

14 No impact to the underlying bedrock, mineral resources, or soil is expected during facility 

15 operations. As discussed in Section 3.6.2, the site is in an area of limited seismic and volcanic 

16 activity, therefore, the statistical probability of fault rupture near the site is very low and the NRC 

17 staff finds that any associated impact due to seismic activity would be SMALL. Additionally, 

18 operation of the proposed IIFP facility is not expected to cause seismic or fault-related impacts. 
 4-31 

1 Seismic risks to the facility would be mitigated by incorporation of seismic criteria in the facility 

2 design to prevent spills or releases to the environment (IIFP, 2009a). 

3 Consequently, the NRC staff concludes that impacts of operation of the proposed IIFP facility to 

4 geology, minerals, seismicity, and soils are expected to be SMALL, and that impacts to the 

5 facility from any seismic activity would be SMALL. 

6 4.1.2.6 Water Resources 

7 All facility water systems – for potable, process and fire protection water -- would use 

8 groundwater. Groundwater pumped from the site well(s) would be a consumptive use because 

9 the groundwater would either be consumed or evaporated. 

10 4.1.2.6.1 Groundwater Use 

11 As discussed in Section 4.1.1.6.1.1, groundwater would be supplied from up to two onsite 

12 production wells. These wells would meet an estimated operations demand from 7.9 L/min 

13 (2.1 gpm) to 11.8 L/min (3.1 gpm) (normal) up to 26.3 L/min (6.95 gpm) (maximum). The 

14 operation of the facility would require relatively low volumes of water because it would recycle 

15 process water and re-circulate cooling water. The project is projected to use less than 38,000 L 

16 (10,000 gal) of groundwater per day (IIFP, 2011a). 

17 As discussed in Section 3.7.1.2.1, because current pumping is in excess of the Ogallala’s 

18 recharge rate, the aquifer has experienced significant drawdown in the last several decades. In 

19 2009, the NM OSE prepared guidelines on the procedures for processing water rights 

20 applications filed with the Lea County UWB. The NM OSE developed administrative guidelines 

21 in order to promote the orderly development of water resources in the Lea County UWB, while 

22 meeting statutory obligations regarding existing water rights, availability of unappropriated 

23 water, conservation of water with the State, and public welfare of the State through a 40-year 

24 planning period beginning on January 1, 2005 and ending on January 1, 2045. 

25 On March 10, 2009, the NM OSE issued an order closing the Lea County UWB to the filing of 

26 groundwater applications (NMOSE, 2009a). In 1999, in order to meet the projected 

27 groundwater demands of Lea County, 138 applications were filed by the Lea County Water 

28 Users Association to appropriate 6,389 ha-m (51,797 ac-ft) per year of groundwater, which was 

29 essentially all the unappropriated groundwater in the Lea County UWB (Leadshill-Herkenhoff 

30 et al., 2000). 

31 A portion of the applications to appropriate groundwater, totaling 4,215.2 ha-m (34,173 ac-ft) 

32 per year, have been assigned to Lea County during (at least) the 40-year planning period to 

33 allow the County to hold the subject water rights unused until the rights can be put to beneficial 

34 use at projects currently under construction, select future projects, and homes and businesses 

35 in unincorporated areas. The proposed IIFP site has been included in Lea County’s 40-Year 

36 Water Development Plan as an area of proposed development where up to 21.6 ha-m (175 ac37 ft) per year of the Lea County’s water rights would be put to beneficial use. The estimated 

38 quantity of groundwater that Lea County would need by the end of the 40-year planning period 

39 for all projects that currently exist, are being constructed, or have a high likelihood of being 

40 constructed in the near future is 1,173.5 ha-m (9,514 ac-ft) per year (Leadshill-Herkenhoff et al., 

41 2000). 
 4-32 

1 Groundwater rights for the facility would be obtained from the Lea County unallocated water 

2 rights under State Engineer Office Water Right File No. L-04719-A, for industrial water use. The 

3 proposed facility would obtain a joint Lea County and New Mexico Office of State Engineer 

4 Water Rights Agreement for 6.2 ha-m (50 ac-ft) per year (far less than the 21.6 ha-m [175 ac-ft] 

5 per year estimation in the Lea County Water Development Plan). 

6 Operation of the proposed IIFP facility would use approximately 0.50 percent of the estimated 

7 additional annual 40-year planning period groundwater demand of 1,173.5 ha-m (9,514 ac-ft) 

8 per year for Lea County, and only 0.15 percent of the 4,215.2 ha-m (34,173 ac-ft) per year of 

9 unappropriated water rights that have been assigned to Lea County. 

10 As part of NM OSE’s guidelines on the procedures for processing water rights applications filed 

11 with the Lea County UWB, the basin was divided into blocks corresponding to township and 

12 range. No permits were granted to appropriate water in a block unless one-third or more of the 

13 original groundwater storage in the block would be available at the end of the 40-year period. 

14 Blocks with an estimated saturated thickness of 16.8 m (55 ft) or less by 2045 are designated a 

15 CMA. The proposed IIFP site is not located in a CMA. 

16 For wells installed in a non-CMA, the Lea County Water Users Association recommends a 

17 drawdown limit of 2.4 m (7.9 ft) over 40 years, or 0.06 m/yr (0.20 ft/yr). Groundwater model 

18 simulations run by the NM OSE Hydrology Bureau to provide estimated drawdowns for a range 

19 of pumping scenarios in different hydraulic conductivity zones indicates that using a high 

20 hydraulic conductivity value for the Ogallala aquifer of 12.5 to 18.3 m (41 to 60 ft) per day for a 

21 single well pumping 6.2 ha-m (50 ac-ft) per year in an area of the aquifer with a saturated 

22 thickness of 61 m (200 ft) results in an estimated drawdown of 0.11 m (0.36 ft) in 40 years 

23 (NMOSE, 2009b). Considering that (1) the permeability of the Ogallala aquifer is quite variable 

24 (ranging as low as 0.61 m [2 ft/day]), and (2) the two site wells would never independently pump 

25 6.2 ha-m (50 ac-ft) per year, a drawdown of 0.11 m (0.36 ft) in 40 years is very conservative. It 

26 is highly unlikely that the wells would ever exceed the Lea County Water Users Association 

27 drawdown limit of 2.4 m (8 ft) over 40 years. 

28 The NRC staff finds that adverse impacts on groundwater quantity (availability) due to pumping 

29 from the site’s potential of two production wells during operation would be SMALL based on the 

30 following findings: 

31 • The proposed IIFP site has been included in Lea County’s 40-Year Water Development 

32 Plan as an area of proposed development where up to 21.6 ha-m (175 ac-ft) of the Lea 

33 County’s water rights would be put to beneficial use. 

34 • Groundwater rights for the proposed facility would be obtained from the Lea County 

35 unallocated water rights under State Engineer Office Water Right File No. L-04719-A for 

36 industrial water use. The facility would obtain a joint Lea County and New Mexico Office 

37 of State Engineer Water Rights Agreement for 6.2 ha-m (50 ac-ft) per year (far less than 

38 the 21.6 ha-m [175 ac-ft] per year estimation in the Lea County Water Development 

39 Plan). 

40 • Operation of the proposed facility would use approximately 5 percent of the estimated 

41 annual 40-year planning period groundwater demand of 1,173.5 ha-m (9,514 ac-ft) per 

42 year for Lea County, and only 0.15 percent of the 4,215.2 ha-m (34,173 ac-ft) per year of 

43 unappropriated water rights that have been assigned to Lea County. 
 4-33 

1 • Based on comparing the site wells to the most conservative NM OSE groundwater 

2 model scenario, it is highly unlikely that the wells would ever exceed the Lea County 

3 Water Users Association drawdown limit of 2.4 m (8 ft) over 40 years. 

4 • The site production wells would be installed in accordance with all NM OSE and Lea 

5 County Water Users Association well permit regulations. 

6 4.1.2.6.2 Groundwater Quality 

7 During IIFP operation, stormwater from the site would be collected in two runoff 

8 retention/evaporation basins. No wastes from facility process systems would be discharged to 

9 stormwater. In addition, stormwater discharges during facility operation would be controlled by 

10 a Stormwater Pollution Prevention Plan. Water discharged from the site sanitary waste 

11 treatment system would meet required concentrations of all contaminants stipulated in any 

12 permit or license required for that activity, including 10 CFR 20 and a Groundwater Discharge 

13 Permit/Liquid Waste Permit (IIFP, 2011a). An application for the Groundwater Discharge Permit 

14 has been submitted by IIFP to the NMED Groundwater Quality Bureau, which has issued a 

15 conceptual groundwater monitoring plan that is subject to change as more information becomes 

16 available during the discharge permit application process. NMED will require that total 

17 dissolved solids, sulfate, chloride, nitrate as nitrogen, total Kjeldahl nitrogen, fluoride, and 

18 isotopic uranium be monitored quarterly (IIFP 2011a). 

19 Treated process water from the sanitary waste treatment system would be used for irrigation at 

20 the facility. Because of high evaporation rates, and the presence of the 9.1-m (30-ft) indurate 

21 caliche unit that underlies the site, the irrigation water is not expected to migrate to groundwater. 

22 There would be no onsite disposal of solid, hazardous, radioactive, or mixed waste at the 

23 proposed IIFP site. 

24 The existing groundwater monitoring program at the site would be supplemented with the 

25 installation of at least four additional monitoring wells. Three of these monitoring wells are 

26 proposed to be located hydraulically downgradient (south) from the DUF6 Cylinder Storage Pad, 

27 the Cylinder Pad Stormwater Retention Basin, and the Stormwater Retention/Evaporation 

28 Basin. The fourth monitoring well is proposed hydraulically upgradient (north) from the primary 

29 production facility, just within the site’s security fence (IIFP, 2011a). The wells would be 

30 installed per the requirements of the NMED and sampled quarterly. 

31 Any spills of chemicals, diesel fuel, or other contaminants during operations would be cleaned 

32 up quickly in accordance with the proposed facility’s Spill Prevention Control and 

33 Countermeasure Plan, to prevent a pathway for the contaminant to enter the groundwater, 

34 thereby mitigating impacts to groundwater such that any inadvertent releases would result in 

35 localized and temporary impacts. Due to limited liquid effluent discharge from the facility 

36 operations (which would be treated prior to discharge as necessary); the lack of groundwater in 

37 the caliche, sand and gravel layer above the Ogallala aquifer; the quarterly groundwater 

38 monitoring plan; permanent waste disposal off site; the proposed facility’s Spill Prevention 

39 Control and Countermeasure Plan; and the 9.1-m (30-ft) depth to groundwater 

40 (GL Environmental, 2010) at the proposed IIFP site, the NRC staff concludes that the impacts to 

41 groundwater quality from operations would be SMALL. 
 4-34 

1 4.1.2.6.3 Surface Water 

2 As discussed in Section 3.7.2, no permanent surface water or jurisdictional waters are present 

3 on the proposed IIFP site and, therefore, the operation of the proposed facility would not affect 

4 surface water. 

5 4.1.2.7 Ecological Resources 

6 No additional land beyond the approximately 16 ha (40 ac) footprint would be disturbed during 

7 operations. The remaining portion of the IIFP site is expected to be left undeveloped for the 

8 duration of the license. 

9 Maintenance practices such as the use of chemical herbicides and roadway maintenance would 

10 be implemented during plant operation (IIFP, 2009a). 

11 The tallest proposed building would be 21.3 m (70 ft) high and emission stacks would be less 

12 than 30.5 m (100 ft) tall (IIFP, 2009a); well under the 61 m (200 ft) threshold that requires lights 

13 for aviation safety (FAA, 1992). Security lighting and equipment would be directed downward to 

14 help to minimize light pollution and reduce the potential for adverse impacts to wildlife 

15 (IIFP, 2009a). This minimization of lights, which attract nocturnal insects and their predator 

16 species, and the low height of the structures, reduce the potential for adverse impacts on night17 migrating birds. 

18 No unique or critical habitats or threatened or endangered species occur on the site or in the 

19 vicinity. Commercially and recreationally important species would not be adversely affected by 

20 plant operations. The NRC staff finds that adverse impacts during operations to ecological 

21 resources would be SMALL. 

22 4.1.2.8 Socioeconomic Resources and Environmental Justice 

23 This section provides analyses of the socioeconomic impacts associated with operation of the 

24 proposed IIFP facility. Phase 1 operation would begin during the fourth quarter of 2013; after 

25 Phase 2 is completed, Phase 1 and Phase 2 operate concurrently. Wage and salary spending 

26 and expenditures associated with materials, equipment, and supplies would produce income 

27 and employment and local and State tax revenue, while the in migration of workers and their 

28 families into the area would affect the availability of housing, public utilities and community 

29 services such as education, fire protection, law enforcement and medical resources. 

30 Socioeconomic impacts of the proposed IIFP would occur within the two-county ROI (Lea and 

31 Eddy Counties, New Mexico), where the operations workforce will likely live and spend most of 

32 their incomes. 

33 These analyses are based on the peak number of workers (140) employed at the IIFP facility for 

34 Phase 1 operation (IIFP, 2011a). The location of the IIFP facility was selected in part because 

35 local colleges and universities have existing training programs in partnership with the nearby 

36 URENCO USA centrifuge facility. These institutions, particularly the New Mexico Junior 

37 College, have the capability and are committed to provide training to ensure a skilled nuclear 

38 workforce (IIFP, 2009a). The New Mexico Junior College Workforce Training Program is 

39 designed to offer training requested by area employers, including specialized training for the 

40 nuclear service industry. Enrollment in the Workforce Training Program has increased to over 

41 4,251 total trainees through 2009 (NMJC, 2011). Therefore, this analysis assumes that 

42 80 percent of the IIFP worker force would be filled by residents within the ROI. Table 4-19 
 4-35 

1 depicts the workforce in-migration, based on the assumption that 80 percent of the operation 

2 employees would be current ROI residents and that each in-migrating operation employee 

3 would move his family into the ROI. These projections are used throughout this analysis. 

4 Table 4-19. Assumptions for Workforce Characterization During Phase 1 Operation 

Workforce characterization 

Peak number of workers onsite during Phase 1 operation 1 140 

Workforce migration 

Percent of operation workforce migrating into ROI 20% 

Number of workers migrating into ROI during peak operation 2 28 

Families 

Percent of operation workers who bring families 2 100% 

Average New Mexico family size (2009) 3 3.23 

Number of operation workers who would move into ROI and bring families 2 28 

Number of In-migrating workers' family members 2 62 

Number of operation workers and family members migrating into ROI (new 

population in ROI) 2 90 

School-age children 

Number of school-age children per family 4 0.8 

Number of school-age children migrating into ROI 2 22 

5 Source: 

1 6 IIFP, 2011a 

2 7 For supporting analyses, see Appendix D 

3 8 USCB, 2010a 

4 9 BMI, 1981. This study is an analysis of nuclear construction workforces, however, it included information about 

10 nuclear plant non-construction workers [i.e., managers, engineers, supervisors, clerical, security, and medical 

11 personnel who were on the site during construction]. 

12 

13 4.1.2.8.1 Population 

14 As shown in Section 3.9.1.2, the population within the ROI was 112,938 in 2009. The IIFP 

15 Phase 1 operation would employ 140 people, of which 80 percent would be current ROI 

16 residents. The other 20 percent of the operations workforce (28 workers) and their families 

17 would migrate into the ROI (see Table 4-19). Using the 2009 New Mexico average family size 

18 of 3.23, the in-migration would result in 90 new residents (Table 4-19). An increase of 90 

19 residents would result in less than a 0.1 percent increase in the 2009 population of the ROI. 

20 4.1.2.8.2 Employment and Income 

21 Approximately 80 percent, or 112, of the IIFP Phase 1 operation positions (140 x 0.8 = 112 jobs) 

22 would be filled by people currently residing in the ROI (Table 4-19). Those 112 workers would 

23 represent 0.2 percent of the June 2010 ROI labor force. If all 112 of these jobs were filled by 

24 unemployed workers in the ROI, the unemployment rate would decrease by 0.2 percent. 

25 Approximately 20 percent of the IIFP Phase 1 operation positions (28 jobs) would be filled by 

26 people migrating into the ROI from outside the region (Table 4-19). The in-migrating workers 

27 would represent 0.2 percent of the June 2010 labor force. 
 4-36 

1 The in-migration of 28 workers would create indirect jobs within the ROI because of the 

2 multiplier effect (described in Section 4.1.1.8.2). In this analysis, the NRC staff used the BEA 

3 direct effect employment multiplier for the “All Other Basic Inorganic Chemical Manufacturing” 

4 classification to estimate the number of indirect jobs that would be created as a result of the in5 migration of the project-related workers. Table 4-20 provides information about direct and 

6 indirect employment for Phase 1 operation. Indirect jobs are often non-technical, non7 professional positions in the retail and service sectors and would likely be filled by unemployed 

8 workers already residing in the ROI. The 51 indirect jobs represent 1.3 percent of the 

9 unemployed labor force in June 2010. 

10 Table 4-20. Direct and Indirect Employment during IIFP Phase 1 Operation 

Phase 1 operations workforce peak (Table 4-19) 140 

Number of Phase 1 operations workers who migrate into ROI (20 percent of 

operation workforce peak) (Table 4-19) 28 

Employment multiplier for Phase 1 operations workers (indirect portion only) 

(BEA, 2010) 1.8173 

Indirect jobs resulting from in-migrating Phase 1 operations workers (See 

Appendix D) 51 

11 

12 The regional economy would benefit from the capital investment expenditures and recurring 

13 costs associated with the operation of the IIFP facility. IIFP has provided estimates for some of 

14 these costs. The payroll associated with Phase 1 would be between $7,900,000 and 

15 $9,100,000 annually (IIFP, 2009a). IIFP employees and indirect workers would spend earnings 

16 on goods and services with the ROI. Additional costs associated with operations include 

17 replacement capital; waste disposal; insurance premiums and taxes; utilities; and maintenance 

18 materials and supplies. These expenditures would range from $17,315,000 to $23,727,000 

19 annually. 

20 The NRC staff finds that due to the size of the available workforce in the ROI, the effect of IIFP 

21 Phase 1 operations on employment and income within the ROI would be SMALL and beneficial. 

22 4.1.2.8.3 Taxes 

23 Phase 1 operations-related wages and purchases would generate several types of taxes, 

24 including corporate income taxes, individual income taxes, gross receipts taxes, and property 

25 taxes. Increased tax collections are viewed as a benefit to the State of New Mexico, Lea and 

26 Eddy Counties, the Hobbs Municipal School District, the New Mexico Junior College, the 

27 communities in Lea and Eddy Counties, and other locales where plant-related spending would 

28 occur. 

29 Income and Gross Receipts Taxes 

30 IIFP has estimated the income and gross receipts tax impacts of Phase 1 operation in 

31 Table 4-21. The NRC staff finds that the increase in tax revenues to the State and county would 

32 be SMALL and beneficial. 
 4-37 

1 Table 4-21. Estimated Gross Receipts and Income Tax Payments to New Mexico and 

Lea County for the Phase 1 Operation Period, 2009 Dollarsa 2 

New Mexico Lea County 

Gross Receipts Tax 

High Estimate $118,100,000 $8,800,000 

Low Estimate $87,100,000 $6,500,000 

NM Corporate Income Taxb

High Estimate $77,200,000 Nonec

Low Estimate $57,100,000 Nonec

3 Source: IIFP, 2011a 

a 4 Tax values based on 2009 tax rates 

b 5 Based on average annual earnings for the Phase 1 increment 

c 6 Allocation would be made to the State of New Mexico 

7 

8 In addition to IIFP’s corporate income and gross receipts tax payments, plant employees would 

9 pay State individual income and State and county gross receipts taxes. The NRC staff finds 

10 that these tax payments would have a SMALL, beneficial impact on New Mexico’s and the 

11 counties’ income tax revenues. Regional spending on goods and services by IIFP employees 

12 would generate gross receipts tax revenues for Lea and Eddy County municipalities, Lea and 

13 Eddy Counties, New Mexico, and other locales. The NRC staff finds that these additional tax 

14 revenues would create a SMALL, beneficial impact 

15 Property Taxes 

16 As stated in Sections 3.9.3, International Isotopes, Incorporated, the parent corporation of IIFP, 

17 has an IRB agreement with Lea County and is generally exempt from property taxes. However, 

18 two taxing entities are not part of the IRB agreement. For Phase 1 operation, IIFP would pay an 

19 amount in lieu of property tax to the Hobbs Municipal School District and to the New Mexico 

20 Junior College. Table 3-28 presents total revenue data for the Hobbs Municipal School District 

21 and the New Mexico Junior College, IIFP’s estimated average annual tax payments to those 

22 schools, and those payments as a percentage of the schools’ revenues. As shown in 

23 Table 3-28, the Hobbs Municipal School District’s total 2007-2008 revenues were about 

24 $71 million and the New Mexico Junior College’s total 2008-2009 revenues were about 

25 $37 million. IIFP’s payments would represent a very small percentage of the school district and 

26 college’s revenues. The NRC staff finds that the impact of the payment in lieu of taxes to each 

27 jurisdiction would be SMALL, and beneficial. 

28 Therefore, the NRC staff concludes that operation of the proposed IIFP facility would have a 

29 SMALL beneficial impact on tax revenues. 

30 4.1.2.8.4 Housing 

31 In 2008, about 46,971 housing units were in the ROI, and 5,823 of them were vacant 

32 (Section 3.9.4). The Phase 1 operation of the IIFP facility would result in an influx of 

33 approximately 28 workers (Table 4-19), all of whom would need housing. Housing the 28 

34 in-migrating workers would require 0.5 percent of the vacant housing units within the ROI. The 

35 in-migrating workers would not exhaust the existing housing inventory. 
 4-38 

1 Therefore, the NRC staff concludes that operation of the proposed IIFP facility on the existing 

2 housing inventory would be SMALL. 

3 4.1.2.8.5 Public Utilities 

4 Public Water 

5 All onsite potable, process, and fire water needed for the operation of the IIFP Phase 1 facility 

6 would be provided by no more than two wells installed in the Ogallala aquifer. The facility will 

7 not use public water (IIFP, 2011a). 

8 Phase 1 operation will result in 90 people migrating into the ROI (Section 4.1.2.8.1). These new 

9 residents would likely select housing within areas that rely on a public water supplier. The major 

10 public water suppliers serve approximately 88,643 people (Table 3-30) and most, if not all, have 

11 excess capacity. The 90 new residents would result in a 0.1 percent increase in customers who 

12 rely on the public water suppliers. The NRC staff finds that the impact of Phase 1 operations on 

13 public water supplies would be SMALL, because the excess capacity of water suppliers in the 

14 ROI is sufficient to support the in-migrating workforce. 

15 Public Wastewater 

16 The IIFP facility would not be connected to any public wastewater or sewage system (IIFP, 

17 2011a). The project will result in 90 people migrating into the ROI. These new residents would 

18 likely elect to reside within areas that rely on a public wastewater system. The major public 

19 wastewater treatment facilities serve approximately 78,917 people (Table 3-31) and have 

20 excess capacity. The 90 new residents would result in a 0.1 percent increase in customers who 

21 rely on the public wastewater systems. Therefore, because the increase in households is a 

22 small percentage of the existing public wastewater users, and the public wastewater facilities 

23 have excess capacity, the NRC staff concludes that impact of the proposed IIFP operation on 

24 public wastewater treatment systems would be SMALL. 

25 4.1.2.8.6 Community Services 

26 Education 

27 During the 2008 school year, there were 8 public school districts, containing 64 schools 

28 educating 22,847 students in the ROI (Section 3.9.6.1). The operation of the IIFP facility would 

29 result in an influx of approximately 28 employees and their families (Table 4-18). Each in30 migrating family is estimated to have 0.8 school aged children (Table 4-18); therefore, 

31 22 additional children would be eligible for public school as a result of Phase 1 operation 

32 (Table 4-18). The new student enrollment would represent an increase of 0.1 percent of the 

33 2008 enrollment. Therefore, the NRC staff concludes that the impact of the proposed Phase 1 

34 operation on education would be SMALL. 

35 Fire Protection 

36 As discussed in Section 4.1.2.8.1, the population increase in the ROI associated with the 

37 operation of the IIFP Phase 1 facility would be less than 0.1 percent and would result in filling 

38 0.5 percent of the available housing. Therefore, there would not be a detectable increase in the 

39 demand for fire protection. Existing fire protection personnel, facilities, and equipment would be 
 4-39 

1 sufficient to support the population increase. Therefore, the NRC staff concludes that impact of 

2 operation of the proposed facility on fire protection would be SMALL. 

3 Law Enforcement 

4 The in migrating workforce would increase the ROI population less than 0.1 percent 

5 (Section 4.2.1.8) and would not affect the ability of existing law enforcement services to meet 

6 the needs of the population. Existing law enforcement personnel, facilities, and equipment 

7 would be sufficient to support the population increase; therefore, the NRC staff finds that the 

8 impact of Phase 1 operation of would be SMALL. 

9 Hospitals and Physicians 

10 An ROI population increase of less than 0.1 percent (Section 4.2.1.8) would not measurably 

11 increase the demand for hospital and physician services. The NRC staff finds that the impact of 

12 operation on hospitals and physician services would be SMALL. 

13 4.1.2.8.7 Environmental Justice 

14 The primary environmental resources that could be affected by the operation of the proposed 

15 IIFP facility are soil, groundwater quality, groundwater quantity, air quality, ecology, 

16 socioeconomics and human health. Section 3.9.1.2 defines and identifies the minority and low17 income populations within the 80 km (50-mi) radius of the proposed IIFP facility. There are 

18 96 block groups that fall completely or partially within the 80 km (50-mi) radius. Of the 96 block 

19 groups, one has a significant African American population, 15 have significant “Some Other 

20 Races” populations, 32 have significant Hispanic populations, and 10 have significant low21 income populations. Figures 3-22, 3-23, 3-24 and 3-25 locate these block groups. The 

22 following is a summary of the impacts on the resources area and addresses whether minority or 

23 low-income populations would experience disproportionately high and adverse impacts from the 

24 IIFP Phase 1 operation: 

25 • Land Use – The NRC staff finds that operation of the facility would not affect land use 

26 beyond those impacts attributed to construction. Accordingly, the NRC staff finds that 

27 impacts to land use would be SMALL. 

28 • Soils – The NRC staff finds that impact to soils during IIFP operation would be SMALL. 

29 • Groundwater quality – During IIFP operation, stormwater from the site would be 

30 collected in two runoff retention/evaporation basins. No wastes from facility process 

31 systems would be discharged to stormwater. Furthermore, any stormwater discharges 

32 would be controlled by a Stormwater Pollution Prevention Plan. Treated process water 

33 would be used for irrigation at the facility but is not expected to migrate to groundwater. 

34 The NRC staff finds that effects to groundwater quality would be SMALL, localized, and 

35 temporary. 

36 • Groundwater quantity – No municipal water line runs near the proposed IIFP facility. No 

37 more than two groundwater wells would supply all of the water for the facility. The 

38 operation of the facility would require relatively low volumes of water because it would 

39 recycle process water and re-circulate cooling water; groundwater use is estimated to be 

40 less than 37,854 (10,000 gal) per day. The proposed IIFP site has been included in Lea 

41 County’s 40 Year Water Development Plan and would use approximately 5 percent of 

42 the estimates 40-year planning period demand. The NRC staff finds that it is highly 
 4-40 

1 unlikely that the two wells would ever exceed the Lea County UWB drawdown limit. The 

2 NRC staff finds that impacts to groundwater quantity during operation would be SMALL. 

3 • Air quality - The estimated criteria pollutant emissions from Phase 1 operation represent 

4 a very small fraction of the current emissions in Lea County. Pollutant emissions, 

5 including nonradioactive process effluents, would not change the existing ambient air 

6 quality in the vicinity of the IIFP facility. The NRC staff finds that the air quality impacts 

7 would be SMALL to MODERATE. 

8 • Public and Occupational Health - Operation of the IIFP facility would require shipment of 

9 DUF6 cylinders to and from the facility and hazardous, mixed and LLW to disposal 

10 facilities. The transportation risk associated with IIFP transportation operations is 0.03 

11 additional latent cancer fatalities (LCF) per year. The NRC staff finds that impacts from 

12 the proposed action on Public and Occupational health would be SMALL. 

13 • Ecology – More than 90 percent of the IIFP site would be undisturbed by operations, no 

14 threatened or endangered species or critical or unique habitats occur on the site, and the 

15 site does not provide extensive habitat for any commercial or recreational species. 

16 Therefore, the NRC staff finds that operation of the IIFP facility would have a SMALL 

17 effect on ecological resources. 

18 • Socioeconomics – Phase 1 IIFP operations would employ 140 employees, 28 of whom 

19 would migrate into the ROI with their families. The in-migrating workers and their 

20 families would increase the population within the ROI by 0.1 percent. The NRC staff 

21 concludes that these workers and their families would have a SMALL effect on housing, 

22 community services, and public utilities and a SMALL and beneficial effect on 

23 employment and taxes. 

24 The NRC staff finds that the impacts of IIFP operation on the resources evaluated would be 

25 SMALL for most resources and SMALL to MODERATE for air quality and in some cases, 

26 beneficial. Furthermore, the nearest minority or low-income population is 22.5 km (14 mi) from 

27 the proposed facility. Therefore, because all resource area impacts are SMALL and the 

28 identified minority and low income populations are not in close proximity to the proposed site, 

29 the NRC staff finds that impacts would not be considered disproportionately high and adverse 

30 impacts to any population, including low-income or minority populations. 

31 4.1.2.9 Traffic and Transportation 

32 4.1.2.9.1 Traffic 

33 Operations impacts would occur from commuting personnel and the transport of nonradiological 

34 and radiological materials to and from the proposed IIFP site. The impacts from each are 

35 discussed below. 

36 The principal highway routes that would handle this traffic include NM 483, which borders the 

37 site to the west, and US 62/180, which provides an east-west route to the nearest population 

38 centers. All traffic would access the site via NM 483, and most traffic would use US 62/180 to 

39 NM 483 to access the site. Some portion of the workforce may access the site from the north, 

40 using NM 83 to access NM 483 north of the site. At the junction of NM 483 and US 62/180, 

41 traffic would go east to Hobbs, Eunice and other Lea County municipalities or southwest to 

42 Eddy County. After the intersection of NM 483 and US 62/180 traffic associated with the site 

43 would be increasingly dispersed. 
 4-41 

1 IIFP operations would use 140 workers working three shifts per day (IIFP, 2011a) or 47 people 

2 per shift. Therefore, if each employee commutes alone, there would be an increase of 

3 94 vehicles (47 ending a shift plus 47 starting a shift) on NM 483 for each shift change. 

4 Additionally, IIFP estimated 10 delivery or waste disposal trucks each day. 

5 The Highway Capacity Manual 2000 (TRB 2000) indicates that the capacity of a two-lane 

6 highway is 1,700 passenger cars per hour for a single direction and 3,400 passenger cars per 

7 hour for both directions. The AADT on NM 483, a two-lane highway, at Arkansas Junction in 

8 2008 was 955 vehicles per day (NMDOT, 2009). If all the vehicles on NM 483 in one day used 

9 the road in a single hour, including the anticipated 10 truck trips per day (IIFP, 2011a), and if 

10 two operations workforce shifts used the road to the site during that same hour, a maximum of 

11 1,059 vehicles would be on the road. This is less than the design capacity of a two-lane 

12 highway. The impact of traffic increases due to facility operations on US 62/180, which is a 

13 four-lane highway, would be smaller than the impact on NM 483. Therefore, the NRC staff 

14 concludes that impacts to traffic from operations would be SMALL. 

15 Using the same assumptions for operations as for construction, 140 operation employees would 

16 commute approximately 2,300,000 km (1,400,000 mi) per year of facility operation. The New 

17 Mexico 2010 vehicle accident rates result in 51.73 injuries and 1.73 fatal accidents per 

18 160 million vehicle km (100 million vehicle mi) traveled (UNM, 2010). Based on these rates, 

19 statistically there would be one injury (risk of less than 0.7 injury crashes) per year and no 

20 fatalities (risk of less than 0.02 fatal crashes) per year due to the Phase 1 operations traffic. 

21 The transportation of nonradiological materials would include the delivery of routine supplies 

22 and equipment and the removal of nonradiological wastes (including hazardous wastes). The 

23 transport of hazardous waste is subject to EPA and DOT regulations. Nonradiological deliveries 

24 and waste removal would require an estimated 1,950 truck round-trips per year, or 

25 approximately 8 round-trips per day (IIFP, 2011a). As with the commuter traffic, the NRC staff 

26 finds that this increase in traffic volume would have a SMALL impact on the current traffic and 

27 the carrying capacity of the affected roads would not be challenged. 

28 Assuming a round-trip distance of 113 km (70 mi), the round-trip distance to the furthest 

29 nonradiological waste disposal facility likely to be used by IIFP, these trucks would travel 

30 approximately 220,480 km (137,000 mi) per year of operation, therefore, no injuries (risk <0.07), 

31 and no fatalities (risk <0.002) would be expected per year of Phase 1 operation. The NRC staff 

32 concludes that impacts from accidents involving the shipment of nonradiological materials would 

33 be SMALL. 

34 4.1.2.9.2 Incident-free Radiological Transportation 

35 Operation of the proposed IIFP facility would require shipment of full DUF6 cylinders from 

36 commercial enrichment facilities, empty DUF6 cylinders back to the commercial enrichment 

37 facilities, DUO2 to waste disposal facilities, and other process and miscellaneous LLW to waste 

38 disposal facilities. Data for the analysis came from IIFP (IIFP 2011a; IIFP, 2011b) unless 

39 specified otherwise. More detail on the analysis can be found in Appendix E. 

40 Full DUF6 Cylinders: The NRC staff selected all current or proposed U.S. commercial 

41 enrichment facilities as representative origins for shipments of DUF6. These are (1) URENCO 

42 USA, just east of Eunice, New Mexico, (2) the GE-Hitachi Global Laser Enrichment Facility 

43 north of Wilmington, North Carolina, and (3) the AREVA Eagle Rock Enrichment Facility west of 

44 Idaho Falls, Idaho. The cylinders would be shipped one per 18-wheel truck. The radiation dose 
 4-42 

1 rate at 1 m (3.28 ft) from a cylinder is 0.0046 mSv per hour (0.46 mrem per hour) (Biwer et al., 

2 2001). There would be 293 shipments per year of full DUF6 cylinders for Phase 1 operations. 

3 Empty DUF6 Cylinders: Although it is possible that some cylinders would not be shipped back 

4 to their origin, NRC staff has assumed, for purposes of analysis, that all cylinders would be 

5 returned. In the event that cylinders are not returned, they could be disposed empty as LLW or 

6 filled with DUO2 and disposed as LLW. The returned cylinders would have a heel of less than 

7 23 kg (50 lb) and, thus, contain radioactive material. The cylinders are conservatively assumed 

8 to be shipped one per truck, consistent with IIFP data; however, two per truck is a likely 

9 scenario. Radiation dose rates from empty cylinders are slightly higher than from full cylinders 

10 due to the concentration of uranium daughter products and loss of self-shielding. The estimated 

11 radiation dose rate 1 m (3.28 ft) from an empty cylinder is 0.01 mSv per hour (1 mrem per hour). 

12 Conservatively, there would be 293 shipments per year of empty cylinders. 

13 DUO2 Waste: The DUO2 is assumed to be waste and not sold. It would be packaged into 

14 55-gallon drums and loaded 40 per truck (subject to weight limitations). Shipment destinations 

15 selected for analysis are the EnergySolutions Clive, Utah facility and the WCS facility on the 

16 Texas-New Mexico border west of Andrews, Texas (immediately east of the URENCO USA 

17 facility). Less probable destinations, such as the U.S. Ecology Washington disposal facility on 

18 the Hanford Site near Richland, Washington and the Nevada National Security Site, are 

19 represented by these analyses. The radiation dose rate 1 m (3.28 ft) from a drum would be 

approximately 6 x 10-4 20 mSv per hour (0.06 mrem per hour). IIFP estimates that there would be 

21 as many as 155 DUO2 waste shipments per year. 

22 Process and Miscellaneous LLW: This volume of LLW would be small compared to the DUO2

23 waste. The radioactivity in most of this waste would likely be less concentrated than the DUO2

24 waste. There would be 31 shipments per year, each with 40 55-gal drums. The dose rate is 

conservatively selected to be the same as the DUO2 shipments, 6 x 10-4 25 mSv per hour 

26 (0.06 mrem per hour). 

27 NRC staff used the TRAGIS (Johnson and Michelhaugh, 2003) transportation routing computer 

28 modeling code and the RADTRAN5 (Neuhauser and Kanipe, 2003) transportation risk 

29 assessment computer modeling code to calculate radiological impacts (collective dose) to 

30 members of the public living near the transportation route, drivers and passengers sharing the 

31 highways, persons at fueling or rest stops, the truck drivers, and package handlers. Results of 

32 that analysis are provided in Table 4-22. 

33 Assuming a scenario in which DUF6 shipped from the enrichment facility results in the greatest 

34 collective dose and DUO2 waste shipped to the disposal facility results in the greatest collective 

35 dose, and summing for all receptors (Appendix E), one arrives at 0.18 person-sievert per year 

36 (18 person-rem per year). This is for receipt and return of cylinders to the GLE facility in 

37 Wilmington, North Carolina and disposal of low-level waste at the EnergySolutions Clive, Utah 

38 facility. Multiplying the collective dose by the Interagency Steering Committee on Radiation 

Standards conversion factor of 6 × 10-4 39 latent cancer fatalities (LCFs) per person-rem (ISCORS, 

40 2002), estimates the transportation-related latent cancer fatalities for one year of incident-free 

41 exposure as 0.01 LCF. 

42 The Centers for Disease Control and Prevention (CDC, 2010) estimated the age-adjusted 

43 cancer death rate in the U.S. was 178.4 deaths per 100,000 people in 2007. Similarly, 

44 23.2 percent (23,200 per 100,000) of all deaths in the U.S. in 2007 were cancer related. 

45 Although these results are from two different studies and difficult to compare, both studies show 
4-43 

Table 4-22. Annual Collective Doses to Various Receptors from Radiological Transportation 1 

Description 

General Public Drivers and Passengers Persons at Stops Truck Drivers Package Handlers 

PersonSv Person- Rem Person- Sv Person- Rem Person- Sv Person- Rem Person- Sv Person- Rem Person- Sv Person- Rem 

Full DUF6 cylinders 

from URENCO USA 

2.3 x 10-5 2.3 x 10-3 2.6 x 10-4 0.02.6 a a 4.3 x 10-4 0.043 3.9 x 10-3 0.39 

Full DUF6 cylinders 

from GLE Facility 

6.8 x 10-3 0.68 0.07 4.7 0.075 7.5 0.029 2.9 3.9 x 10-3 0.39 

Full DUF6 cylinders 

from AREVA Eagle Rock 

3.9 x 10-3 0.39 0.039 3.9 0.075 7.5 0.026 2.6 3.9 x 10-3 0.3 

Empty DUF6 cylinders 

to URENCO 

5.1 x 10-5 5.1 x 10-3 5.6 x 10-4 0.056 a a 9.3 x 10-4 0.093 8.4 x 10-3 0.84 

Empty DUF6 cylinders 

to GLE Facility 

0.015 1.5 0.10 10 0.16 16 0.06.3 6.3 8.4 x 10-3 0.84 

Empty DUF6 cylinders 

to AREVA Eagle Rock 

8.5 x 10-3 0.85 0.084 8.4 0.16 16 0.056 5.6 8.4 x 10-3 0.84 

DUO2 and 

Miscellaneous LLW to EnergySolutions

3.0 x 10-4 0.03 3.3 x 10-3 0.33 5.3 x 10-3 0.53 2.0 x 10-3 0.20 5.8 x 10-3 0.5 

DUO2 and 

Miscellaneous LLW to Waste Control Specialists 

2.0 x 10-6 2.0 x 10-4 2.1 x 10-5 2.1 x 10-3 a a 3.6 x 10-5 3.6 x 10-3 5.8 x 10-3 0.5 

Source: See Appendix E 2 a A stop was not assumed because the route was short 3 

4 
 4-44 

10 CFR 20 Exposure Limits

The NRC exposure limits place 

annual restrictions on the total 

dose equivalent exposure (1 mSv 

[100 mrem]), which includes 

external plus internal radiation 

exposures, and the dose 

equivalent rate (0.02 mSv [2 

mrem]) in any 1 hour in 

unrestricted areas that are 

accessible by members of the 

public who are not employees, but 

who may be present during the 

year at the facility. 

Source: 10 CFR 20.1301 

1 that cancer fatalities are significant in normal life. Given these cancer fatality rates, the addition 

2 of 0.01 LCF from the proposed action is considered by NRC staff to be a SMALL impact. While 

3 mitigation measures are not required, IIFP would be required by NRC regulation 10 CFR 20 to 

4 maintain all radiation doses As Low As Reasonably Achievable (ALARA). 

5 Estimates of radiological exposure to the workforce and public from facility operations other than 

6 radiological transport are discussed in Section 4.1.2.12. 

7 4.1.2.10 Noise Impacts 

8 As discussed in Section 3.11, noise from the operation of the proposed facility would be 

9 minimal, occur mostly inside the buildings, and be attenuated by distance. The proposed facility 

10 is in a relatively remote location, surrounded by other industrial facilities, and far from lands 

11 uses that could be adversely affected by increases in noise levels. Noise at the nearest 

12 residences and recreational areas would not increase due to operation of the proposed IIFP 

13 facility. Therefore, the NRC staff concludes that impacts from noise of operations would be 

14 SMALL. 

15 4.1.2.11 Public and Occupational Health Impacts 

16 Normal operations at the proposed IIFP facility have the potential to impact the health of 

17 workers and the public due to exposures from permitted chemical and radiological gaseous 

18 emissions and liquid effluents. Additionally, workers could be impacted from direct radiation 

19 exposures and occupational hazards. This section discusses these potential impacts. Although 

20 normal operations at the proposed IIFP facility create the potential for radiological and 

21 nonradiological impacts, plant design would incorporate features to minimize gaseous and liquid 

22 effluent releases and to keep them well below regulatory limits. These features include the 

23 following (IIFP, 2011a): 

24 • DUF6 cylinders would be moved only when cool and when DUF6 is in solid form, which 

25 minimizes the risk of inadvertent release due to mishandling. 

26 • Process off-gas from DUF6 purification and other 

27 operations would be solidified to reclaim as much 

28 DUF6 as possible. Remaining gases pass through 

29 high-efficiency filters and chemical absorbers, which 

30 remove HF and uranium compounds. 

31 • Liquid and solid waste handling systems and 

32 techniques would be used to control wastes and 

33 effluent concentrations. 

34 • Gaseous emissions would pass through pre-filters, 

35 high efficiency filters, and carbon filters, all of which 

36 greatly reduce the radioactivity in the final 

37 discharged emission to very low concentrations. 

38 • Uranium-bearing liquid waste would be routed to the 

39 Decontamination Building for removal of uranium 

40 and the treated water would be evaporated or 

41 reused in the Decontamination Building. 
 4-45 

1 • Effluent paths would be monitored and sampled to assure compliance with regulatory 

2 discharge limits. 

3 Radiological Impacts 

4 The general public could be impacted by radiation and radioactive material from the IIFP facility 

5 via controlled releases of gas associated with the uranium process lines during routine 

6 operations and from decontamination and maintenance of equipment, or direct radiation 

7 exposure associated with transportation and storage of DUF6 cylinders and wastes. 

8 The radiation exposure limits for the general public have been established by the NRC in 

9 10 CFR 20. Routine operations would be conducted to ensure that public exposure at off-site 

10 locations would be within these limits. Annual exposure to the public would be maintained 

11 \ALARA through effluent controls and monitoring. 

12 The potential radiological impacts to the public from operations at the proposed IIFP facility are 

13 those associated with chronic exposure to low levels of radiation and not the immediate health 

14 effects associated with acute radiation exposure. The major sources of potential radiation 

15 exposure (chronic or acute) are the gaseous discharges from the plant scrubber systems for the 

16 DUF4 and fluorine extraction processes and the dust collector scrubber system. It is estimated 

17 that the total amount of uranium released to the air from the proposed IIFP facility would be less 

18 than 0.5 kg (1.1 lb) per year. Due to the low volume of contaminated liquid waste anticipated by 

19 the applicant, no liquid effluent discharges are expected to contain radiological waste. 

20 Therefore, there would be no dose pathway and no significant radiological impact to the public 

21 or the environment from liquid effluent discharges. The radiological impacts associated with 

22 direct radiation from indoor operations are not expected to be a significant contributor to dose to 

23 the public because the low-energy gamma-rays associated with the uranium would be absorbed 

24 almost completely by the process lines, equipment, cylinders, and building structures (IIFP, 

25 2011a). Routine radiological gaseous releases from the proposed IIFP facility are listed in 

26 Table 4-23. 

27 Table 4-23. Estimated and Bounding Radiological Releases from the Stacks 

Radionuclide DUF6 to DUF4 Stack SiF4 and BF3 Production Stack 

kBq/yr Ci/yr kBq/yr Ci/yr 

Estimated Releases 

234U 461 1.25 x 10-5

 42.2 1.14 x 10-6

235U 44.5 1.20 x 10-6

 4.08 1.10 x 10-7 238U 3,500 9.46 x 10-5 321 8.66 x 10-6

Total 21,600 5.83 x 10-4 9,490 2.56 x 10-4

Bounding Releases 

234U 922 2.49 x 10-5

 84.5 2.28 x 10-6

235U 89.1 2.41 x 10-6

 8.16 2.21 x 10-7

238U 7,000 1.89 x 10-4 641 1.73 x 10-5

Total 8,010 2.16 x 10-4 734 1.98 x 10-5

28 Source: IIFP, 2011a 

kBq = kilobecquerel (2.7 X 10-7 29 curies) 

30 
 4-46 

Committed Effective Dose 

Equivalent (CEDE)

Committed effective dose 

equivalent is the sum of the 

products of the weighting factors 

applicable to each of the body 

organs or tissues that are 

irradiated and the committed dose 

equivalent to these organs or 

tissues. 

Source: 10 CFR 20.1003. 

Total Effective Dose Equivalent 

(TEDE)

Total effective dose equivalent is 

the sum of the effective dose 

equivalent or the deep-dose 

equivalent (for external 

exposures) and the committed 

effective dose equivalent (for 

internal exposures).

Source: 10 CFR 20.1003. 

1 There are three primary exposure pathways associated with plant effluent: inhalation; direct 

2 radiation due to deposited radioactivity on the ground surface (“ground plane exposure”); and 

3 ingestion of contaminated food products. Of these three exposure pathways, inhalation 

4 exposures are expected to be the predominant pathways at site boundary locations and also at 

5 off-site locations that are relatively close to the site boundary. Because airborne concentrations 

6 decrease with the distance from the discharge point, for gaseous releases from the proposed 

7 IIFP facility, the highest off-site airborne concentrations (and, hence, the greatest radiological 

8 impacts) are expected at locations near the site boundary. Beyond those locations, the 

9 concentrations of airborne radioactive material would decrease continuously because of 

10 dispersion of the material and depletion processes. 

11 The critical populations for determining dose impacts include the resident nearest to the 

12 proposed IIFP facility (at the northwest boundary) and the maximally exposed individual (MEI). 

13 The MEI is a hypothetical person living at the point of highest projected total uranium 

14 concentrations. The impact due to gaseous releases was evaluated for the dose from the three 

15 primary exposure pathways identified above. Because there is no pathway for contamination of 

16 drinking water, no radiological contamination of drinking water was considered in the analysis. 

17 The analysis included dose equivalent assessments for four age groups (i.e., adults, teens, 

18 children, and infants) for these pathways. 

19 IIFP calculated doses using GENII (version 2.08), which 

20 is a dose assessment model developed for EPA for 

21 calculating radiation dose and risk from radionuclides 

22 released to the environment. Dose equivalents for the 

23 MEI and the nearest resident due to gaseous releases 

24 were calculated by pathway for the total body in adults, 

25 teens, children, and infants, and are presented in Tables 

26 4-24 and 4-25, respectively. For the MEI, the highest 

27 committed effective dose equivalent (CEDE) from the 

28 proposed IIFP facility emissions was calculated to be 

1.40 x 10-7 Sv (1.40 x 10-5 29 rem) per year. For the adult 

30 fulltime resident nearest to the facility, the highest CEDE 

from the IIFP facility was calculated to be 9.46 x 10-8 31 Sv 

(9.46 x 10-6 32 rem) per year. 

33 In its environmental report (IIFP, 2009a), IIFP calculated 

34 direct dose rates for the MEI and the nearest resident. 

35 These doses rates were extremely small (e.g., less than 

1.04 x 10-2 36 mSv per year [1.04 mrem per year]). The 

37 CEDE and the direct dose equivalent were totaled to 

38 determine the total effective dose equivalent (TEDE) for 

39 the MEI. The highest TEDE was determined to be 0.21 

40 mSv per year (20.8 mrem per year), which is 

41 approximately one-fifth of the NRC exposure limit of 1 

42 mSv (100 mrem). Doses for public receptors at other 

43 sites of interest (e.g., schools and hospitals) would be 

44 lower than those of the MEI because the airborne 

45 concentrations of uranium would be lower at these more distant locations. Therefore, NRC staff 

46 anticipates that radiological impacts to off-site receptors from routine combined effluent releases 

47 and direct radiation would to be SMALL. 
 4-47 

1 Table 4-24. Annual and Committed Dose Equivalents for Exposures to the MEI from 

2 Gaseous Effluents 

Source Units Adult EDE Teen EDE Child EDE Infant EDE 

Cloud Immersion 

Sv 5.77 x 10-16 5.77 x 10-16 5.77 x 10-16 5.77 x 10-16

rem 5.77 x 10-14 5.77 x 10-14 5.77 x 10-14 5.77 x 10-14

Inhalation 

Sv 3.06 x 10-8 3.67 x 10-8 6.19 x 10-8 1.30 x 10-7

rem 3.06 x 10-6 3.76 x 10-6 6.19 x 10-6 1.30 x 10-5

Ingestion 

Sv 1.30 x 10-9 1.96 x 10-9 2.35 x 10-9 9.79 x 10-9

rem 1.30 x 10-7 1.96 x 10-7 2.35 x 10-7 9.79 x 10-7

Ground Plane 

Exposure 

Sv 2.08 x 10-10 2.08 x 10-10 2.08 x 10-10 2.08 x 10-10

rem 2.08 x 10-8 2.08 x 10-8 2.08 x 10-8 2.08 x 10-8

Total Dose 

Sv 3.21 x 10-8 3.88 x 10-8 6.45 x 10-8 1.40 x 10-7

rem 3.21 x 10-6 3.88 x 10-6 6.45 x 10-6 1.40 x 10-5

3 Source: IIFP, 2011a 

4 

5 Table 4-25. Annual and Committed Dose Equivalents for Exposure to the Nearest 

6 Resident from Gaseous Effluents 

Source Units Adult EDE Teen EDE Child EDE Infant EDE 

Cloud Immersion 

Sv 4.40 x 10-17 4.40 x 10-17 4.40 x 10-17 4.40 x 10-17

rem 4.40 x 10-15 4.40 x 10-15 4.40 x 10-15 4.40 x 10-15

Inhalation 

Sv 2.20 x 10-8 2.65 x 10-8 4.44 x 10-8 9.38 x 10-6

rem 2.20 x 10-6 2.65 x 10-6 4.44 x 10-6 9.38 x 10-6

Ingestion 

Sv 9.91 x 10-11 1.49 x 10-10 1.79 x 10-10 7.43 x 10-10

rem 9.91 x 10-9 1.49 x 10-8 1.79 x 10-8 7.43 x 10-8

Ground Plane 

Exposure 

Sv 1.59 x 10-11 1.59 x 10-11 1.59 x 10-11 1.59 x 10-11

rem 1.59 x 10-9 1.59 x 10-9 1.59 x 10-9 1.59 x 10-9

Total Dose 

Sv 2.21 x 10-8 2.66 x 10-8 4.46 x 10-8 9.46 x 10-8

rem 2.21 x 10-6 2.66 x 10-6 4.46 x 10-6 9.46 x 10-6

7 Source: IIFP, 2011a 

8 

9 Potential doses to the total population within an 80-km (50-mi) radius of the proposed IIFP 

10 facility were also determined. The local area population distribution was derived from U.S. 

11 Census Bureau 2000 data for counties in New Mexico and Texas (IIFP, 2011a) that fall all or in 

12 part within the 80-km (50-mi) radius of the proposed IIFP site. A standard 16-sector compass 

13 rose was centered on the IIFP site and divided into annular rings out to a distance of 80 km 

14 (50 mi) (see Figure 4-1). Using census data, significant population groups, typically towns or 

15 cities, within the 80-km (50-mi) area were identified in those sectors. Table 4-26 and Table 4-27 

16 present the total population doses expected in units of person-sieverts and person-rem, 
 4-48 

1 Figure 4-1. 50-Mile Sectors 

2 
4-49 

Table 4-26. Collective Dose Equivalents to All Ages Population (person-Sv) (gas release pathways) 1 

Vector 0-1 mi 1-2 mi 2-3 mi 3-4 mi 4-5 mi 5-10 mi 10-20mi 20-30 mi 30-40 mi 40-50 mi Total 

E 0.00 0.00 0.00 0.00 0.00 0.00 1.82 x 10-4 4.03 x 10-6 9.53 x 10-6 5.15 x 10-6 2.01 x 10-4ENE 0.00 0.00 0.00 0.00 0.00 3.72 x 10-5 4.08 x 10-5 0.00 1.16 x 10-5 4.77 x 10-5 9.44 x 10-5NE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.25 x 10-6 3.25 x 10-6NNE 0.00 0.00 0.00 0.00 0.00 0.00 6.54 x 10-6 0.00 0.00 0.00 6.54 x 10-6N 0.00 0.00 0.00 0.00 0.00 0.00 9.55 x 10-5 3.56 x 10-6 3.56 x 10-6 0.00 1.03 x 10-4NNW 0.00 0.00 0.00 0.00 0.00 0.00 9.89 x 10-6 0.00 0.00 0.00 9.89 x 10-6NW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 WNW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 W 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 WSW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 SW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 SSW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 S 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.28 x 10-6 3.28 x 10-6SSE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 8.68 x 10-6 0.00 0.00 8.68 x 10-6SE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 ESE 0.00 0.00 0.00 0.00 0.00 0.00 4.43 x 10-6 0.00 0.00 6.05 x 10-7 5.03 x 10-6Ring 0.00 0.00 0.00 0.00 0.00 3.72 x 10-5 3.39 x 10-4 1.63 x 10-5 2.47 x 10-5 1.71 x 10-5 4.34 x 10-4Cumulative 0.00 0.00 0.00 0.00 0.00 3.72 x 10-5 3.76 x 10-4 3.92 x 10-4 4.17 x 10-4 4.34 x 10-4Source: IIFP, 2011a 2 

3 
4-50 

Table 4-27. Collective Dose Equivalents to All Ages Population (person-rem) (gas release pathways). 1 

Vector 0-1 mi 1-2 mi 2-3 mi 3-4 mi 4-5 mi 5-10 mi 10-20 mi 20-30 mi 30-40 mi 40-50 mi Total 

E 0.00 0.00 0.00 0.00 0.00 0.00 0.0182 4.03 x 10-4 9.53 x 10-4 5.15 x 10-4 0.0201 ENE 0.00 0.00 0.00 0.00 0.00 3.72 x 10-3 4.08 x 10-3 0.00 1.16 x 10-3 4.77 x 10-4 9.44 x 10-3NE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.25 x 10-4 3.25 x 10-4NNE 0.00 0.00 0.00 0.00 0.00 0.00 6.54 x 10-4 0.00 0.00 0.00 6.54 x 10-4N 0.00 0.00 0.00 0.00 0.00 0.00 9.55 x 10-3 3.56 x 10-4 3.56 x 10-4 0.00 0.0103 NNW 0.00 0.00 0.00 0.00 0.00 0.00 9.89 x 10-4 0.00 0.00 0.00 9.89 x 10-4NW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 WNW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 W 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 WSW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 SW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 SSW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 S 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.28 x 10-4 3.28 x 10-4SSE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 8.68 x 10-4 0.00 0.00 8.68 x 10-4SE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 ESE 0.00 0.00 0.00 0.00 0.00 0.00 4.43 x 10-4 0.00 0.00 6.05 x 10-7 5.03 x 10-4Ring 0.00 0.00 0.00 0.00 0.00 3.72 x 10-3 0.0339 1.63 x 10-3 2.47 x 10-3 1.71 x 10-3 0.0434 Cumulative 0.00 0.00 0.00 0.00 0.00 3.72 x 10-3 0.0376 0.0376 0.0417 0.0434 Source: IIFP, 2011a 2 

3 
 4-51 

respectively. As shown on those tables, the total population dose would be 4.34 x 10-4 1 personSv/yr (4.34 x 10-2 2 person-rem/yr). Multiplying the total population dose by the Interagency 

Steering Committee on Radiation Standards conversion factor of 6 × 10-4 3 LCFs per person-rem 

(ISCORS, 2002), yields approximately 2.6 x 10-5 4 LCFs expected in the 80-km (50-mi) population 

5 for every for one year of operation of the IIFP facility. To put this population dose into 

6 perspective, based on statistics, the proposed IIFP facility would need to operate for 

7 approximately 38,400 years to produce 1 LCF in the 80-km (50-mi) population. Therefore, NRC 

8 staff anticipates that radiological impacts to the 80-km (50-mi) population would be SMALL. 

9 Workers at the IIFP plant would be subject to higher potential exposures than members of the 

10 public because they would be involved directly with handling uranium cylinders, uranium 

11 processes, and decontamination and maintenance of equipment. During routine operations, 

12 workers at the plant potentially could be exposed to radiation from uranium via inhalation of 

13 airborne particles and direct exposure to equipment and components containing uranic 

14 materials. The radiation protection program at the IIFP facility would require routine radiation 

15 surveys and air sampling to ensure that worker exposures are maintained ALARA. Exposure16 monitoring techniques at the plant would include personal dosimeters worn by workers, 

17 personnel breathing zone air sampling, and annual whole-body counting. 

18 Potential doses to workers were estimated based on analyses conducted for similar DUF6

19 deconversion operations at the DOE Piketon (Portsmouth) Ohio and Paducah, Kentucky 

20 facilities. For those facilities, the TEDE for workers was conservatively estimated to be about 

21 0.75 mSv per year (75 mrem per year) for involved workers in the deconversion facility. The 

22 average TEDE for workers at the cylinder yards was estimated to range from 4.3 mSv per year 

23 (430 mrem per year) to 6.9 mSv per year (690 mrem per year) (DOE, 2004a; DOE, 2004b). 

24 These doses would be well below the regulatory limit of 50 mSv (5 rem) codified in 10 CFR 

25 20.1201. 

26 Annual radiation exposure for an employee would be controlled, monitored, and maintained 

27 ALARA through the Radiation Protection Program at the IIFP plant. The Radiation Protection 

28 Program would comply with all applicable NRC requirements established in 10 CFR 20, 

29 Subpart B. The radiation exposure of involved workers is estimated to be well within public 

30 health standards and the NRC staff finds that radiological impacts to facility workers would be 

31 SMALL. Section 4.1.2.9.2 discusses the potential impacts to workers associated with 

32 radiological transportation. 

33 Nonradiological Impacts 

34 Routine nonradiological gaseous fluoride effluents from the plant are listed in Table 4-28. For 

35 Phase 1 operations, approximately 52.7 kg/yr (116 lb/yr) of HF would be released from the IIFP 

36 process stacks. Additionally, approximately 64 kg (141 lb) of BF3 and 3.7 kg (8.2 lb) of SiF4

37 would be released through the stack annually. Emissions of regulated air pollutants would 

38 come predominately from the operating natural gas-fired boiler that would be used to provide 

39 steam for the plant heating and autoclave feed systems (the facility would have two boilers for 

40 redundancy, but only one would operate at any given time. Emission data estimated for the 

41 boiler indicates that it would not emit more than 13.2 metric tons (14.5 tons) per year of any 

42 regulated air pollutants. At 100 percent power, the boiler would emit 0.93 metric tons 

43 (1.03 tons) per year of CO, and 0.11 metric tons (0.12 tons) per year of NOx. IIFP would 

44 determine if the boilers would require an air quality permit from the State of New Mexico 

45 (IIFP, 2011a). 
 4-52 

1 Table 4-28. Estimated Annual Nonradiological Gaseous Fluoride Emissions 

Emission 

Estimated Releases 

DUF6 Dust Collector 

Stack 

SiF4 & BF3 

Dust Collector Stack 

SiF4 N/A 3.7 kg/yr 

(8.19 lb/yr) 

BF3 N/A 62.5 kg/yr 

(137.75 lb/yr) 

HF 49.3 kg/yr 

(108.72 lb/yr) 

0.3 kg/yr 

(0.77 lb/yr) 

2 Source: IIFP, 2011a 

3 

4 Nonradiological effluents would not exceed criteria in 40 CFR 50, 59, 60, 61, 122, 129, or 141 

5 (IIFP, 2009a). The primary chemical hazard is HF. HF is a clear, colorless, corrosive, fuming 

6 liquid with a very acrid odor. A release can form dense white vapor clouds. Both liquid and 

7 vapor can cause severe burns to all parts of the body. Exposure to skin, eyes and inhalation or 

8 ingestion can cause severe health consequences, including death. 

9 The facility would not discharge any industrial effluents to natural surface waters or soil, and 

10 there is no plant facility tie-in to a public waste water treatment facility. All effluents would be 

11 contained on the IIFP site via collection tanks. No routine liquid effluent discharge is expected; 

12 therefore, there would be no public impact. 

13 The NRC staff finds that impacts from routine releases (Phase 1 operations) to the public would 

14 be SMALL. 

15 No worker exposures exceeding the OSHA Standards for Toxic and Hazardous Substances 

16 (29 CFR 1910, Subpart Z) are anticipated (IIFP, 2011a). Additionally, handling of all chemicals 

17 and wastes would be conducted in accordance with the site Environment, Health, and Safety 

18 Program which would conform to 29 CFR 1910 OSHA standards and specify the use of 

19 appropriate engineered controls, as well as personnel protective equipment, to minimize 

20 potential chemical exposures (IIFP, 2011a). 

21 In addition to the radiological hazards associated with uranium, workers may be potentially 

22 exposed to the chemical hazards associated with uranium. UF6 is hygroscopic (moisture 

23 absorbing) and, in contact with water, would chemically breakdown into UO2F2 and HF. When 

24 released to the atmosphere, gaseous UF6 combines with humidity to form a cloud of particulate 

25 UO2F2 and HF fumes. The reaction is very fast and is dependent on the availability of water 

26 vapor. Consequently, an inhalation of UF6 is typically an internal exposure to HF and UO2F2. In 

27 addition to the radiation dose, a worker would be subjected to two other primary toxic effects: 

28 the uranium in the uranyl complex acts as a heavy metal poison that can affect the kidneys, and 

29 the HF can cause acid bums to the skin and lungs if concentrated. Because of low specific 

30 activity values, the radiotoxicity of UF6 and its products are smaller than their chemical toxicity 

31 (IIFP, 2011a). 

32 Because of the containment systems for gasses used or created in the plant process, and the 

33 personal protective equipment that would be used in areas where exposure could occur, worker 
 4-53 

1 exposure to in-plant gaseous releases would be minimal, and no exposures exceeding 

2 29 CFR 1910, Subpart Z are anticipated (IIFP, 2009a). Laboratory and maintenance operations 

3 involving hazardous gaseous or respirable effluents would be conducted with ventilation control 

4 (i.e., fume hoods, local exhaust, or similar) and with the use of respiratory protection, as 

5 required. All regulated gaseous effluents would be below regulatory limits as specified by the 

6 New Mexico Air Quality Bureau (IIFP, 2011a). The NRC staff finds that impacts from routine 

7 releases within the facility (Phase 1 operations) to workers would be SMALL. 

8 The proposed action involves a major industrial activity with the potential to cause temporary 

9 injuries, long-term injuries and/or disabilities, and even fatalities to workers. Common 

10 occupational accidents at facilities similar to the proposed IIFP plant typically involve hand and 

11 finger injuries, tripping accidents, minor burns and impacts due to striking objects or falling 

12 objects. To estimate the number of potential fatal and nonfatal occupational injuries from 

13 operation of the proposed IIFP facility, data on fatal and nonfatal occupational injuries per 

14 worker per year were collected from the U.S. Department of Labor’s Bureau of Labor Statistics. 

15 Nonfatal and fatal occupational injury rates for the manufacturing industry were used to 

16 calculate the estimated fatal and nonfatal injuries associated with operation of the proposed IIFP 

17 facility. As shown in Table 4-29, less than four nonfatal injuries and less than one fatality are 

18 expected annually during operation of the proposed IIFP facility. The NRC staff finds that the 

19 impacts to human health from occupational injuries during operation would be SMALL. 

20 Table 4-29. Annual Nonfatal and Fatal Occupational Injuries Projected for Operation of 

21 the IIFP Facility 

Category Injury Rate Expected Occurrences 

Nonfatal Injuries 2.3 per 100 workersa 3.2 

Fatal Injuries 2.2 per 100,000 workersb less than 1 (3.1 x 10-3) a 22 The expected nonfatal injury rate (total recordable cases) is from BLS (2010a). b 23 The fatal injury rate is from BLS (2010b). 

c 24 Expected occurrences are based on 140 workers during Phase 1 operations. 

25 

26 Worker health and safety at the proposed IIFP facility would be protected by its Chemical Safety 

27 Program, the Radiation Protection Program, and the Industrial Safety Program. These 

28 programs would comply with applicable State, NRC (10 CFR 20), and OSHA (29 CFR 1910) 

29 requirements. Work environments that present the potential for exposure to chemical, 

30 biological, or physical agents (e.g., radiation, noise, heat/cold, vibration) would be evaluated, 

31 and appropriate safety controls would be implemented and/or safety equipment would be 

32 assigned to workers. Personal protective equipment requirements would be based on the 

33 nature of the work and chemical and/or radiological hazards present and would be a key 

34 component to minimizing exposure to chemical and radiological agents. Exposure monitoring 

35 would be conducted on radiation workers to evaluate their personal exposure; if personal 

36 monitoring is not feasible, work area monitoring would be used to represent personal exposure. 

37 The NRC staff finds that the impacts to human health from occupational injuries during 

38 operation would be SMALL. 

39 4.1.2.12 Waste Management Impacts

40 Waste generation during facility operation would be minimized through reduction, reuse, and 

41 recycling, as applicable to specific waste streams. The proposed IIFP facility would incorporate 

42 waste minimization systems in its operational procedures and design with the goal of conserving 
 4-54 

1 materials, recycling important compounds, and preventing the spread of contamination. Good 

2 work practices would be used to collect and sort the wastes generated during operation for 

3 recycling or disposal (e.g., using designated roll-off containers and collection areas for different 

4 types of wastes) (IIFP, 2011a). 

5 There would be no permanent onsite disposal of any waste; only temporary storage. Wastes 

6 generated at the proposed IIFP facility would be disposed of at licensed facilities designed to 

7 accept the various waste types. The management of stormwater and wastewater at the 

8 proposed IIFP facility is discussed in Section 4.1.2.6. 

9 Solid waste, including sanitary waste, miscellaneous trash, vehicle air filters, empty cutting oil 

10 cans, miscellaneous scrap metal, and paper would be shipped offsite for recycling or 

11 minimization, if appropriate, or transported offsite to an approved local landfill (IIFP, 2011a). 

12 The radioactive DUO2 waste from the deconversion process would be shipped to an offsite LLW 

13 disposal facility licensed to accept DUO2. Other LLW, including dust collector bags, ion 

14 exchange resin, crushed contaminated drums, contaminated trash, contaminated coke, and 

15 carbon trap material, would be collected in labeled containers in each Restricted Area and 

16 transferred to the Radioactive Waste Storage Area for inspection. Waste would be volume17 reduced, if appropriate, and disposed of at a licensed LLW disposal facility. 

18 Hazardous wastes and some mixed wastes would be collected at the point of generation in 

19 approved containers, transferred to the onsite Waste Storage Area, inspected, classified, and 

20 shipped by a licensed transporter to a hazardous waste treatment or disposal facility. The 

21 majority of the projected hazardous waste is the potential waste CaF2. As described in 

22 Section 2.1.6.4.2, the KOH regeneration process results in CaF2 that would be packaged and 

23 stored for sale. If a market for this material is not identified, the CaF2 would be sent to a 

24 licensed hazardous waste disposal facility. Any mixed waste would be treated in its original 

25 collection container prior to shipment for offsite disposal, or shipped directly to a mixed waste 

26 processor (IIFP, 2011a). 

27 Tables 4-30, 4-31, and 4-32 provide information on the types and estimated annual quantities of 

28 solid, hazardous, and LLW, respectively, generated from Phase 1 operations at the proposed 

29 IIFP facility. 

30 As described in Section 4.1.1.12, nonhazardous solid wastes from the proposed IIFP facility 

31 would likely be transported to the Lea County landfill for disposal. The Lea County landfill 

32 receives approximately 82,500 tons of solid waste annually (NMED, 2009). Nonhazardous, 

33 industrial waste generated from operation of the proposed facility (up to 46 tons per year as 

34 shown in Table 4-30) would result in an increase of approximately 0.06 percent in the waste that 

35 the Lea County Landfill receives annually from all other sources. The NRC staff finds that this 

36 quantity of nonhazardous waste material would result in SMALL impacts that could be managed 

37 effectively. 

38 Hazardous wastes would be packaged and shipped offsite to licensed hazardous waste 

39 treatment and disposal facilities in accordance with Federal and State regulations (IIFP, 2011a). 

40 Table 4-31 shows that the quantity of hazardous waste generated by operations could be as 

41 much as 154 tons per year if a market for the CaF2 cannot be identified. The projected annual 

42 hazardous waste generation would likely classify the proposed IIFP facility as large quantity 

43 generator (over 1,000 kg/mo [2,200 lb/mo]). As discussed in Section 4.1.1.12, hazardous waste 

44 generators in New Mexico produced 1,078,672 tons of hazardous waste in 2009 (EPA, 2010b). 
 4-55 

1 The maximum IIFP generation rate would result in an increase of less than 0.02 percent in the 

2 hazardous waste generated annually in the State of New Mexico. Therefore, the NRC staff 

3 finds that the quantity of operations hazardous waste material would result in SMALL impacts 

4 that could be managed effectively. 

5 Table 4-30. Solid Waste Generation – Operations 

Material Estimated Annual Amount 

Clothing 45 – 90 kg 

(100 – 200 lbs) 

Molecular sieve 140 – 230 kg 

(300– 500 lbs) 

Municipal trash waste 27,000 – 41,000 kg 

(60,000 – 90,000 lbs) 

Safety gear 90 – 180 kg 

(200 – 400 lbs) 

Waste Glass 23 – 90 kg 

(50 – 200 lbs) 

Total 27,500 – 41,400 kg 

(60,650 – 91,300 lbs) 

6 Source: IIFP, 2011a 

7 

8 Table 4-31. Hazardous Waste Generation – Operations 

Material Estimated Annual Amount 

Aerosol cans, paints cans, bulbs 450 – 1400 kg 

(1,000 – 3,000 lbs) 

CaF2

a 90,000 – 136,000 kg 

(200,000 – 300,000 lbs) 

Lab chemicals 90 – 180 kg 

(200 – 400 lbs) 

Oil sorbent 900 – 2,300 kg 

(2,000 – 5,000 lbs) 

Totala 92,000 – 140,000 kg 

(203,200 – 308,400 lbs) 

9 Source: IIFP, 2011a 

a 10 Includes CaF2 that would not be waste if sold. 

11 

12 Table 4-32. Low Level Radioactive Waste Generation – Operations 

Material Estimated Annual Amount 

Activated alumina 900 – 1,800 kg 

(2,000 – 4,000 lbs) 

Air ventilation filters 23 – 45 kg 

(50 – 100 lbs) 

Carbon 11,000 – 14,000 kg 

(25,000 – 30,000 lbs) 

DUF4 clinkers 2,300 – 4,500 kg 

(5,000 – 10,000 lbs) 

Coke 3,600 – 5,400 kg 

(8,000 – 12,000 lbs) 

13 
 4-56 

1 Table 4-32. Low Level Radioactive Waste Generation – Operations (Continued) 

Material Estimated Annual Amount 

Crushed drums 450 – 1,400 kg 

(1,000 – 3,000 lbs) 

Dust collector bags 230 – 1,400 kg 

(500 – 3,000 lbs) 

Ion exchange resin 450 – 900 kg 

(1,000 – 2,000 lbs) 

Oxide for burial (plus drums) 1,270,000 – 2,800,000 kg 

(2,800,000 – 6,200,000 lbs) 

Radioactive waste trash 16,000 – 25,000 kg 

(35,000 – 55,000 lbs) 

Scrap metal 1,800 – 3,600 kg 

(4,000 – 8,000 lbs) 

Sintered metal tubes 450 – 900 kg 

(1,000 – 2,000 lbs) 

Sodium fluoride 900 – 1,800 kg 

(2,000 – 4,000 lbs) 

Spent blasting sand 45 – 90 kg 

(100 – 200 lbs) 

Wood trash (pallets) 450 – 1,800 kg 

(1,000 – 4,000 lbs) 

Total 1,309,000 – 2,875,000 kg 

(2,885,650 – 6,337,300 lbs) 

2 Source: IIFP, 2011a 

3 

4 Depleted uranium is classified as Class A low level waste; however, a specific disposal site may 

5 place additional limits on concentration, volume or waste form. Disposal options, including 

6 waste form, would be determined after licensing and may change over the operating life of the 

7 facility; however, licensed LLW disposal facilities, including the U.S. Ecology site in Richland, 

8 Washington; EnergySolutions site in Clive, Utah, DOE’s site in Area 5 of the Nevada National 

9 Security Site (formerly known as the Nevada Test Site), and the WCS facility in Andrews, Texas 

10 are potentially viable options, provided regulatory and contractual conditions can be satisfied. 

11 The U.S. Ecology facility is in the Pacific Northwest Compact, which has an agreement with 

12 Rocky Mountain Compact, of which New Mexico is a member, to dispose of waste but the U.S. 

13 Ecology facility would need a revision in the allowable total uranium inventory. EnergySolutions

14 accepts shipments from all states. Shipment to the Nevada National Security Site would require 

15 DOE to accept possession of the LLW (consistent with Section 13 of the USEC Privatization Act 

16 of 1996). 

17 The WCS facility is 42 km (26 mi) southeast of the proposed site but is currently limited to waste 

18 from the Texas Compact and therefore, would have to establish approval mechanisms for out19 of-compact waste to be disposed. Furthermore, the Rocky Mountain Compact would have to 

20 approve shipment outside the compact. The analysis in this draft EIS is not intended to support 

21 selection of the LLW disposal facility for the DUO2. 

22 Decisions regarding the disposal location for DUO2 and other LLW would be made based on 

23 economic and other considerations. For analysis purposes, the radioactive wastes were 

24 assumed to be shipped to the EnergySolutions site in Clive, Utah. As shown in Table 4-32, up 

25 to 3,170 tons per year of LLW could be sent for disposal. Most of the LLW generated 
 4-57 

Acute Exposure Guideline Levels 

(AEGLs) 

AEGLs represent threshold exposure limits 

for the general public and are applicable to 

five emergency exposure periods (10 

minutes, 30 minutes, 1 hour, 4 hours, and 

8 hours) and are distinguished by varying 

degrees of severity of toxic effects. It is 

believed that the recommended exposure 

levels are applicable to the general 

population including infants and children, 

and other individuals who may be 

susceptible. The three AEGLs have been 

defined as follows: 

AEGL-1 is the airborne concentration of a 

substance, expressed as parts per million 

or milligrams per cubic meter (ppm or 

mg/m3) above which it is estimated that the 

general population, including susceptible 

individuals, could experience notable 

discomfort, irritation, or certain 

asymptomatic nonsensory effects. 

However, the effects are not disabling and 

are transient and reversible upon cessation 

of exposure. 

AEGL-2 is the airborne concentration 

(expressed as ppm or mg/m3) of a 

substance above which it is estimated that 

the general population, including 

susceptible individuals, could experience 

irreversible or other serious, long-lasting 

adverse health effects or an impaired 

ability to escape. 

AEGL-3 is the airborne concentration 

(expressed as ppm or mg/m3) of a 

substance above which it is estimated that 

the general population, including 

susceptible individuals, could experience 

life-threatening health effects or death.

1 (approximately 97 percent) would be the DUO2 produced by the deconversion process. The 

2 DUO2 and other LLW generated would be Class A waste (IIFP, 2009a). The projected 

3 quantities of DUO2 and other Class A LLW generated by the proposed IIFP facility operations 

4 would have little effect on the available disposal capacity for such material. The projected 

volume of DUO2 waste (up to 6,200 55-gal drums or 1,300 m3 5 /yr) represents approximately 

0.04 percent of the 3.1 million m3 6 disposal volume of the Class A cell at the Clive facility (DOE, 

7 2000). The Clive facility accepts most of the United States’ Class A waste and is estimated to 

8 have capacity to accept this waste at current volume levels for more than 20 years (GAO, 

9 2004). The NRC staff finds that the potential impact of proposed IIFP facility operations on LLW 

10 disposal capacity would be SMALL. 

11 4.1.2.13 Impacts of Postulated Accidents 

12 4.1.2.13.1 Facility Accidents 

13 The operation of the proposed IIFP facility would 

14 involve risks to workers, the public, and the 

15 environment from potential accidents. The facility 

16 would be licensed under 10 CFR 40, Domestic 

17 Licensing of Source Material, and would also be subject 

18 to consideration of 10 CFR 70, Subpart H, Additional 

19 Requirements for Certain Licensees Authorized to 

20 Possess a Critical Mass of Special Nuclear Material, as 

21 part of the licensing basis for the application review of 

22 certain new source material facilities as an interim 

23 measure pending the completion of 10 CFR 40 

24 rulemaking. NRC regulation 10 CFR 70 requires that 

25 each applicant or licensee evaluate, in an Integrated 

26 Safety Analysis (ISA), its compliance with certain 

27 performance requirements. As part of the safety 

28 review, the NRC staff would conduct a confirmatory 

29 analysis, which independently evaluates the 

30 consequences of potential accidents identified in IIFP’s 

31 ISA plans. The accidents evaluated are a 

32 representative selection of the types of accidents that 

33 are possible at the proposed facility. 

34 The analytical methods used in the NRC staff’s 

35 consequence assessment are based on NRC guidance 

36 for analysis of nuclear fuel-cycle facility accidents 

37 (NRC, 1990; NRC, 1991; NRC, 1998) and regulatory 

38 guidance cited by IIFP (EPA, 1999). The consequence 

39 assessment considered the available information 

40 regarding the facility prior to final design. The NRC 

41 staff analyzed accidents involving the release of HF, 

42 the primary chemical hazard at the facility. HF is a 

43 clear, colorless, corrosive, fuming liquid. In high 

44 concentrations, a release could form dense white vapor 

45 clouds. HF releases pose a chemical risk to workers, 

46 the public, and the environment. Both direct releases 

47 of HF and releases from a byproduct reaction involving 
 4-58 

1 other fluoride species (DUF6, DUF4, SiF4 and BF3) could pose accident risks. NRC staff also 

2 evaluated accidents involving radioactive materials (depleted uranium bound with fluoride 

3 and/or oxide) for radiation and chemical (heavy metal toxicity) impacts. 

4 4.1.2.13.1.1 Accidents Considered 

5 A number of potential accidents could occur at the proposed facility. The NRC staff selected, 

6 for detailed evaluation, a subset of the potential accident scenarios that is intended to 

7 encompass the range of possible accidents. The accident sequences the staff selected vary in 

8 severity from high- to low-consequence events, and include accidents initiated by natural 

9 phenomena (seismic event), operator error, and equipment failure. 

10 The accident scenarios evaluated were as follows: 

11 • Seismic event causing multiple process containment failures: This scenario would occur 

12 across multiple processes. The staff evaluation of acute effects was limited to cylinder 

13 breaches in the cylinder storage area which IIFP identified as resulting in high 

14 consequences. The staff evaluation of collective effects utilized an estimate of the total 

15 facility source term. 

16 • Liquid DUF6 cylinder drop: This scenario would include a breach and release of liquid 

17 DUF6. 

18 • SiF4 release: This scenario could be caused by over-pressurization of a nitrogen loop 

19 with secondary cold trap breach. 

20 • UF4 collection drum spill. 

21 • UF4 vacuum transfer line rupture: This scenario would occur outside of the building. 

22 IIFP’s ISA attributes “likelihood categories” (highly unlikely, unlikely, or not unlikely) to each 

23 accident sequence. The staff’s analysis described in this section does not include an estimate 

24 of the probability of occurrence of accidents, which, in combination with consequences, would 

25 reflect the overall risk from an accident. Instead, analyzed accidents are assumed to occur and 

26 consequences of each accident reported. 

27 4.1.2.13.1.2 Accident Consequences 

28 The performance requirements in 10 CFR 70, Subpart H, define acceptable levels of risk of 

29 accidents at nuclear fuel cycle facilities such as the proposed facility. The regulations in 

30 Subpart H require that IIFP reduce the risks of credible high-consequence and intermediate31 consequence events, with all nuclear processes being subcritical. Table 4-33 defines the 

32 accident consequence categories used for the accident analysis. Table 4-34 defines exposure 

33 thresholds, by receptor and for intermediate- and high- consequence accidents, for each 

34 chemical species analyzed, as interpreted by IIFP. Subcritical conditions are assured because 

35 the facility would work exclusively with depleted uranium materials, and the incoming materials 

36 would be assayed to ensure this condition. 

37 The staff evaluated the consequences of the selected accidents against the threshold values for 

38 a facility worker, a site worker 100 m (328 ft) from the release point, an individual at the site 

39 boundary, and the environment at the site boundary. Table 4-35 summarizes these results. 

40 
4-59 

Table 4-33. Accident Consequence Categories 1 

Category Workers Off-Site Public Environment 

Category 3 High Consequences 

• Individual Radiation Dose ≥100 rem • Individual Chemical Dose = endanger 

life (> than AEGL-3, 10 min exposure) 

• 75 mg soluble uranium intake 

• Individual Radiation Dose ≥25 rem • Chemical Dose = long-lasting health 

effects (> AEGL-2, 30 min exposure) 

• 30 mg soluble uranium intake 

Category 2 Intermediate Consequences 

• Individual Radiation Dose ≥25 rem • Individual Chemical Dose = long-lasting 

health effects (>AEGL-2 but <AEGL-3, 10 min exposure) 

• Individual Radiation Dose ≥5 rem • Chemical Dose = mild transient health 

effects (>AEGL-1 but <AEGL-2, 30 min exposure) 

Radiological release >5000 times values in Table 2 of 10 CFR 20 

Category 1 Low Consequences 

Accidents of lower radiological and chemical exposures than Category 2 

Accidents of lower radiological and chemical exposures than Category 2 

Radiological releases lower than Category 2 

Source: IIFP, 2009b 2 

Table 4-34. Chemical Consequence Exposure Thresholds 3 

Chemical 

Intermediate Consequences High Consequences 

Worker Exposure Public Exposure Worker Exposure Public Exposure 

Level of 

Concern 

Concentration, 

mg/m3

Level of 

Concern 

Concentration, 

mg/m3

Level of 

Concern 

Concentration, 

mg/m3

Level of 

Concern 

Concentration, 

mg/m3

Hydrogen fluoride (HF) 

AEGL-2 

10 min 

77.8 AEGL-1 

30 min 0.82 AEGL-3 10 min 139 AEGL-2 30 min 28 

Silicon tetrafluoride (SiF4) 

AEGL-2 

10 min 27 AEGL-1 30 min 0.21 AEGL-3 10 min 81 AEGL-2 30 min 18 

Boron trifluoride (BF3) AEGL-2 

10 min 47 AEGL-1 30 min 2.5 AEGL-3 10 min 140 AEGL-2 30 min 47 

Uranium hexafluoride (UF6) 

AEGL-2 

10 min 28 AEGL-1 30 min 3.6 AEGL-3 10 min 216 AEGL-2 30 min 19 

Uranyl fluoride (UO2F2) 

AEGL-2 

10 min 28 AEGL-1 30 min 3.6 AEGL-3 10 min 216 AEGL-2 30 min 19 

Uranium tetrafluoride (UF4) 

AEGL-2 

10 min 28 AEGL-1 30 min 3.6 AEGL-3 10 min 216 AEGL-2 30 min 19 

Uranium dioxide (UO2) 

ERPG-2 

10 min 201 ERPG-1 30 min 0.68 ERPG-3 10 min 180 ERPG-2 30 min 32 

Source: IIFP, 2009b 4 ERPG = Emergency Response Planning Guideline – Concentration values established by the American Industrial Hygiene Association that meet certain human 5 response criteria similar to those for Acute exposure guideline levels (AEGLs). 6 

7 
 4-60 

1 Table 4-35. Summary of Accident Analysis Results 

Receptor Parameter 

Worst 

Case 

DUF6

Release 

Seismic 

event 

causing 

multiple 

process 

containment 

failures 

Fluorine 

Compounds 

Release 

UF4 Spill 

Transfer 

Line 

Rupture 

Worker 

(inside room, 

10 min 

exposure) 

HF concentration 

(mg/m3

) 1.34 x 106

 56.5 

UO2F2

concentration 

(mg/m3

) 

5.14 x 106

 

Soluble U intake 

(mg) 7.94 x 105

 

Dose (rem) 686 0.052 

SiF4

concentration 

(mg/m3

) 

 73.5 

UF4

concentration 

(mg/m3

) 

 121 

Worker 

(outside 

building, 

10 min 

exposure) 

HF concentration 

(mg/m3

) 1.64 x 104

 47.3 0.452 

UO2F2

concentration 

(mg/m3

) 

6.05 x 104

 179 

Soluble U intake 

(mg) 9,340 27.6 

Dose (rem) 8.07 0.02 4.05 x 10-

4 3.48 x 10-4

SiF4

concentration 

(mg/m3

) 

 0.588 

UF4

concentration 

(mg/m3

) 

 0.953 0.817 

Public 

(at Site 

Boundary, 

30 min 

exposure) 

HF concentration 

(mg/m3

) 7,800 15.7 0.367 

UO2F2

concentration 

(mg/m3

) 

2.93 x 104

 59.4 

Soluble U intake 

(mg) 1.36 x 104

 27.4 

Dose (rem) 11.7 0.02 0.0017 3.45 x 10-4

SiF4

concentration 

(mg/m3

) 

 0.478 

UF4

concentration 

(mg/m3

) 

 1.33 0.27 
 4-61 

1 Table 4-35. Summary of Accident Analysis Results (Continued) 

Receptor Parameter 

Worst 

Case 

DUF6

Release 

Seismic 

event 

causing 

multiple 

process 

containment 

failures 

Fluorine 

Compounds 

Release 

UF4 Spill 

Transfer 

Line 

Rupture 

Environment 

(at Site 

Boundary, 

24 hr avg) 

Activity 

Concentration 

(uCi/mL) 

2.7 2 x 10-7 4.96 x 10-10 6.67 x 10-

12 2.17 x 10-12

Public 

collective 

exposure 

Dose (personrem) 16.1 135 0.00317 0.00192 

LCF 0.00351 0.0297 2.63 x 10-6 1.59 x 10-6

2 Source: NRC, 2011 

3 Note: Not all accident sequences resulted in datum for the categories listed in this table. This could be because the sequence was 

4 postulated to occur outside of a building or did not involve all the chemicals or radioactive materials listed. 

5 The most significant accident consequences are those associated with the release of liquefied 

6 UF6 caused by rupturing a cylinder. The facility emergency plan addresses this type of event, 

7 as well as all other lower-risk, high- and intermediate-consequence events. IIFP would reduce 

8 the likelihood of this type of event by requiring a robust cylinder design that maintains its 

9 integrity during credible drops, shocks, collisions, and thermal events, and an interlock on the 

10 autoclave which would prevent the removal of liquid or partially full cylinders during heating/feed 

11 cycles. The NRC staff concludes that through the combination of plant design, passive and 

12 active engineered controls, and administrative controls, accidents at the facility would pose an 

13 acceptably SMALL risk to workers, the environment, and the public. 

14 NRC regulations and IIFP’s operating procedures for the proposed facility would be designed to 

15 ensure that the high and intermediate accident scenarios would be highly unlikely and unlikely, 

16 respectively. The combination of responses by Items Relied on for Safety, which mitigate or 

17 prevent emergency conditions, and the implementation of emergency procedures and protective 

18 actions in accordance with the facility emergency plan would limit the consequences and reduce 

19 the likelihood of accidents that could otherwise extend beyond the proposed facility site and 

20 property boundaries. 

21 4.1.2.13.2 Transportation Accidents 

22 Operation of the IIFP facility would require shipment of full DUF6 cylinders from commercial 

23 enrichment facilities, empty DUF6 cylinders back to the commercial enrichment facilities, DUO2

24 to waste disposal facilities, and other process and miscellaneous LLW to waste disposal 

25 facilities. Section 4.1.2.9.2 describes these shipments, which are summarized here in 

26 Table 4-36. 

27 NRC staff used the TRAGIS (Johnson and Michelhaugh, 2003) transportation routing computer 

28 modeling code and the RADTRAN5 (Neuhauser and Kanipe, 2003) transportation risk 

29 assessment computer modeling code to calculate the radiological transportation dose-risk to the 

30 exposed population along the transportation route. Dose-risk is the product of dose and 

31 probability for small segments along the route and summed over the entire route. Accident 

32 frequencies were taken from Saricks and Tompkins (1999). Severity fractions and 

33 package/contents response characteristics were taken from NUREG-0170 (NRC, 1977). 
 4-62 

1 Results of that analysis are provided in Table 4-37, with more details on the analysis provided in 

2 Appendix E. LCF risk is the product of dose-risk times the Interagency Steering Committee on 

Radiation Standards conversion factor of 6 x 10-4 3 LCFs per person-rem (ISCORS, 2002). 

4 Table 4-36. Summary of Annual Radiological Transportation Shipments 

Description Origin Destination 

Number of 

Shipments Packaging 

Full DUF6 cylinders URENCO USA IIFP 293 1 cylinder per truck 

Full DUF6 cylinders GLE IIFP 293 1 cylinder per truck 

Full DUF6 cylinders from 

AREVA Eagle Rock 

Eagle Rock IIFP 293 1 cylinder per truck 

Empty DUF6 cylinders IIFP URENCO USA 293 1 cylinder per truck 

Empty DUF6 cylinders IIFP GLE 293 1 cylinder per truck 

Empty DUF6 cylinders IIFP Eagle Rock 293 1 cylinder per truck 

DUO2 IIFP EnergySolutions, 

Clive Facility 

155 55-gal drums, 

40 per truck 

DUO2 IIFP Waste Control 

Specialists 

155 55-gal drums, 

40 per truck 

Miscellaneous LLW IIFP EnergySolutions, 

Clive Facility 

31 55-gal drums, 

40 per truck 

Miscellaneous LLW IIFP Waste Control 

Specialists 

31 55-gal drums, 

40 per truck 

5 Source: IIFP, 2011a 

6 

7 Table 4-37. Annual Accident Dose-Risk and LCF-Risk from Radiological Transportation 

Description 

Dose-Risk 

(person-Sv) 

Dose-Risk 

(person-rem) LCF Risk 

Full DUF6 cylinders from URENCO USA 4.0 x 10-5 0.0040 2.4 x 10-6

Full DUF6 cylinders from GLE Facility 0.14 14 0.0081 

Full DUF6 cylinders from AREVA Eagle Rock 0.10 10 0.0060 

Empty DUF6 cylinders to URENCO USA 1.5 x 10-7 1.5 x 10-5 8.7 x 10-9

Empty DUF6 cylinders to GLE Facility 4.9 x 10-4 0.049 2.9 x 10-5

Empty DUF6 cylinders to AREVA Eagle Rock 3.7 x 10-4 0.037 2.2 x 10-5

DUO2 to EnergySolutions, Clive 0.10 10 0.0063 

DUO2 to Waste Control Specialists 3.9 x 10-5 0.0039 2.3 x 10-6 

Miscellaneous LLW to EnergySolutions, Clive 5.5 x 10-5 0.0055 E 3.3 x 10-6

Miscellaneous LLW to Waste Control 

Specialists 2.0 x 10-8 2.0 x 10-6 1.2 x 10-9

8 Source: See Appendix E 

9 

10 Assuming a scenario in which DUF6 is shipped from the enrichment facility and the DUO2 waste 

11 is shipped to the waste disposal facility as the greatest transportation risks, one arrives at 

12 0.24 person-sievert (24 person-rem) of accident risk annually. This is for receipt and return of 

13 cylinders to the GLE facility in Wilmington, North Carolina and disposal of low-level waste at 
 4-63 

1 EnergySolutions Clive, Utah facility. The equivalent number of latent cancer fatalities is 

2 0.014 LCF. 

3 According to the Centers for Disease Control and Prevention (CDC, 2010), there were 

4 178.4 cancer deaths per 100,000 people in 2007 with a probability of occurrence of 100 percent. 

5 Given the high rate of cancer fatalities in the U.S. from all causes, the addition of 0.014 LCF 

6 from the risk of a radiological transportation accident from the proposed facility is considered by 

7 the NRC staff to be a SMALL impact. While mitigation measures are not required, IIFP would 

8 be required by NRC and DOT regulations to package and manage the transported waste to 

9 minimize the probability of accidental release of radioactive material. 

10 4.1.3 Decommissioning Impacts 

11 This section summarizes the potential environmental impacts of the decommissioning of the 

12 proposed IIFP facility. Decommissioning as described in Chapter 10 of the License Application 

13 (IIFP, 2009a), would involve the decontamination of equipment and buildings and the removal 

14 and disposal of all operating fuel-cycle facility equipment. Decommissioning would be funded in 

15 accordance with a decommissioning funding plan for the proposed IIFP facility, which will be 

16 prepared by IIFP in accordance with 10 CFR 70.25(a) and NUREG-1757 (NRC, 2006). 

17 A complete description of the actions to be taken to decommission the proposed IIFP facility at 

18 the expiration of the plant’s NRC license period (if the license is granted) cannot be provided at 

19 this time. In accordance with 10 CFR 70.38, IIFP must prepare and submit a decommissioning 

20 plan (different from the decommissioning funding plan) to the NRC for review and comment at 

21 least 12 months prior to the expiration of the proposed facility’s NRC license. IIFP would submit 

22 a final decommissioning plan to the NRC for review prior to the start of decommissioning. This 

23 plan would include more detail than is available at this time. All decommissioning activities 

24 would comply with the applicable Federal, State, and local regulations in effect at the time of the 

25 decontamination and decommissioning activities. 

26 It is reasonable to expect that decommissioning would occur over the course of three years and 

27 that it would be expected to employ 40 workers for the three-year period (IIFP, 2009a). 

28 Two possibilities exist for decommissioning the facility. One is to leave the structures and most 

29 (non-uranium-processing) support equipment in place after they are decontaminated to 

30 appropriate (unrestricted release) levels, in accordance with 10 CFR 20, for ultimate use by 

31 another industrial tenant or owner. The second is to decontaminate and raze the entire facility, 

32 restoring the site to its current use as open range land (e.g., grazing and wildlife habitat). The 

33 final disposition of the property would be determined at the time of decommissioning. The ER 

34 assumes that “...decommissioning...will involve the removal of the internal equipment, utilities, 

35 and products from the building(s); however the physical structure, associated foundations, 

36 access roads, and utility lines will likely remain intact,” (IIFP, 2009a). Therefore, this section 

37 evaluates leaving structures for industrial re-use as the likely decommissioning option. 

38 Decontamination and decommissioning of the proposed facility is described in Section 2.1.7. 

39 Regardless of the end use of the facility, decommissioning would begin with the 

40 decontamination and removal of uranium-processing equipment and other materials to be 

41 shipped offsite for licensed disposal. The number of daily truck shipments is anticipated to be 

42 similar to the average daily shipments during operations, and the total number of shipments 

43 would depend upon the volume of demolition debris and materials packaged for disposal. 

44 Radioactively-contaminated equipment and materials would be disposed of by shipping them to 
 4-64 

1 a licensed treatment or disposal facility in compliance with applicable NRC and DOT 

2 requirements. 

3 Discussions of issue- and resource-specific impacts of decommissioning include the following: 

4 LAND USE: The chain-link perimeter security fence surrounding the facility compound could be 

5 removed following decommissioning. If decommissioning included the removal of all facilities, 

6 the land could revert to its current use for grazing and wildlife habitat. If buildings are not 

7 removed, another industry could move into the facility; and the 16 ha (40 ac) would not be 

8 available for grazing; however, the undeveloped land (240 ha, or 600 ac) could be available for 

9 grazing. Land use plans and land uses surrounding the site would be unaffected by 

10 decommissioning. The NRC staff concludes that regardless of the condition (option with 

11 structures remaining for alternate uses or option with all structures removed/site restored), the 

12 impacts to local land use due to decommissioning would be SMALL. 

13 HISTORIC AND CULTURAL RESOURCES: Decommissioning of the facility would not involve 

14 land disturbance which could affect historic properties, districts, resources or significant 

15 historic/precontact archaeological sites. No historic resources were identified within the cultural 

16 resources APEs and three isolated artifacts that are not NRHP-eligible were identified during the 

17 cultural resource survey. No Native American Tribes expressed concerns to the NRC regarding 

18 the project. 

19 Therefore, the NRC staff concludes that any impacts to historic properties, districts, resources 

20 or significant historic/precontact archaeological sites during facility decommissioning would be 

21 SMALL.

22 CLIMATE, METEOROLOGY, AND AIR QUALITY: GHG emissions associated with 

23 decommissioning would result primarily from three activities: (1) the onsite consumption of 

24 fossil fuels in vehicles and equipment used to dismantle and possibly demolish existing 

25 structures or excavate buried utilities and components, (2) the transportation of waste materials 

26 and salvage materials from the proposed site to appropriate offsite disposal or recycling 

27 facilities, and (3) the commuting decommissioning workforce. 

28 The following are conservative assumptions that can be made relative to the proposed IIFP 

29 facility decommissioning and that can be used to estimate GHG impacts associated with 

30 decommissioning activities (IIFP, 2011a): 

31 • CO2 emissions from shipments of DUF6 feed materials and operational waste shipments 

32 still occurring during the initial period of decommissioning are treated as operational 

33 GHG impacts. 

34 • Shipments of wastes or recycling materials would occur by diesel-fueled trucks 

35 averaging 23.5 liters of fuel per100 km (10 mpg). 

36 • LLW resulting from decontamination activities would be substantially greater in volume 

37 than LLW resulting from routine IIFP facility operation. 

38 • All non-radioactive and non-hazardous solid wastes would be delivered to the same area 

39 landfills and treatment facilities that received wastes of similar nature during IIFP facility 

40 operation. Assuming successful decontamination of the majority of IIFP facility 

41 equipment and structures, a significantly higher number of annual trips would occur 

42 throughout the 3-year decommissioning phase than would have occurred annually 
 4-65 

1 during IIFP facility operation, and the resulting CO2 emissions would be at least an order 

2 of magnitude greater than the values for such waste shipments appearing in 

3 Section 4.1.2.4.1, “Greenhouse Gases”. 

4 • All non-radioactive hazardous waste generated during IIFP facility operations would 

5 already have been transported to permitted disposal facilities. The CO2 emissions of 

6 such deliveries would be credited to the IIFP facility operational phase. The amount of 

7 non-radioactive hazardous waste generated as a result of decommissioning is expected 

8 to be small and would likely be transported to the same disposal facilities that received 

9 similar waste during IIFP facility operation. It is further assumed that an appropriately 

10 permitted disposal facility will be located within a reasonable distance from the proposed 

11 IIFP facility, resulting in limited amounts of GHG emissions from transport. 

12 • Except for the period at the beginning of decommissioning when some operations would 

13 still be ongoing, the decommissioning workforce would decrease from 140 to 

14 40 employees. Therefore annual releases of CO2 related to workforce commuting would 

15 be approximately one-third of the values shown in Table 4-13 for operations. Releases 

16 of CO2 related to workforce commuting during the time that operations are continuing as 

17 decommissioning is beginning would be approximately one-third higher than the values 

18 shown in Table 4-13. 

19 Therefore, the NRC staff concludes that impacts to climate and air quality would be SMALL. 

20 GEOLOGY, MINERALS, AND SOIL: The general condition of the site geologic resources would 

21 not change during or after decommissioning activities. Minerals at the site and vicinity would 

22 not be affected by decommissioning. As with construction, demolition of structures and 

23 disturbed areas would be subject to BMPs to prevent adverse impacts to soils. As a final step in 

24 decommissioning, soil testing would demonstrate that site soils meet NRC, EPA, and NMED 

25 regulations and guidelines for free release. Accordingly, the NRC staff concludes that impacts 

26 to geology, minerals, and soil during decommissioning would be SMALL. 

27 WATER RESOURCES: No surface water is present on the site, so decommissioning would not 

28 affect surface water. The management of stormwater is not expected to change during or after 

29 decommissioning activities, unless the site is restored to its original open range conditions. 

30 Groundwater would be used during decommissioning for the potable water system, and 

31 decommissioning needs such as dust suppression. Water for facility processes would no longer 

32 be used; therefore, water withdrawal during decommissioning would be less than during 

33 operations. 

34 Accordingly, the NRC staff concludes that impacts to water resources during decommissioning 

35 would be SMALL. 

36 SOCIOECONOMICS: Decommissioning is expected to employ 40 workers over three years. 

37 The workers would be IIFP employees or work in the construction trades. All would be 

38 residents of the ROI. No workers would migrate into the area; however, some former IIFP staff 

39 could migrate out of the area. The NRC staff finds that impacts to socioeconomic resource 

40 would be SMALL. The NRC staff finds that no disproportionately high or adverse impacts would 

41 be incurred by any minority or low-income population. 

42 TRAFFIC AND TRANSPORTATION: Impacts to traffic would be similar to the impacts during 

43 construction and operations. The Phase 2 construction and operations workforces and the 

44 number of trucks transporting materials to/from the facility on a daily basis would be similar to 
 4-66 

1 the number during Phase 1 construction and operation. IIFP would ensure that all 

2 transportation of materials met NRC and DOT regulations. 

3 Therefore, the NRC staff concludes that impacts to traffic and transportation would be SMALL. 

4 NOISE: Impacts from noise during decommissioning would be very similar to impacts during 

5 construction. Therefore, the NRC staff concludes that impacts would be SMALL. 

6 OCCUPATIONAL AND PUBLIC HEALTH: Impacts to occupational and public health would be 

7 similar to impacts during construction. Therefore, the NRC staff concludes that impacts would 

8 be SMALL. 

9 WASTE MANAGEMENT: The overall strategy for decommissioning would be to remove all 

10 radioactively contaminated materials, hazardous materials and chemicals from the site. 

11 Decommissioning programs and procedures would focus on minimizing waste volumes. For 

12 example, as described in Chapter 10 of the License Application (IIFP, 2009a), IIFP would 

13 incorporate design features that would result in minimizing the radioactive waste volumes 

14 including the following: 

15 • A washable coating on floors and walls in the Restricted Areas, which have the potential 

16 to become radioactively contaminated during operation would lower waste volumes 

17 during decontamination and simplify the decontamination process. 

18 • Sealed, nonporous pipe insulation in areas with higher potential to become 

19 contaminated would facilitate cleaning in event of a spill and reduce the waste volume 

20 during decommissioning. 

21 • Tanks would have access for entry and decontamination. Design provisions would be 

22 made to allow complete draining of the wastes contained in the tanks. 

23 • Connections in the process systems would provide access during operation and 

24 maintenance and to allow for thorough purging at plant shutdown which would remove 

25 some radioactive contamination prior to disassembly. 

26 Decommissioning activities would include cleaning to remove radioactive and hazardous 

27 contamination that could be present on materials, equipment, and structures. Wastes produced 

28 during decommissioning would be collected, handled, and disposed of in a manner similar to 

29 that described for the wastes produced during operation. These wastes would consist of 

30 industrial trash, nonhazardous chemicals and fluids, small amounts of hazardous materials, and 

31 radioactive wastes. The radioactive waste would consist primarily of piping, tanks, hoppers, and 

32 compactable trash generated during the dismantling process. 

33 Solid wastes would be generated by decontamination activities and by the removal of used 

34 process equipment. Decontaminated used equipment would be shipped offsite to salvage or 

35 disposal facilities, as appropriate. In the event that structures would be demolished as part of 

36 the decommissioning activities, the demolition material would be shipped offsite for disposal in 

37 permitted disposal facilities. Radioactively- contaminated equipment and materials would be 

38 shipped to a licensed treatment or disposal facility (as appropriate for the material type) or 

39 disposed of in a manner authorized by the NRC. Similarly, materials constituting hazardous 

40 wastes would be shipped to a RCRA-permitted treatment and/or disposal facility or an 

41 appropriate licensed recovery facility. 
 4-67 

1 A detailed estimate of the wastes produced during decommissioning would be provided in the 

2 decommissioning plan that would be submitted to the NRC prior to initiating the 

decommissioning of the plant (IIFP, 2009a). Approximately 56,000,000 L (2 million ft3 3 ) of 

4 commercial LLW were disposed of in the United States in 2008 (NRC, 2010). The estimated 

5 decommissioning LLW generation from decommissioning represents less than 1 percent of the 

6 national annual disposal volume. The LLWs from the decommissioning are expected to be 

7 Class A waste. In its analysis of LLW disposal capacity, the U.S. Government Accountability 

8 Office concluded that the availability of disposal capacity in the United States for Class A LLW is 

9 not considered to be a problem for the short or long term (GAO, 2004). The NRC staff 

10 concludes that the waste management impacts resulting from decommissioning of the IIFP 

11 facility, decontamination, disposal, and closure activities would be SMALL. 

12 4.2 Cumulative Impacts 

13 The CEQ regulations implementing NEPA define cumulative impacts, or effects, as “the impact 

14 on the environment which results from the action when added to other past, present, and 

15 reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or 

16 person undertakes such other actions” (40 CFR 1508.7). In the following analysis, cumulative 

17 impacts are assessed from the anticipated impacts of the proposed construction, operation, and 

18 decommissioning of the proposed IIFP facility when added to other identified projects, facilities, 

19 or activities in the region that have impacts that affect the same resources or human 

20 populations. Effects from the various sources may be direct or indirect and they may be 

21 additive or interactive. Such effects are assessed that, when on their own, may be minor, but in 

22 combination with other effects may produce a cumulative effect that is of greater concern. 

23 To identify the activities in the region that could contribute to cumulative impacts, NRC staff 

24 defined an ROI for each resource that is expected to be affected by the proposed IIFP facility. 

25 An ROI for a particular resource is the size of the surrounding area within which impacts from 

26 multiple sources may be additive or interactive. The sizes of the ROIs may be different for 

27 various resources, and some resources may be remote from the proposed site, such as a waste 

28 disposal facility. Still others might cover large areas, such as a watershed or airshed. 

29 NUREG-1748 (NRC, 2003) states that the surrounding area of the proposed action can range 

30 from less than 1.6 km to 80 km (1 mi to 50 mi). Consistent with NUREG-1748, for the proposed 

31 IIFP facility, an ROI radius of 16 km (10 mi) was identified for the majority of resources. The 

32 exceptions include socioeconomics, for which an ROI radius of 80 km (50 mi) was identified 

33 (Section 3.9); and cultural and historic resources and visual resources, for which an ROI radius 

34 of 10 km (6 mi) was identified (Section 3.3.4). Additionally, in order to assess the potential 

35 cumulative impacts of radiological transportation, the analysis includes consideration of the 

36 URENCO USA/LES uranium enrichment facility and the DOE WIPP, both of which are more 

37 than 16 km (10 mi) from the proposed IIFP facility. 

38 In order to identify projects or activities in the region that could contribute to cumulative effects, 

39 the NRC staff conducted Internet searches, reviewed news media (local newspapers and local 

40 television), and reviewed other relevant NEPA documents (such as the Environmental Impact 

41 Statement for the Proposed National Enrichment Facility in Lea County, New Mexico 

42 [NUREG-1790; NRC, 2005a], the Final Complex Transformation Supplemental Programmatic 

43 Environmental Impact Statement [DOE/EIS-0236-S4; DOE, 2008 ], and the Supplement 

44 Analysis for the Waste Isolation Pilot Plant Site-Wide Operations [DOE/EIS-0026-SA-07, 

45 DOE, 2009]). This cumulative impacts analysis included review of existing activities in the 

46 region that would affect the same resources as the proposed IIFP facility, known past impacts 
 4-68 

1 on these resources, and reasonably foreseeable proposed new projects, activities, or facilities 

2 that could impact these resources. Section 4.2.1 discusses these projects or activities. 

3 4.2.1 Past, Present, and Reasonably Foreseeable Future Actions 

4 Five other projects or actions are identified and described in this section: 

5 1. Preconstruction activities on the proposed IIFP site that could occur prior to NRC issuing a 

6 license for construction, operation, and decommissioning of the proposed IIFP facility. 

7 2. Construction, operation, and decommissioning of Phase 2 of the IIFP facility. 

8 3. Construction, operation, and decommissioning of the URENCO USA/LES uranium 

9 enrichment facility (formerly known as the National Enrichment Facility) in Lea County, New 

10 Mexico. 

11 4. Operation of the DOE WIPP near Carlsbad, New Mexico. 

12 5. Construction and operations related to energy production facilities in the region. 

13 4.2.1.1 Proposed IIFP Facility Preconstruction Activities 

14 The preconstruction activities would be preparatory in nature and would not involve any 

15 radiological process or safety related equipment or systems. Required Federal and State 

16 permits would be obtained prior to the start of preconstruction, and preoperational baseline 

17 environmental samples would be collected. Preconstruction activities for the proposed IIFP 

18 project would include (IIFP, 2011a): 

19 • Clearing land 

20 • Site grading and erosion control 

21 • Installing temporary fencing 

22 • Installing main entrance roadbed and drainage to highway 

23 • Installing construction trailer 

24 • Preparing preliminary site roadways and gravel parking area 

25 • Drilling water wells 

26 • Constructing power substation and electric utility lines 

27 • Stubbing in gas line to the meter 

28 • Beginning administration building construction 

29 • Beginning maintenance and stores building construction 

30 • Beginning warehouse building construction 

31 • Installing geothermal heating/cooling loops 

32 • Installing firewater tanks 

33 • Installing truck washing station 

34 Based on the characteristics of the proposed IIFP site, major grading would not be required. 

35 Excavation would be required for sewer systems, roads, pads, and structure foundations. Less 
 4-69 

1 than 10 percent of the total 259-ha (640-ac) area would be disturbed. The area of clearing 

2 would include locations of buildings, process structures, storage pads and roads. During this 

3 pre-licensing, preconstruction phase, conventional earthmoving and grading equipment would 

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

5 ripping tools. Soil removal work for foundations would be controlled to minimize excavation. In 

6 addition, loose soil and/or damaged caliche would be removed prior to installation of 

7 foundations for seismically-designed structures. Temporary silt fencing and sediment straw 

8 bales would be installed around the areas of construction to entrap silt and to prevent its 

9 migration off site. Drainage trenches and ditch checks would be installed along the entrance 

10 road to prevent run-off and silt from the site moving onto NM 483 right-of-way. Site sloping, 

11 earth berms, underground drainage pipe, and wet sediment retention basins would be installed 

12 to entrap storm water run-off from construction areas (IIFP, 2011a). 

13 The natural gas line feeding the site would be connected to an existing, nearby line. This would 

14 minimize impacts of short-term disturbances related to the placement of the tie-in line. A new 

15 electrical distribution line is proposed for providing electrical service to the IIFP facility. There 

16 are currently 115 and 230 kV transmission lines along US 62/180 and NM 483 and crossing the 

17 site. IIFP anticipates that the additional line would be erected in an existing right(s)-of-way. In 

18 conjunction with the new electrical lines serving the site, the local electrical utility company 

19 would install an independent substation within the 16-ha (40-ac) facility to ensure service 

20 (IIFP, 2011a). 

21 The Clean Water Act NPDES requires an NPDES(s) permit for discharges to surface waters, for 

22 stormwater from construction projects and industrial pollutant discharges. This could include 

23 construction and operation of a facility such as the proposed IIFP. A Spill Prevention, Control, 

24 and Countermeasures (SPCC) plan would also be implemented to prevent and, if necessary, 

25 respond to oil spills. An SPCC plan would be completed and an NPDES Construction 

26 Stormwater Permit with the General Construction Permit would be obtained by IIFP prior to the 

27 implementation of preconstruction activities (IIFP, 2011a), if necessary. 

28 4.2.1.2 Proposed Phase 2 of the IIFP Facility 

29 The proposed Phase 2 project would add additional deconversion capacity at the facility and a 

30 process for the direct deconversion of DUF6 to uranium oxide. Phase 2 construction activities 

31 are proposed to begin in early 2015 and would be completed to support operations by mid-2016 

32 and require a maximum of 180 additional workers (IIFP, 2011a). 

33 Prior to the proposed Phase 2 expansion, IIFP would prepare and submit an amended license 

34 application to the NRC for the Phase 2 facility, including possession of up to 2,200,000 kg 

35 (4,850,120 lb) of DUF6 (compared to the 750,000 kg [1,653,450 lb] of DUF6 that were requested 

36 in the Phase 1 application). IIFP plans to submit a license amendment for this plant expansion 

37 in 2013 (IIFP, 2011a). 

38 During Phase 2 construction, additions are planned for the DUF6 Autoclave Building, the Oxide 

39 Process Building, Direct Oxide Staging Building, and the HF Distillation Annex. The entire site 

40 clearing would occur during preconstruction and Phase 1 construction. No roads would need to 

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

42 required. Hence, no major earth grading or movement would be necessary, but excavation 

43 would be required for sewer and building foundations and floors and for tie-ins for water, natural 

44 gas, and utilities. Excavation for foundations would be minimized. Loose soil and/or damaged 

45 caliche would be removed prior to installation of foundations for seismically designed structures. 
 4-70 

1 Approximately 20 percent more building space would be added to the existing Phase 1 facility. 

2 Considering the total 259-ha (640-ac) area, minimal soil disturbance would occur. Silt fences 

3 and straw bales would be used to control erosion and to protect undisturbed areas (IIFP, 

4 2009a). As part of the Phase 2 plant expansion, another major stack would be added for 

5 venting filtered exhaust gas from the oxide process dust collector system. Phase 2 construction 

6 would be accomplished with an average construction crew of 150 to 180 workers (IIFP, 2011a). 

7 Once the Phase 2 facility is operational in mid-2016, all of the fluorides in the DUF6 could be 

8 directly converted to AHF, and SiF4 and BF3 would not be produced unless warranted by market 

9 conditions for these products. Despite different internal operations, many aspects of the Phase 

10 2 operations that would give rise to potential environmental impacts would be very similar to 

11 those in Phase 1 (IIFP, 2011a). Upon completion of Phase 2, the integrated facility would have 

12 an overall total deconversion capacity of nearly 800 DUF6 cylinders per year; about 9.8 million 

13 kg/yr (21.7 million lb/yr) of DUF6. Nearly 2.6 million kg/yr (5.7 million lb/yr) of AHF product is 

14 projected to be produced and sold (IIFP, 2009a). 

15 The utilities needed to support the Phase 2 facility would be the same as those for the Phase 1 

16 facility, although there would be an increase in overall utility usage (especially electricity and 

17 steam) with the addition of the Phase 2 facility. For example, when the Phase 2 facility 

18 becomes operational, the total steam load would increase to about 2,722 to 3,629 kg/hr 

19 (6,000 to 8,000 lb/hr) compared to 1,134 to 1,588 kg/hr (2,500 to 3,500 lb/hr) for Phase 1 

20 operations (IIFP, 2009a). At the end of its useful life, the IIFP facility would be decommissioned 

21 consistent with the decommissioning plan that is developed. 

22 4.2.1.3 URENCO USA/LES Uranium Enrichment Facility 

23 In December 2003, the LES submitted a license application to the NRC to construct, operate, 

24 and decommission a facility to produce enriched U-235, up to 5 percent weight, by the gas 

25 centrifuge process. The enriched uranium would be used as fuel in commercial nuclear power 

26 plants. The NRC staff issued a Final EIS (NUREG-1790) (NRC, 2005a) and SER 

27 (NUREG-1827) (NRC, 2005b) for the facility in June 2005. In June 2006, the NRC issued LES 

28 a 30-year license to construct and operate the facility with a nominal production capacity of 

29 3 million separative work units (SWUs) per year. On November 21, 2008, LES announced 

30 plans to expand the facility capacity to 5.7 million SWUs per year (NRC, 2010); although a 

31 license application for the facility expansion has not yet been submitted to the NRC. 

32 The URENCO USA/LES Uranium Enrichment facility commenced initial operations on June 11, 

33 2010. Construction of the project will continue until the plant reaches the planned 5.7 million 

34 SWU capacity and full operations are expected in 2015 (assuming a license for the additional 

35 2.7 million SWU is granted by the NRC). The facility is located approximately 32 km (20 mi) 

36 south of Hobbs, New Mexico, 8 km (5 mi) east of Eunice, and approximately 40 km (25 mi) 

south of the proposed IIFP site. DUF6 37 is a waste product of the uranium enrichment process, 

38 and the URENCO USA/LES Uranium Enrichment facility would be one of the likely DUF6

39 suppliers to the IIFP facility. 

40 This cumulative impacts analysis is based on information in the Final EIS (NUREG-1790) 

41 (NRC, 2005a). 

42 
 4-71 

1 4.2.1.4 DOE Waste Isolation Pilot Plant (WIPP) 

2 The WIPP facility is the nation’s first underground repository 

3 permitted to safely and permanently dispose of transuranic 

4 radioactive waste generated by defense-related activities. 

5 Waste generated at DOE sites is shipped to the WIPP and 

6 permanently disposed in an ancient salt formation 655 m 

7 (2,150 ft) below the surface. Over the planned 35-year 

8 operational lifetime ending in 2034, the WIPP is expected to 

9 receive approximately 37,000 shipments of waste from 

10 locations across the United States (DOE, 2008). The WIPP 

11 disposal site is 42 km (26 mi) east of Carlsbad, in Eddy County 

12 in the Chihuahuan Desert of southeastern New Mexico, and 

13 approximately 87 km (54 mi) from the proposed IIFP facility 

14 site. 

15 Waste disposal operations began at the WIPP in March 1999. As of August 2010, the WIPP 

16 has received 8,812 transuranic waste shipments, totaling more than 16.1 million km (10 million 

mi) of transport on U.S. highways of approximately 69,240 m3

 (90,566 yd3 17 ) of transuranic waste. 

18 Based on the most recent transuranic waste inventory data, DOE estimates that approximately 

140,000 m3

 (182,779 yd3 19 ) of transuranic waste either has been disposed of or could be eligible 

20 for disposal at the WIPP (DOE, 2010). 

21 4.2.1.5 Regional Energy Production Facilities 

22 As shown on Figure 3-2 and described in this section, there are four energy production facilities 

23 in the vicinity of the IIFP facility that could contribute to cumulative impacts: 

24 1. Xcel Energy Cunningham Station 

25 2. Xcel Energy Maddox Station 

26 3. Colorado Energy Station 

27 4. DCP Midstream Linam Ranch Natural Gas Processing Facility 

28 The cumulative impacts analysis is based on information in Section 4.1 of this draft EIS, the 

29 Environmental Report submitted by IIFP (IIFP, 2009a), Official Responses to the Environmental 

30 Report Requests for Additional Information (IIFP, 2011a), and the other references identified in 

31 Section 4.2.2. 

32 4.2.2 Cumulative Impacts to Environmental Resources 

33 The potential cumulative impacts are presented for each resource presented in Section 4.1. 

34 4.2.2.1 Land Use 

35 As described in Section 3.2, the proposed IIFP facility would be located in a sparsely populated 

36 area on undeveloped land and near four power and gas industry plants. Present land uses in 

37 the vicinity include cattle grazing and oil and gas development. The preconstruction, 

38 construction, and operation of Phase 1 would disturb less than 10 percent of the total 259-ha 

39 (640-ac) site (IIFP, 2011a). Because approximately 93 percent of Lea County (approximately 

40 1.0 million ha [2.6 million ac]) is used as range land for grazing, the impacts resulting from 

Transuranic Waste 

Transuranic waste is 

waste that contains alphaemitting radionuclides with 

atomic numbers greater 

than uranium (92) and 

half-lives greater than 

20 years, in 

concentrations greater 

than 100 nanocuries per 

gram of waste. 
 4-72 

1 restricting the current land use would be negligible due to the abundance of other nearby 

2 grazing land. There are no zoning restrictions on the property. As described in Section 4.2.1.2, 

3 during the Phase 2 expansion, no roads would be added and only minor revisions to paved or 

4 concrete areas may be required. Hence, no major earth grading and land disturbance would 

5 occur. Therefore, the NRC staff concludes that cumulative impacts on land use from the 

6 preconstruction of the proposed facility, the proposed action, and Phase 2 construction, 

7 operation, and decommissioning would be SMALL. 

8 4.2.2.2 Historic and Cultural Resources 

9 As described in Section 3.3, an archaeological survey of the site conducted in May 2009 

10 identified three isolated artifacts and no archaeological sites. A review of the current listings for 

11 the New Mexico State Register of Cultural Resource Properties and the National Register of 

12 Historic Places indicate no NRHP-listed or eligible historic properties within 10 km (6 mi) of the 

13 proposed site and one State-listed property just less than 10 km (6 mi) south of the IIFP site. 

14 The archaeological consultant recommended no further work based on the survey results. The 

15 NM SHPO concurred with this determination (Appendix B). Preconstruction activities at the 

16 proposed IIFP site and Phase 2 expansion, which would occur within the same footprint as the 

17 proposed action, would have no impact on historic properties, districts, resources or significant 

18 historic/precontact archaeological sites. Therefore, the NRC staff concludes that cumulative 

19 impacts on historic and cultural resources from the proposed action, preconstruction of the 

20 proposed facility, and Phase 2 construction, operation, and decommissioning would be SMALL. 

21 4.2.2.3 Visual Resources 

22 As discussed in Section 3.4, the construction of the proposed facility would occur in a sparsely 

23 populated area with an existing low-quality viewshed. No regionally or locally important high 

24 quality views occur in the vicinity of the proposed IIFP facility. Consequently, the NRC staff 

25 concludes that cumulative impacts would be SMALL. 

26 4.2.2.4 Climatology/Meteorology/Air Quality 

27 4.2.2.4.1 Greenhouse Gases 

28 Greenhouse gas emissions from construction vehicles and equipment were taken into account 

29 in the analysis for Phase 2. During the Phase 2 construction, it was assumed that the workforce 

30 of 180 would commute 2,900,000 km (1,800,000 mi) over the 1-year construction period (250 

31 days). Over the course of the construction period, it was also estimated that there would be 20 

32 deliveries each day each also traveling a distance of 64 km (40 mi). NRC staff used EPA 

33 MOVES to calculate the resulting CO2 emissions associated with workforce commuting and 

34 construction deliveries during Phase 2 construction. The total CO2 equivalent emissions, 

35 expected during the Phase 2 construction period would be 1,303 metric tons (1,435 tons), which 

36 are substantially less than those expected from the Phase 1 construction period. 

37 Using calendar year 2000 as a reference point (the latest year for which New Mexico 

38 greenhouse gas emission data are available), and as shown in Table 3-1, total net CO2

39 emissions for New Mexico for the year 2000 were 62 million metric tons (68 million tons) of CO2

40 equivalents. For the United States for that same year, total net CO2 emissions were 

41 5,977 million metric tons (6,588 million tons) (EPA, 2010a). By comparison, during the Phase 2 

42 construction phase, CO2 emissions are projected to be 1,303 metric tons (1,435 tons), 

43 approximately 0.002 percent of the New Mexico statewide output or 0.00002 percent of the 
 4-73 

1 nationwide emissions for calendar year 2000. Consequently, the NRC staff concludes that 

2 potential cumulative impacts on greenhouse gas emissions would be SMALL 

3 4.2.2.4.2 Air Quality 

4 4.2.2.4.2.1 Air Quality (pre-construction) 

5 Air quality impacts from the operation of construction equipment and support vehicles during the 

6 preconstruction stage were evaluated based on the construction schedules and parameters 

7 provided by IIFP (IIFP, 2011a). The proposed IIFP facility site is 16 ha (40 ac). 

8 Activities that would take place during preconstruction are described in Section 4.2.1.1. IIFP 

9 estimates preconstruction would last for a period of approximately three months, and would be 

10 followed by approximately 12 months of Phase 1 construction (IIFP, 2011b). 

11 During preconstruction, criteria pollutants (e.g., CO, NO2, PM10, PM2.5, and SO2), HAPs, and 

12 VOCs would be generated by the operation of construction vehicles and equipment (operating 

13 at 10 hours a day, 5 days a week), delivery vehicles (estimated at 20 trips a day), and workforce 

14 transport vehicles (estimated at 140 trips per day) traveling to and from the site. These 

15 emissions would include (1) fugitive dust emissions from the disturbance of unpaved surfaces, 

16 (2) combustion emissions from the operation of diesel-fired vehicles and equipment, (3) tailpipe 

17 emissions from the operation of gasoline and diesel-fired commuter and delivery vehicles, and 

18 (4) fugitive HAP and VOC emissions due to evaporative losses from diesel fuel tanks and diesel 

19 fuel transfers. 

20 The quantities of air pollutants that would be generated from preconstruction activities at the 

21 IIFP site were estimated using the equipment list and description of planned activities provided 

22 by IIFP (2011b); and emission factors from the EPA MOVES Model (EPA, 2009a), the EPA 

23 NONROAD model (EPA, 2005), and EPA AP-42 emission factors (EPA, 1995a). Air quality 

24 impacts were evaluated using the EPA SCREEN3 (EPA, 1995b) air dispersion model. 

25 IIFP anticipates that most of the earth moving activities would take place during preconstruction. 

26 Consequently, fugitive dust emission rates would be greater during preconstruction than during 

27 the Phase 1 construction period, however, the 3-month preconstruction period is relatively short. 

28 The estimated pollutant emissions during preconstruction would represent a very small fraction 

29 of the current emissions in Lea County. 

30 Dispersion modeling results show that air pollutant concentrations at the IIFP site boundary 

31 during preconstruction would be similar to the concentrations during Phase 1 construction (See 

32 Appendix C). The estimated incremental increases in ambient background concentrations due 

33 to the proposed preconstruction activities would be above the NAAQS for NO2, PM2.5 and PM10

34 emissions. Pollutant emissions from preconstruction activities potentially could change the 

35 existing ambient air quality in the vicinity of the proposed IIFP facility temporarily. Because 

36 conservative assumptions that tend to overestimate impacts were used to produce these 

37 estimates, actual emissions from the construction activities are expected to be lower. Overall, 

38 the preconstruction impacts would be localized and short-term. 

39 Because preconstruction and Phase 1 construction would not occur simultaneously, the impacts 

40 would not be cumulative. As discussed in Section 3.5.3, Lea County is in attainment for all 

41 criteria pollutants. The cumulative air impacts of preconstruction and other projects in the 

42 region of influence are not expected to change this attainment status. Therefore, the NRC staff 
 4-74 

1 concludes that the air quality impacts resulting from the preconstruction of the proposed IIFP 

2 facility would be MODERATE for NO2, PM2.5, and PM10 emissions and SMALL for other 

3 emissions. BMPs during preconstruction and construction as described in Chapter 5, Mitigation 

4 Measures and Commitments, would reduce impacts to air quality. NRC staff considers the use 

5 of BMPs to minimize impacts to air quality as an environmental commitment. Furthermore, the 

6 NRC staff finds that the BMPs committed to by IIFP would be sufficient to ensure that pre7 construction impacts of the proposed IIFP facility to air quality would be MODERATE for NO2 

8 and particulate emissions; and SMALL for other emissions. 

9 4.2.2.4.2.2 Air Quality (Phase 2 Construction and Operation) 

10 During Phase 2 construction, the process area would be expanded approximately 28 percent to 

11 add a 33.5 m x 33.5 m (110 ft x 110 ft) area next to the Phase 1 process buildings. Less than 

12 1 percent of the 16-ha (40-ac) site area would be disturbed during the Phase 2 construction 

13 period of approximately 1 year (IIFP, 2011a). 

14 Pollutant emissions and diesel fuel consumption attributable to Phase 2 construction activities 

15 were estimated using the equipment list and description of planned activities provided by IIFP 

16 (2011b); and emission factors from the EPA MOVES Model (EPA, 2009a), the EPA NONROAD 

17 model (EPA, 2005), and EPA AP-42 emission factors (EPA, 1995a). Air quality impacts were 

18 evaluated using the EPA SCREEN3 (EPA, 1995b) air dispersion model. 

19 Heavy earth-moving equipment (e.g. dozers, excavators, and graders) would not be required for 

20 Phase 2 construction, so annualized Phase 2 emissions would be approximately 25 percent 

21 less than annualized Phase 1 construction emissions (See Appendix C). The estimated 

22 pollutant emissions during Phase 2 construction represent a very small fraction of the current 

23 emissions in Lea County. 

24 Dispersion modeling results show that air pollutant concentrations at the IIFP site boundary 

25 during Phase 2 construction would be much lower than the concentrations during Phase 1 

26 construction (See Appendix C). The estimated incremental increases in ambient background 

27 concentrations due to the proposed preconstruction activities would be above the NAAQS for 

28 NO2 emissions over a 1-hr averaging time. All other pollutant concentrations were estimated to 

29 be below NAAQS. Pollutant emissions from Phase 2 construction activities potentially could 

30 change temporarily the existing ambient air quality in the vicinity of the IIFP facility with respect 

31 to NO2. Because conservative assumptions that tend to overestimate impacts were used to 

32 produce these estimates, actual emissions from the construction activities are expected to be 

33 lower. Overall, the Phase 2 construction impacts would be localized and short-term. 

34 Because Phase 2 and Phase 1 construction would not occur simultaneously, the impacts would 

35 not be cumulative. As discussed in Section 3.5.3, Lea County is in attainment for all criteria 

36 pollutants. The cumulative air impacts of Phase 2 construction and other projects in the region 

37 of influence are not expected to change this attainment status. Therefore, the NRC staff finds 

38 that the air quality impacts resulting from the construction of the IIFP Phase 2 facility would be 

39 MODERATE for NO2 emissions and SMALL for other air emissions. BMPs used during 

40 construction would reduce the impact of construction activities on air quality. These BMPs are 

41 described in Chapter 5, Mitigation Measures and Commitments. The NRC staff finds that the 

42 BMPs committed to by IIFP for the proposed facility would be sufficient to maintain impacts to 

43 air quality from Phase 2 construction as MODERATE to SMALL. 
 4-75 

1 Greenhouse gas emissions from construction vehicles and equipment were taken into account 

2 in the analysis for Phase 2. During the Phase 2 construction, it was assumed that the workforce 

3 of 180 would commute 2,900,000 km (1,800,000 mi) over the 1-year construction period (250 

4 days). Over the course of the construction period, it was also estimated that there would be 20 

5 deliveries each day each also traveling a distance of 64 km (40 mi). NRC staff used EPA 

6 MOVES to calculate the resulting CO2 emissions associated with workforce commuting and 

7 construction deliveries during Phase 2 construction. The total CO2 equivalent emissions, 

8 expected during the Phase 2 construction period would be 1,303 metric tons (1,435 tons), which 

9 are substantially less than those expected from the Phase 1 construction period. 

10 Greenhouse gas emissions from operation of the IIFP facility would be insignificant (less than 

11 0.1 percent) when compared to the greenhouse gas emissions from the regional energy 

12 facilities. In 2008, the total CO2 emissions from the Cunningham Station, Maddox Station, 

13 Colorado Energy Station, and DCP Midstream Linam Ranch Natural Gas Processing Facility 

14 were more than 1.3 million metric tons (1.43 million tons) (NMED, 2010). 

15 For Phase 2 operations, criteria pollutant emissions attributable to operations are well below 

16 Title V and Class II PSD thresholds. IIFP evaluated regional impacts with SCREEN3 based on 

17 frequency-weighted site-specific meteorological data. Pollutant concentrations at the site 

18 boundary were determined to be well below the NAAQS (IIFP, 2011a). The cumulative air 

19 impacts of Phase 2 operations of the IIFP facility and other projects in the region of influence, 

20 including IIFP Phase 1 operations, are not expected to change the attainment status of Lea 

21 County. Consequently, the NRC staff concludes that potential cumulative impacts on air quality 

22 would be SMALL. 

23 4.2.2.5 Geology, Minerals, and Soil 

24 Preconstruction would occur within about 16 ha (40 ac) of the 259-ha (640-ac) proposed site 

25 (IIFP 2009a; IIFP 2011a); and construction, operation, and decommissioning for Phase 2 would 

26 occur within the previously disturbed 16-ha (40-ac) footprint of the Phase 1 IIFP facility. 

27 Therefore, these actions would have little or no additional impacts on geology, minerals, 

28 seismology, and soil beyond those of the proposed action. 

29 During all preconstruction and Phase 2 construction activities, BMPs would be employed to limit 

30 soil loss and mitigate these impacts. These would include: 

31 • Soil stabilization (e.g. temporary and permanent seeding), 

32 • Structural controls (e.g. hay bales and sediment fences), 

33 • Drainage trenches and ditch checks would be installed along the entrance road to 

34 prevent run-off and silt from the site onto NM 483 right-of-way, and 

35 • Management practices (e.g. construction sequencing, materials delivery sequencing, 

36 physical delineation of disturbed areas) (IIFP, 2011a). 

37 Once the Phase 2 facility is constructed, no additional impacts to geology, minerals, seismicity, 

38 and soil are expected. Thus, the NRC staff concludes that cumulative impacts from 

39 preconstruction of the proposed IIFP facility, the proposed action, and Phase 2 construction, 

40 operation, and decommissioning would be SMALL. 
 4-76 

1 4.2.2.6 Water Resources 

2 Preconstruction activities are not expected to require any use of on-site of groundwater. During 

3 the preconstruction period, up to two new wells would be installed, and capped at the wellheads 

4 for connections to the facility water distribution systems after possible NRC license approval. 

5 For dust control during preconstruction activities, IIFP would bring in tanker trucks of water from 

6 the City of Hobbs municipal system. The City of Hobbs groundwater allocation is included as 

7 part of Lea County’s 40-Year Water Development Plan and preconstruction activities would not 

8 result in cumulative impacts to groundwater use. Site sloping, earth berms, underground 

9 drainage pipe, and wet sediment retention basins would be installed to entrap storm water run10 off from construction areas. As discussed in Section 3.7.2, no permanent surface water or 

11 jurisdictional waters are present on the proposed IIFP site and, therefore, there would not be 

12 any cumulative impacts to surface water. 

Approximately 3.79 m3 13 /day (1,000 gal/day) of groundwater would be required during Phase 2 

14 construction, mainly for dust suppression control, fill compaction, and concrete formation. 

15 Average and peak site water requirements for Phase 2 operations are expected to be 

approximately 11.36 m3

/day (3,000 gal/day) and 37.85 m3 16 /day (10,000 gal/day), respectively. 

17 Phase 2 facility operation would require relatively low volumes of water because it would recycle 

18 process water and re-circulate cooling water. Groundwater use during operation is projected to 

19 be less than 37,854 L (10,000 gal) per day (IIFP, 2011a), and would be below the water 

20 allotment set aside by Lea County. Therefore, the NRC staff concludes that cumulative impacts 

21 to groundwater use from preconstruction of the proposed IIFP facility, the proposed action and 

22 Phase 2 construction and operation would be SMALL. 

23 As summarized in Section 3.13.5, there are four energy production facilities in the vicinity of the 

24 proposed IIFP facility. Each of these facilities uses groundwater from the Ogallala aquifer, as 

25 would the proposed action. The Xcel Energy Cunningham Station, which is adjacent to the IIFP 

26 site, is a zero discharge plant, meaning no process waters are discharged from the plant site. 

27 The cooling water from the Cunningham Station is reused to irrigate pecan orchards. The 

28 groundwater rights and use for the four facilities were allocated prior to the development of the 

29 Lea County 40-Year Water Development Plan and, thus, are not reliant on Lea County’s 

30 assigned unappropriated 4,215.2 ha-m (34,173 ac-ft) per year of water rights. In 2005, the four 

31 energy plants were factored into the Lea County annual groundwater withdrawals of 2,293,700 

32 ha-m/yr (185,952 ac-ft/yr) (McCoy and Perry, 2004). The Lea County 40-Year Water 

33 Development Plan includes an assessment of groundwater use impacts from existing and future 

34 beneficial uses of groundwater. 

35 The National Enrichment Facility operations are expected to use on an average approximately 

87,600 million m3 36 (23.1 million gal) of water annually. For the life of the facility, the National 

Enrichment Facility could use up to 263,000 m3 37 (695 million gal) of the Ogallala waters, 

38 encompassing both construction and operations use. This constitutes a small portion, 0.004 

percent, of the 60 billion m3 39 (49 million ac-ft or 16 trillion gal) of Ogallala reserves in the State of 

40 New Mexico territory. Water use during decontamination and decommissioning would be less 

41 than or equal to the water consumption during operations (NRC 2005a). 

42 As discussed in Section 4.1.2.6, Lea County has allocated up to 175 ac-ft/yr of water rights to 

43 the proposed IIFP site in their 40-year plan, which takes into account existing groundwater 

44 users. As discussed above, the IIFP site’s groundwater use would be much less than this 

45 allotment. In accordance with regulations of the New Mexico Office of the State Engineer for 
 4-77 

1 wells installed in a non-Critical Management Area, the two site wells are not expected to create 

2 drawdowns that exceed the limit of 2.4 m (8 ft) over 40 years, or 0.06 m/yr (0.20 ft/yr). 

3 Therefore, the NRC staff concludes that the cumulative groundwater use impact related to the 

4 Lea County unappropriated water rights from the operation of the four existing energy 

5 production facilities, the National Enrichment Facility, and the activities associated with the 

6 proposed IIFP facility would be SMALL. 

7 With respect to groundwater quality, the Xcel Energy Cunningham Station, which is the closest 

8 energy facility to the proposed IIFP Facility, operated with an unlined cooling tower and boiler 

9 cleanout pond for a number of years. The pond has recently been lined. Xcel Energy 

10 monitoring wells along the western boundary of the proposed IIFP site were installed to monitor 

11 contaminants in groundwater that potentially originated from cooling water pond and/or 

12 agricultural fields. Data since 2004 from these monitoring wells indicate that concentrations of 

13 sulfate, chloride, and total dissolved solids have exceeded New Mexico Water Quality Control 

14 Commission Standards for Groundwater (IIFP, 2011a). 

15 During preconstruction, operations, and decommissioning of the proposed IIFP facility, control 

16 of surface water runoff would be required by the NPDES permit. As a result, no impacts are 

17 expected to surface or groundwater bodies. Stormwater and effluent sampling would be 

18 conducted as required by the NPDES permit to protect surface water quality. In addition, site19 wide groundwater levels would continue to be monitored routinely, and samples from the 

20 groundwater monitoring-well and pumping-well networks would continue to be analyzed to 

21 confirm that cumulative impacts to groundwater quality would be SMALL (IIFP, 2011a). 

22 Therefore, the NRC staff finds that groundwater quality impacts would be SMALL. 

23 4.2.2.7 Ecological Resources 

24 Most of the impacts to ecological resources would occur during the preconstruction activities. 

25 Land clearing would occur within the 16 ha (40 ac) facility area and would destroy the Western 

26 Great Plains Shortgrass Prairie and Apacherian-Chihuahuan Mesquite Upland Scrub vegetation 

27 communities. The amount of vegetation cleared would be limited, to the extent practicable, to 

28 the land area needed for the proposed IIFP facility’s operational, security, and utility 

29 requirements (IIFP, 2011a). However, neither of these vegetation communities provides unique 

30 habitat in the area. The existing natural habitats on the proposed IIFP site and the region 

31 surrounding the proposed site have been previously impacted by domestic livestock grazing, 

32 wildfires, oil/gas pipeline rights-of-way and access roads (IIFP, 2011a). The total area to be 

33 disturbed for the facility (16 ha [40 ac]) represents less than one-tenth of the total site area. 

34 Therefore, the NRC staff finds that the loss of 16 ha (40 ac) of either habitat type, for both direct 

35 and onsite cumulative impacts, would have a SMALL impact on native vegetation in the vicinity 

36 of proposed action. 

37 During preconstruction, an access roadway off of northbound NM 483 would be built to support 

38 construction and delivery of materials to the site during construction. Roadway preconstruction 

39 activities would have a SMALL effect on ecological resources, due to the limited amount of area 

40 involved. 

41 Noise, dust, and air emissions associated with site clearing would be short-lived and represent 

42 only a temporary adverse impact to the biota of the IIFP site (IIFP, 2011a). Removal of the 

43 vegetation and the soil disturbance that would occur during preconstruction activities would 

44 likely destroy nesting substrates for many of the potential breeding bird species found in this 

45 area (see Table 3-17). However, the impacts are not likely to have population-level impacts to 
 4-78 

1 the affected species (SORA, 2011). NMGF has suggested a minimization measure, for 

2 preconstruction to take place outside of the nesting season of migratory birds, which, if 

3 instituted, would impact few nesting activities in the affected habitat. Accordingly, 

4 preconstruction site clearing activities would have a SMALL effect on ecological resources. 

5 Construction of Phase 2, which will occur on recently disturbed land adjacent to the Phase 1 

6 facility, would not affect ecological resources. Accordingly, Phase 2 construction would have a 

7 SMALL effect on ecological resources. 

8 Therefore, the NRC staff concludes that cumulative impacts to ecological resources would be 

9 SMALL. 

10 4.2.2.8 Socioeconomic Resources 

11 Preconstruction activities are assumed to begin in 2011 and to conclude prior to the end of 

12 2011. Initially 35 and later as many as 70 workers would be involved in preconstruction 

13 activities. During preconstruction, the work force would consist of heavy equipment operators 

14 and structural crafts, most of which are expected to come from the ROI. Preconstruction 

15 activities are expected to result in impacts that would be approximately one-fourth to one-half 

16 the impacts presented in Section 4.1.8 for Phase 1 construction. As such, the NRC staff finds 

17 that there would be a correspondingly SMALL impact on housing, taxes, infrastructure and 

18 community services (IIFP, 2011a). 

19 Phase 2 would use a construction crew of 150 to 180 workers. IIFP estimates approximately 

20 27 workers of the construction work force are expected to move into the vicinity as new 

21 residents (15 percent of 180 workers). The increases in area population during Phase 2 

22 construction, therefore, would be approximately the same as Phase 1 construction and the NRC 

23 staff finds that those increases would have SMALL impacts to socioeconomic resources. 

24 The Phase 2 operations of the IIFP facility would require a maximum of 40 additional workers 

25 (IIFP, 2009). Using the same assumptions for the Phase 1 operations workforce, the NRC staff 

26 assumed that 32 workers would already reside in the area, and that 8 would in-migrate. Given 

27 the excess housing, public utilities and capacity in local schools, as described in Section 3.9, the 

28 NRC staff concludes that socioeconomic impacts from Phase 2 operations would be SMALL. 

29 No disproportionately high or adverse impacts would occur to environmental justice populations 

30 in the ROI. The NRC staff finds that the cumulative impacts of preconstruction, the proposed 

31 action and Phase 2 construction and operation on socioeconomic resources would be SMALL. 

32 The URENCO USA/LES Uranium Enrichment facility is expected to employ a maximum of 

33 210 people annually and would indirectly create an additional 173 jobs (NRC, 2005a). 

34 Overall, the NRC staff concludes that the cumulative impacts from the proposed IIFP project 

35 and the UNENCO facility Phase 2 construction and operation are expected to be SMALL.

36 4.2.2.9 Traffic and Transportation 

37 The peak preconstruction workforce is estimated to be 70 employees (INIS, 2011). The 

38 construction work force would predominantly use NM 483 and US 62/180 to access the IIFP 

39 site. The existing AADT of both of these roadways is within the general capacity of 

40 3,400 personal cars per hour for two-lane highways. There would be an increase of a maximum 
 4-79 

Latent Cancer Fatality (LCF) 

A latent cancer fatality (LCF) is a 

fatality associated with acute or 

chronic environmental exposures to 

chemicals or radiation. The fatality 

may occur many years after the 

exposure. 

1 of 140 trips per day, two trips per potential employee, 

2 plus up to 40 additional trips associated with 

3 preconstruction equipment or supply deliveries (IIFP, 

4 2009a). During preconstruction, the roadways would 

5 still operate well within their capacity. There would be 

6 no radiological transportation during preconstruction. 

7 The NRC staff finds that the impacts from increased 

8 traffic during preconstruction would be SMALL and 

9 temporary; therefore, the NRC staff concludes that no 

10 cumulative impacts would occur. 

11 An average construction crew of 150 to 180 workers would be required during the approximately 

12 15-month Phase 2 construction period. Once operational, the workforce at the IIFP facility 

13 would increase from approximately 120-138 for Phase 1 operations to 145-160 for Phase 2 

14 operations. If all the construction traffic used the access road off NM 483 this would result in a 

15 75 percent increase during Phase 2 construction (including construction and operations traffic). 

16 The vast majority of this increase is expected to be on the 2.4 km (1.5 mi) section between the 

17 access road and US 62/180. Compared with the traffic count for the various highways from 

18 2006 through 2008 and the transportation commuting statistics in Lea County from the 2000 

19 census data, the impact of this temporary increase in traffic during Phase 2 construction is 

20 considered to be MODERATE for the peak construction period on NM 483. During construction 

21 of Phase 2 mitigation could include staggering the construction and operations shifts, 

22 encouraging carpooling or providing vans to transport construction workers from remote 

23 locations. Mitigation would reduce the impacts from MODERATE to SMALL. 

24 After Phase 2 is operational, there would be a maximum of 40 additional round trips per day due 

25 to operation workers, resulting in an additional 80 vehicles on the area highways per day which 

26 would not exceed the design capacity of the roadways. The NRC staff finds that operational 

27 traffic would have a SMALL impact on the local transportation pattern. 

28 During Phase 2 operations, the number of radiological shipments (including DUO2 and LLW) per 

29 year would increase from 145 -155 shipments of DUO2 (IIFP, 2011b) during Phase 1 with a total 

30 of approximately 700 radiological shipments (IIFP, 2011b) total, to 450-500 shipments of DUO2

31 (IIFP, 2011b) during Phase 2 with a total of approximately 2,150 radiological shipments (IIFP, 

32 2011b). The number of non-radiological shipments is not expected to change from 1,950 

33 shipments. Therefore during Phase 2 operations, a total of 4,100 shipments are estimated 

34 annually or approximately 16 round trips per day. Compared with the transportation commuting 

35 statistics in Lea County from the 2000 census data and the AADT on the specific highways, the 

36 NRC staff finds that this increase in traffic from operational deliveries and waste removal would 

37 be SMALL for Phase 2 operations. One mitigation measure to be considered by IIFP is to 

38 schedule operations worker shift changes and truck shipments for off-peak traffic periods, when 

39 practical. 

40 The URENCO USA/LES Uranium Enrichment facility truck shipments of feed, product, and 

41 waste materials (including DUF6) could result in 2 LCFs to the general population over the life of 

42 the facility due to vehicle emissions and fewer than 0.03 LCF due to direct radiation. All rail 

43 shipments of feed, product, waste materials, and empty cylinders were estimated to result in 

44 fewer than 0.08 LCF to the general population over the life of the facility, and 0.1 LCF from 

45 direct radiation (NRC, 2005a). 
 4-80 

1 Some adverse transportation impacts are expected as a result of moving the transuranic wastes 

2 from sites across the country to the WIPP. One of the official WIPP routes is US 62/180, which 

3 runs along the southern boundary of the proposed IIFP facility site. DOE estimated that the 

4 non-radiological impacts of transportation related to WIPP operations would result in 

5 approximately one traffic fatality and less than one death from pollution health effects. 

6 Radiological impacts associated with WIPP-related accident-free transportation are expected to 

7 be much less than 1 LCF (DOE, 2009). 

8 The radiological impacts associated with combined Phase 1 and Phase 2 operations would 

9 result in a total population dose of 1.7 person-Sv (170 person-rem) annually. Statistically, this 

10 dose could result in 0.10 LCFs annually. When combined with the radiological transportation 

11 impacts from operation of the LES (0.1 LCFs over the facility life) and radiological transportation 

12 impacts from the WIPP (less than 1 LCF annually), the NRC staff finds that the cumulative 

13 radiological impacts from transportation would be SMALL (less than 1 LCF annually) 

14 (IIFP, 2009a). 

15 4.2.2.10 Noise 

16 As discussed in Section 3.11.2, there are no noise sensitive receptors in close proximity to the 

17 proposed IIFP facility. The nearest commercial facility is the Xcel Energy Cunningham 

18 Generating Station, approximately 1.6 km (1 mi) west of the proposed site. The nearest 

19 residence is approximately 2.6 km (1.6 mi) northwest of the site and there are no recreational 

20 facilities areas within 8.0 km (5.0 mi) of the proposed site. Because of the absence of any 

21 sensitive noise receptors, no noise impacts are anticipated during preconstruction activities and 

22 Phase 2 construction activities and no cumulative impacts would occur. 

23 Cumulative impacts from all site noise sources would remain at or below HUD guidelines of 

24 65 dBA Ldn (24 CFR 51), and the EPA guidelines of 55 dBA Ldn, (EPA, 1974) at the site 

25 boundary during IIFP facility construction and operation. Therefore, the NRC staff concludes 

26 that the cumulative noise of all site construction and operation activities, even when considered 

27 in conjunction with surrounding regional energy production facilities would have a SMALL 

28 impact and to only those receptors closest to the site boundary. 

29 4.2.2.11 Public and Occupational Health 

30 The preconstruction activities have the potential to cause industrial accidents, material-handling 

31 accidents, falls, etc., that could result in temporary injuries, long-term injuries and/or disabilities, 

32 and even fatalities. The proposed activities are not anticipated to be any more hazardous than 

33 the construction activities discussed in Section 4.1.1.11. The preconstruction workforce would 

34 be smaller than the construction workforce and the duration of preconstruction would be less 

35 than that of construction. Less than six nonfatal injuries and no fatalities (less than one fatality) 

36 are expected during preconstruction activities. Therefore, the NRC staff concludes that 

37 preconstruction health and safety impacts would be SMALL. 

38 The Phase 2 construction activities have the potential to cause industrial accidents, material39 handling accidents, falls, etc., that could result in temporary injuries, long-term injuries and/or 

40 disabilities, and even fatalities. The proposed activities are not anticipated to be any more 

41 hazardous than the construction activities discussed in Section 4.1.1.11. The Phase 2 

42 construction workforce would be slightly larger than the Phase 1 construction workforce, and 

43 less than 13 nonfatal injuries and no fatalities (less than 1 fatality) are expected during Phase 2 

44 construction activities. 
 4-81 

1 Once operational, the workforce at the IIFP facility would increase from 140 for Phase 1 

2 operations to 180 for Phase 1 and Phase 2 operations. Statistically, this would increase the 

3 potential number of both nonfatal and fatal occupational injuries by approximately 10 - 

4 15 percent. Overall, less than seven nonfatal injuries and no fatalities (less than 1 fatality) are 

5 expected annually during the proposed operation of Phase 1 and Phase 2. 

6 The NRC staff finds that radiological impacts associated with operation of the Phase 2 facility 

7 would be SMALL. The differential in the total population dose between the integrated Phase 1 

and Phase 2 operations and Phase 1 operations alone would be an increase of 2.33 ×10-4 8 

person-Sv/yr (2.33 ×10-2 9 person-rem/year). The differential in the dose to the MEI would be 

1.62 ×10-8 person-Sv/yr (1.62 ×10-6 10 rem/yr). The differential between the two operational 

phases for the dose to the nearest resident would be 1.18 ×10-8 Sv/yr (1.18 ×10-6 11 rem/year) 

12 (IIFP, 2011a). The difference, therefore, between operational phases is very low. 

13 The types of postulated accidents and release scenarios for the Phase 2 facility would not differ 

14 from those already addressed in Phase 1 operations because Phase 2 operations only add 

15 inventory and capacity; no new types of chemical or radiological risks would be added. As 

16 such, the types of accidents and the description of postulated accidents for the Phase 1 facility 

17 would be representative of the range of credible accidents associated with the Phase 2 facility. 

18 Therefore, the NRC staff concludes that the cumulative impacts to occupational and public 

19 health from preconstruction, the proposed action, and Phase 2 construction and operations 

20 would be SMALL. 

21 4.2.2.12 Waste Management 

22 As discussed in Section 4.1.1.12, the NRC staff finds that the quantities of wastes generated 

23 during construction of the proposed IIFP facility would result in SMALL impacts that could be 

24 managed effectively. Approximately 300-500 kg (650-1,100 lbs) of solid waste and 270–820 kg 

25 (600-1,800 lbs) of hazardous waste would be generated (INIS, 2011). Preconstruction activities 

26 are expected to generate waste types similar to and with volumes less than those estimated for 

27 construction (IIFP, 2011a). No radiological wastes would be generated during preconstruction. 

28 As a point of comparison, the operation of the National Enrichment Facility would generate 

29 approximately 172,500 kg (380,400 lbs) of solid nonradioactive waste annually, including 

30 approximately 1,900 L (500 gal) of hazardous liquid wastes (NRC, 2005a). Approximately 

31 87,000 kg (191,800 lbs) of radiological and mixed waste would be generated annually, of which 

32 approximately 50 kg (110 lbs) would be mixed waste. When added to the wastes from other 

33 waste generators, such as the National Enrichment Facility, the NRC staff finds that the impacts 

34 and cumulative impacts of disposal of hazardous and solid (nonhazardous) wastes from 

35 preconstruction activities of the proposed IIFP facility would be SMALL. 

36 Phase 2 construction would necessitate connections to existing Phase 1 facilities and 

37 installation of additional autoclaves (IIFP, 2011b). Radiological materials would not be used in 

38 the construction of the Phase 2 facility. However, Phase 2 construction involving connections to 

39 Phase 1 facilities could result in generation of radioactive wastes. The construction waste types 

40 and volumes would be similar to those during Phase 1 construction. Tables 4-38 through 4-40 

41 provide the estimated annual quantities of solid, hazardous, and radioactive wastes generated 

42 during Phase 2 construction. 
 4-82 

1 Table 4-38. Phase 2 Construction Solid Waste Generation 

Waste Type Estimated Annual Amount 

Air filters(vehicle) 23 – 45 kg 

(50 – 100 lbs) 

Cardboard / packing 136 – 227kg 

(300 – 500 lbs) 

Fiber drums 136 – 318 kg 

(300 – 700 lbs) 

Total 

295 – 590 kg 

(650 – 1,300 lbs) 

2 Source: IIFP, 2011a 

3 

4 Table 4-39. Phase 2 Construction Hazardous Waste Generation 

Waste Type Estimated Annual Amount 

Adhesives, resins, caulking residues 54 – 109 kg 

(120 – 240 lbs) 

Lead (batteries) 45 –113 kg 

(100 – 250 lbs) 

Oil filters 45 – 91 kg 

(100 – 200 lbs) 

Paints, thinners, solvents, organic residues 45 – 227 kg 

(100 – 500 lbs) 

Pesticides 45 – 68 kg 

(100 – 150 lbs) 

Petroleum products, oils, lubricants residues 45 – 227 kg 

(100 – 500 lbs) 

Total 281 – 835 kg 

(620 – 1,840 lbs) 

5 Source: IIFP, 2011a 

6 

7 Table 4-40. Phase 2 Construction Radioactive Waste Generation 

Material Estimated Annual Amount 

Scrap metal 1,800 – 2,700 kg 

(4,000 – 6,000 lbs) 

Spent blasting sand 45 kg 

(100 lbs) 

Wood trash (pallets) 450 – 680 kg 

(1,000 – 1,500 lbs) 

Total 2,300 – 3,400 kg 

(5,100 – 7,600 lbs) 

8 Source: IIFP, 2011a. 

9 

10 As described in Section 4.1.1.12, all construction wastes would be transferred offsite to licensed 

11 waste disposal facilities with adequate disposal capacity for the estimated volumes. Thus, it is 

12 also anticipated by NRC staff that the waste management impacts from Phase 2 construction 

13 would be SMALL. 

14 The URENCO USA/LES Uranium Enrichment facility commenced initial operations on June 11, 

15 2010 and full operations are expected in 2015. Projected waste volumes from the enrichment 

16 facility operations include 173,000 kg/yr (380,400 lb/yr) of solid waste; 1,890 kg/yr (4,165 lb/yr) 

17 of hazardous and mixed waste; and 87,000 kg/yr (191,800 lb/yr) of LLW (NRC, 2005b). DUF6 is 

18 a waste product of the uranium enrichment process, and the URENCO USA/LES Uranium 
 4-83 

1 Enrichment facility would be one of the likely DUF6 suppliers to the proposed IIFP facility. The 

2 enrichment facility will produce depleted uranium at a rate of 627 cylinders or 7,800 metric 

3 tons/yr (NRC, 2005b). During Phase 1, the proposed IIFP facility would process 266 cylinders 

4 annually of DUF6 as feed to the deconversion process. 

5 Solid waste from the enrichment facility would be disposed of at the Lea County Landfill along 

6 with waste from the proposed IIFP facility. The solid waste generated by the enrichment facility 

7 would potentially increase the volume of wastes received at the landfill by less than 0.03 percent 

8 (NRC, 2005b). That increase in combination with the highest IIFP annual solid waste 

9 generation rate (during Phase 1 and Phase 2 operations) would result in less than 0.1 percent 

10 change in the waste received by the Lea County Landfill. Hazardous waste generated by the 

11 enrichment facility (less than 1, 814 kg [2 tons] per year) and the proposed IIFP facility (up to 

12 154 tons/yr during Phase 1 operations) represents less than 0.02 percent of the hazardous 

13 waste managed in the state of New Mexico (more than 1 million tons in 2009). The NRC staff 

14 finds that the combined impacts of managing the solid and hazardous wastes generated by both 

15 facilities on the available capacity would be SMALL. 

16 In the final EIS for the URENCO USA/LES Uranium Enrichment facility (NUREG-1790; NRC, 

17 2005a), NRC staff considered the impacts of conversion of the DUF6 from the enrichment 

18 process (up to 15,727 cylinders over the operating life) to depleted U3O8 and disposal of the 

19 resulting Class A LLW in a licensed disposal facility. The NRC staff concluded that both the 

20 environmental impacts of shallow land disposal such as the EnergySolutions site in Clive, Utah, 

21 and the effect on national disposal capacity for Class A LLW would be SMALL. The 

22 deconversion of DUF6 by the proposed IIFP facility and disposal of the resulting DUO2 as Class 

23 A LLW represents a subset of the impacts previously considered in NUREG-1790 (NRC, 2005a) 

24 (the oxide form of the converted depleted uranium waste, whether U3O8 or UO2, would not 

25 materially change the consequences). Therefore, the NRC staff concludes that the cumulative 

26 effects of the management of depleted uranium wastes from the proposed IIFP facility and the 

27 URENCO USA/LES Uranium Enrichment facility would be SMALL. 

28 The wastes from Phase 2 construction would generate much less than 1 percent of the annual 

29 wastes from the National Enrichment Facility (172,500 kg [380,400 lbs] of solid nonradioactive 

30 waste and approximately 87,000 kg [191,800 lbs] of radiological and mixed waste). Based on 

31 available capacities at hazardous, solid, and radioactive waste treatment and disposal sites, and 

32 the expectation that there would be no large developments in the Hobbs area that would cause 

33 a significant increase in municipal waste disposal volume, the NRC staff finds that the 

34 cumulative impacts from hazardous, solid, and radioactive waste generation would be SMALL. 

35 As described in Section 4.1.2.12, the NRC staff finds that the impact of disposal of hazardous, 

36 solid, and radioactive wastes from operation of the proposed Phase 1 IIFP facility at the 

37 appropriate offsite facilities would be SMALL. Phase 2 operations would generate waste types 

38 similar to those during Phase 1 operations. The hazardous waste volumes are expected to be 

39 lower and LLW volumes higher than from the Phase 1 facility. 

40 The cumulative LLW generation rate during combined Phase 1 and 2 operations would be about 

41 three times higher than from Phase 1 alone. Most of that increase would result from tripling the 

42 production of DUO2. The generation rate of other LLW streams (e.g., trash, waste drums and 

43 pallets) would also increase with the expanded Phase 2 facility. Tables 4-41 through 4-43 

44 provide the estimated annual waste quantities generated during combined Phase 1 and 2 

45 operations, for solid, hazardous, and radioactive wastes, respectively. 
 4-84 

1 The cumulative solid waste generation (up to 49,900 kg [55 tons] per year) would be 20 percent 

2 greater than during Phase 1 operations. Cumulative Phase 1 and 2 operations would result in 

3 an increase of approximately 0.07 percent in the waste that the Lea County landfill receives 

4 annually from all other sources. The NRC staff finds that this quantity of nonhazardous waste 

5 material would result in SMALL impacts that could be managed effectively. 

6 The quantity of cumulative hazardous waste could be as much as 46,300 kg (51 tons) per year 

7 if a market for the CaF2 cannot be identified. As discussed in Section 4.1.1.12, hazardous 

8 waste generators in New Mexico accounted for 978,554,778 kg (1,078,672 tons) of hazardous 

9 waste in 2009 (EPA, 2010b). The maximum cumulative generation rate would result in an 

10 increase of less than 0.005 percent in the hazardous waste generated in the State of New 

11 Mexico. 

12 DUO2 and other radiological waste would be shipped offsite to licensed disposal facilities. As 

13 shown in Table 4-43, up to 9,168,009 kg (10,106 tons) per year of LLW could be sent for 

14 disposal each year. Most of the estimated annual LLW generation (approximately 99 percent) 

15 would be the DUO2 produced by the deconversion process. Assuming 450 kg (1,000 lbs) per 

16 oxide drum, Phase 1 and 2 operations would result in 8,700 to 20,000 drums of material being 

17 sent for disposal. This uranium oxide waste volume represents 3.1 percent to 7.2 percent of the 

18 annual commercial waste volume currently received at the EnergySolutions facility in Clive, 

19 Utah (NRC, 2010). The Clive facility accepts the majority of the United States’ Class A waste 

20 and is estimated to have capacity to accept this waste at current volume levels for more than 20 

21 years (GAO, 2004). The NRC staff finds that the estimated generation of depleted uranium 

22 oxide and other LLW from the Phase 2 deconversion process would result in SMALL impacts to 

23 LLW disposal capacity. 

24 The wastes generated during cumulative Phase 1 and 2 operations would be transferred offsite 

25 to licensed waste facilities with adequate disposal capacity for the estimated volumes. Thus, 

26 the NRC staff anticipates that the waste management impacts from cumulative operations 

27 would be SMALL. 

28 Table 4-41. Cumulative Solid Waste Generation – Phase 1 and 2 IIFP Facility 

Material Estimated Annual Amount 

Clothing 68 – 136 kg 

(150 – 300 lbs) 

Molecular sieve 136 – 227 kg 

(300– 500 lbs) 

Municipal trash waste 32,659 – 48,988 kg 

(72,000 – 108,000 lbs) 

Safety gear 181 – 363 kg 

(400 – 800 lbs) 

Waste Glass 34 – 136 kg 

(75 – 300 lbs) 

Total 33,078 – 49,850 kg 

(72,925 – 109,900 lbs) 

29 Source: IIFP, 2011a 

30 
 4-85 

1 Table 4-42. Cumulative Hazardous Waste Generation -– Phase 1 and 2 IIFP Facility 

Material Estimated Annual Amount 

Aerosol cans, paints cans, bulbs 907 – 1,814 kg 

(2,000 – 4,000 lbs) 

Calcium fluoride* 27,216 – 40,823 kg 

(60,000 – 90,000 lbs) 

Lab chemicals 91 – 182 kg 

(200 – 400 lbs) 

Oil sorb 1,361 – 3,175 kg 

(3,000 – 7,000 lbs) 

Total* 29,574 – 45,994 kg 

(65,200 – 101,400 lbs) 

2 Source: IIFP, 2011a 

3 *Includes calcium fluoride which would not be waste if sold. 

4 

5 Table 4-43. Cumulative Radioactive Waste Generation – Phase 1 and 2 IIFP Facility 

Material Estimated Annual Amount 

Activated alumina 907 – 1,814 kg 

(2,000 – 4,000 lbs) 

Air ventilation filters 29 – 45 kg 

(65 – 100 lbs) 

Carbon 11,340 – 13,608 kg 

(25,000 – 30,000 lbs) 

DUF4 clinkers 2,268 – 4,536 kg 

(5,000 – 10,000 lbs) 

Coke 3,629 – 5,443 kg 

(8,000 – 12,000 lbs) 

Crushed drums 907 – 3,629 kg 

(2,000 – 8,000 lbs) 

Dust collector bags 454 – 1,361 kg 

(1,000 – 3,000 lbs) 

Ion exchange resin 907 – 1,814 kg 

(2,000 – 4,000 lbs) 

Oxide for burial (plus drums) 3,946,258 – 9,071,858 kg 

(8,700,000 – 20,000,000 lbs) 

Radioactive waste trash 31,752 – 45,359 kg 

(70,000 – 100,000 lbs) 

Scrap metal 5,443 – 7,257 kg 

(12,000 – 16,000 lbs) 

Sintered metal tubes 907 – 1,361 kg 

(2,000 – 3,000 lbs) 

Sodium fluoride 907 – 1,814 kg 

(2,000 – 4,000 lbs) 

Spent blasting sand 45 – 91 kg 

(100 – 200 lbs) 

Wood trash (pallets) 1,361 – 5,443 kg 

(3,000 – 12,000 lbs) 

Total 4,007,115 – 9,167,702 kg 

(8,834,165 – 20,211,300 lbs) 

6 Source: IIFP, 2011a 

7 
 4-86 

1 4.3 No-Action Alternative 

2 As presented in Section 2.2 of this draft EIS, the no-action alternative would be to not construct, 

3 operate, and decommission the proposed IIFP facility in Lea County, near Hobbs, New Mexico. 

4 As discussed in Section 2.1, IIFP expects to carry out preconstruction activities (i.e., site 

5 preparation and non-safety related construction activities) prior to issuance of a license by NRC. 

6 If NRC does not ultimately grant IIFP a license for the proposed plant, these would be activities 

7 associated with the no-action alternative. 

8 Preconstruction would be overseen by the NMED and Lea County, pursuant to applicable 

9 permit requirements. NMED state permits would include those listed in Section 1.4, including 

10 stormwater controls, and erosion and sedimentation controls. A New Mexico Department of 

11 Transportation right-of-way permit would be required in order to construct access to NM 483. 

12 Lea County ordinances would require adherence to applicable building codes and fire code 

13 standards. There could be additional activities at the proposed site in the future under the no14 action alternative that could have (adverse or beneficial) impacts on the environment and 

15 community. The impacts associated with these activities would depend on what IIFP would 

16 decide to do with the proposed site or the improvements (e.g., access roads, buildings, etc.) 

17 already constructed on the site, should the license not be granted. The conclusions presented 

18 in this section for the no-action alternative address the impacts of denying the license, but do 

19 not include the impacts of the NRC-approved preconstruction activities, which have been 

20 discussed in Section 4.2.2, Cumulative Impacts. 

21 Under the no-action alternative, as discussed in Section 2.2.1, commercial uranium enrichment 

22 facilities would continue to store depleted uranium. DOE, which operated three gaseous 

23 diffusion plants near Oak Ridge, Tennessee, Piketon, Ohio, and Paducah, Kentucky, as part of 

24 the process of enriching uranium for civilian and defense applications, and would continue to 

25 deconvert its stockpiles of DUF6. In the future, DOE deconversion technology and recently 

26 constructed deconversion plants at Paducah and Piketon would become available to deconvert 

27 commercial DUF6. However, this would only occur when all of the DOE’s DUF6 stockpiles at 

28 Oak Ridge, Portsmouth, and Paducah are deconverted which is projected to take 25 years. 

29 Therefore, the no-action alternative would involve long term storage of depleted uranium at 

30 commercial enrichment facilities until such time as DOE could accept DUF6 from facilities other 

31 than its own. 

32 As discussed in Section 2.2.2, other alternatives, including Alternative Sites, Alternative 

33 Technologies, Overseas Shipment, Indefinite Storage, or deconversion at the commercial 

34 enrichment plants, have been dismissed for various reasons, and it is, therefore, assumed that 

35 none of those alternatives would occur. The environmental impacts of deconversion 

36 alternatives involving other sites and technologies would have impacts similar to or greater than 

37 the impacts from the Proposed Action. Alternatives involving overseas shipment would involve 

38 unreasonable shipment costs, increased potential for adverse transportation-related impacts, 

39 and potentially unacceptable risks. Indefinite storage is not practical or reasonable compared to 

40 the benefits of added commercial fluoride product and increased safety afforded by the 

41 deconversion process. Deconversion onsite at commercial uranium enrichment facilities is not 

42 feasible, considering technological and marketing advantages of using existing DOE facilities 

43 and/or the proposed IIFP facility. Therefore, the no-action alternative is limited to the Proposed 

44 Action, and its affiliated positive or adverse effects, not occurring. 
 4-87 

1 The no-action alternative assumes that preconstruction occurred within the 16-ha (40-ac) facility 

2 and that fencing was erected around the 259-ha (640-ac) proposed IIFP site. Impacts from the 

3 no-action alternative to affected resources are as follows: 

4 LAND USE: If the fencing was not removed, it would restrict cattle grazing. Other land uses in 

5 the vicinity of the site would be unaffected. A Site Redress Plan (SRP) could be required by 

6 NRC. The SRP could require the site to be restored to original grade and condition, including 

7 removal of fencing. The NRC staff finds that impacts to local land use would be SMALL, 

8 because of the amount of land adversely affected compared to the large amount of land 

9 available in the vicinity. 

10 HISTORIC AND CULTURAL RESOURCES: For the same reasons as described for the 

11 proposed action, the NRC staff finds that impacts to historic and cultural resources would be 

12 SMALL and would result in no effect on historic properties, districts, resources or significant 

13 historic/precontact archaeological sites. 

14 VISUAL RESOURCES: The existing character of the area would be altered only within the 

15 preconstruction area perimeter and access road. This disturbance would be limited to less than 

16 ten percent of the Section 27 (IIFP) site, and the NRC could require that all structures be 

17 removed. Therefore, the NRC staff finds that impacts would be SMALL. 

18 CLIMATE, METEOROLOGY, AND AIR QUALITY: Impacts to air quality from preconstruction 

19 activities would be small, localized, and temporary. Local and global atmospheric conditions 

20 would not be altered noticeably, and the NRC staff finds that impacts to air quality would be 

21 SMALL. 

22 GEOLOGY, MINERALS, AND SOILS: Land disturbance from preconstruction clearing, grading, 

23 and excavation would have occurred. For reasons discussed in Section 4.2.2.5, the NRC staff 

24 finds that the impacts would be SMALL. 

25 WATER RESOURCES: Consumptive use of water for preconstruction is anticipated (dust 

26 suppression and domestic use for workers). Water would be brought to the IIFP site by tanker 

27 trucks from the Hobbs municipal water system, which has adequate capacity. No surface water 

28 is present on the site, and so no impacts to surface water quality, including from sedimentation 

29 are expected. Water tanker trucks used for preconstruction would likely obtain water from 

30 groundwater wells within the region, near to, but not within the IIFP site. As indicated in Section 

31 4.1.2.6.1, the NRC staff finds that impacts to surface water and groundwater would be SMALL. 

32 ECOLOGICAL RESOURCES: Preconstruction would result in the loss of vegetation and 

33 terrestrial habitat. Some wildlife may be destroyed. This disturbance would be limited to less 

34 than 10 percent of the 259-ha (640-ac) site. If NRC requires an SRP, the site could be restored 

35 to near original grade and condition, including replanting or re-seeding to allow vegetation to 

36 reclaim the facility location. The NRC staff finds that impacts to ecological resources would be 

37 SMALL. 

38 SOCIOECONOMICS AND ENVIRONMENTAL JUSTICE: Any consequences of the 

39 construction, operation, and decommissioning of the proposed IIFP facility (positive or adverse) 

40 would not occur and socioeconomic conditions in the ROI would remain unchanged. Population 

41 in the ROI would grow in accordance with current projections. The socioeconomic 

42 characteristics of the region, including housing availability, school enrollment, availability of 

43 health service resources, and law enforcement and firefighting resources, would not be affected 
 4-88 

1 by the proposed action. The no-action alternative would not cause any high and adverse 

2 impacts, including to low-income and minority populations. Therefore, there would not be any 

3 environmental justice concerns. The NRC staff finds that impacts of no action on 

4 socioeconomic conditions, including those of low-income and minority populations, in the region 

5 would be SMALL. 

6 TRAFFIC AND TRANSPORTATION: There would be no increased traffic as a result of the no7 action alternative. The NRC staff finds that impacts to the regional and national traffic and 

8 transportation system would be SMALL. 

9 NOISE: Temporary, slight increases in ambient noise levels in the immediate area of the facility 

10 would occur during preconstruction, however, other than those temporary increases in local 

11 noise, the no-action alternative would not affect ambient noise levels. No changes in land use 

12 plans or traffic are expected. Therefore, based on all of these considerations, the NRC staff 

13 finds that impacts to noise would be SMALL. 

14 PUBLIC AND OCCUPATIONAL HEALTH: Except for the potential for construction-related 

15 injuries during preconstruction, the no-action alternative would not affect public or occupational 

16 health. Therefore, the NRC staff finds that impacts to public and occupational health would be 

17 SMALL. 

18 WASTE MANAGEMENT: The no-action alternative would not be expected to cause changes in 

19 management of solid, hazardous, or mixed waste in the region. No radiologically contaminated 

20 waste would be generated during preconstruction or to meet the requirements of the SRP, and, 

21 therefore, the NRC staff finds that impacts to waste management, would be SMALL. 

22 ACCIDENTS: The no-action alternative would not cause accidents to occur within the IIFP 

23 facility. Therefore, the NRC staff finds that impacts from accidents would be SMALL. 

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35 ML103080536. 

36 (McCoy and Perry, 2004) McCoy, A.M., and R.L. Perry. 2004. Second Draft, Lea County Deep 

37 Aquifer Study. Prepared for Lea County Water Users Association. John Shomaker & 

38 Associates, Inc. ADAMS Accession No. ML103080447. 

39 (Neuhauser and Kanipe, 2003) Neuhauser, K. S. and F. L. Kanipe. 2003. RADTRAN 5 User 

40 Guide. SAND2000-2354. Sandia National Laboratory, Albuquerque, New Mexico. July 7, 

41 2003. 
 4-92 

1 (NMDOT, 2009) New Mexico Department of Transportation. Consolidated Highway Database 

2 (CHDB). Website no longer accessible online. Accessed April, 10, 2009. ADAMS Accession 

3 No. ML112860287. 

4 (NMED, 2009) New Mexico Environment Department, Solid Waste Bureau. 2009. New Mexico 

5 Solid Waste Annual Report, 2009. Available at http://www.nmenv.state.nm.us/swb/documents/ 

6 2009FinalAR.pdf. Accessed September 23, 2009. ADAMS Accession No. ML112720586. 

7 (NMED, 2010) New Mexico Environment Department. 2010. Frequently Asked Questions, 

8 Proposed Greenhouse Gas Cap-and-Trade Rule, Updated June 8, 2010. Available at 

9 http://www,nmenv.state.nm.us/aqb/ghg/documents/FAQ_Rev06082010.pdf. Accessed August 

10 17, 2010. ADAMS Accession No. ML 103430404. 

11 (NMJC, 2011) New Mexico Junior College. 2011. NMJC State of the College Report. Available 

12 at http://www.nmjc.edu/assets/documents/NMJC State of the College Report 2011.pdf. 

13 Accessed March 10, 2011. ADAMS Accession No. ML112720596. (NMOSE, 2009a) New 

14 Mexico Office of the State Engineer. 2009. Lea County Underground Water Basin Guidelines 

15 for Review of Water Right Applications. Adopted September 16, 2009. Available at 

16 http://www.ose.state.nm.us/PDF/RulesRegsGuidelines/LeaCounty/ LeaCountyGuidelines-2009-

17 09-16.pdf. Accessed July 29, 2010. ADAMS Accession No. ML103080986. 

18 (NMOSE, 2009b) New Mexico Office of the State Engineer. 2009. Documentation of the Lea 

19 County Underground Basin Guidelines for the Review of Water Right Applications. December 

20 1, 2009. Available at http://www.ose.state.nm.us/PDF/RulesRegsGuidelines/LeaCounty/ 

21 GuidelineBasis-LeaCo-Report-2009-12-01.pdf. Accessed March 1, 2011. ADAMS Accession 

22 No. ML112720601. 

23 (NMOSE, 2010) New Mexico Office of State Engineer. 2010. Lea County Wells with Well Logs. 

24 Available at http://nmwrrs.ose.state.nm.us/nmwrrs/index.html. Accessed July 29, 2010. 

25 (NRC, 1977) U. S. Nuclear Regulatory Commission. 1977. Final Environmental Impact 

26 Statement on the Transportation of Radioactive Material by Air and Other Modes, NUREG/CR27 0170. Office of Standards Development. Washington, D.C. December 1977. 

28 (NRC, 1990) U.S. Nuclear Regulatory Commission. 1990. Control Room Habitability System 

29 Review Methods, NUREG/CR-5659. Division of Safety Resolution. Washington, D.C. 

30 December, 1990. 

31 (NRC, 1991) U.S. Nuclear Regulatory Commission. 1991. Chemical Toxicity of Uranium 

32 Hexafluoride Compared to Acute Effects of Radiation, Final Report, NUREG-1391. Office of 

33 Nuclear Regulatory Research. Washington, D.C. February 1991. 

34 (NRC, 1998) U.S. Nuclear Regulatory Commission. 1998. Nuclear Fuel Cycle Facility Accident 

35 Analysis Handbook, NUREG/CR-6410. Office of Nuclear Regulatory Research. Washington, 

36 D.C., March 1998. 

37 (NRC, 2003) U.S. Nuclear Regulatory Commission. 2003. Environmental Review Guidance for 

38 Licensing Actions Associated with NMSS Programs, Final Report, NUREG-1748. Division of 

39 Waste Management, Office of Nuclear Material Safety and Safeguards. Washington, D.C., 

40 August 2003. ADAMS Accession No. ML032450279. 
 4-93 

1 (NRC, 2005a) U. S. Nuclear Regulatory Commission. 2005. Final Environmental Impact 

2 Statement for the National Enrichment Facility in Lea County, New Mexico NUREG-1790. 

3 Office of Nuclear Materials Safety and Safeguards. Washington, D. C. June 2005. ADAMS 

4 Accession No. ML051730238 and ML051730292. 

5 (NRC 2005b) U. S. Nuclear Regulatory Commission. 2005. Safety Evaluation Report for the 

6 National Enrichment Facility in Lea County, New Mexico, Louisiana Energy Services NUREG7 1827. Office of Nuclear Materials Safety and Safeguards. Washington D.C. June 2005, 

8 (NRC, 2006) U.S. Nuclear Regulatory Commission. 2006. Consolidated Decommissioning 

9 Guidance, NUREG-1757. Office of Nuclear Material Safety and Safeguards. Washington, D.C., 

10 September 2006. 

11 (NRC, 2010) U.S. Nuclear Regulatory Commission. 2010. Low-Level Waste Disposal 

12 Statistics. Available at http://www.nrc.gov/waste/llw-disposal/licensing/statistics.html. Accessed 

13 February 26, 2011. 

14 (NRC, 2011) U.S. Nuclear Regulatory Commission 2011, “Revised Table 4-35.” Personal 

15 communication between A. Malliakos, NRC and T. Harvey, et al., Straughan Environmental. 

16 August 9, 2011. 

17 (Saricks and Tompkins, 1999) Saricks, C. L. and M. M. Tompkins. 1999. State-level Accident 

18 Rates of Surface Freight Transportation: a Re-examination, ANL/ESD/TM-150. Argonne 

19 National Laboratory, Argonne, Illinois. April, 1999. ADAMS Accession No. ML112720605. 

20 (SORA, 2011) SORA. 2011. Lesser Prairie-Chicken Survey on the International Isotopes 

21 Fluorine Products Project Site-2011. Prepared for: International Isotopes, Inc. May 24, 2011. 

22 ADAMS Accession No. ML112720317. 

(TRB, 2000) Transportation Research Board. 2000. Highway Capacity Manual 2000, 3rd 23 . Ed. 

24 National Academy of Sciences Research Council. Washington, D.C., 2000. 

25 (UNM, 2010) University of New Mexico. 2010. Lea County Crash History for the New Mexico 

26 Traffic Safety Bureau, August 19, 2010. Available at http://www.unm.edu/~dgrint/CountyCrash 

27 History/cny0609/LeaCounty.html. Accessed March 11, 2011. ADAMS Accession No. 

28 ML112720608. 

29 (USCB, 2010a). U.S. Census Bureau. 2010. American Factfinder. New Mexico Fact Sheet. 

30 2005-2009 American Community Survey 5-Year Estimates. Available online at 

31 http://factfinder.census.gov. Accessed April 11, 2011. ADAMS Accession No. ML112720609. 

32 (Yarger, 2009) Yarger, F. 2009. Seismic Probability in Lea County, NM: A Brief Analysis, New 

33 Mexico Institute of Mining and Technology, New Mexico Center for Energy Policy. ADAMS 

34 Accession No. ML103080942. 

 5-1 

1 5.0 MITIGATION MEASURES AND COMMITMENTS 

2 This chapter identifies possible measures to mitigate potential environmental impacts from the 

3 proposed action, as required by Appendix A to Subpart A of 10 CFR 51. CEQ’s regulation for 

4 implementing NEPA at 40 CFR 1500.2 (f) requires Federal agencies to “[u]se all practicable 

5 means consistent with the requirements of the NEPA and other essential considerations of 

6 national policy to restore and enhance the quality of the human environment and avoid or 

7 minimize any possible adverse effects of their actions on the quality of the human environment.” 

8 The CEQ regulations (40 CFR 1508.20) note that mitigation activities include those that 

9 “(1) avoid the impact altogether by not taking a certain action or parts of an action; (2) minimize 

10 impacts by limiting the degree or magnitude of the action and its implementation; (3) repair, 

11 rehabilitate, or restore the affected environment; (4) reduce or eliminate impacts over time by 

12 preservation or maintenance operations during the life of the action; or (5) compensate for the 

13 impact by replacing or substituting resources or environments.” As such, mitigation measures 

14 are those actions or processes (e.g., process controls and management plans) that would be 

15 implemented to control and minimize potential impacts associated with the proposed IIFP 

16 facility. 

17 IIFP must comply with applicable laws and regulations, including obtaining all required 

18 construction and operating permits, and decommissioning requirements. Chapter 5 

19 summarizes the mitigation measures that were proposed by IIFP (IIFP, 2009). The proposed 

20 mitigation measures do not include environmental monitoring activities. Environmental 

21 monitoring activities are described in Chapter 6 (Environmental Measurements and Monitoring 

22 Programs). The NRC staff has reviewed the mitigation measures proposed by IIFP and has 

23 concluded that the mitigation measures would reduce or minimize impacts. 

24 IIFP identified measures in its Environmental Report and in responses to Requests for 

25 Additional Information that would mitigate environmental impacts associated with the proposed 

26 action (IIFP, 2009; IIFP, 2011). Table 5-1 lists measures proposed to mitigate the impacts of 

27 construction. Table 5-2 lists measures proposed to mitigate the impacts of operations. These 

28 measures do not preclude additional mitigation that may be considered by IIFP based upon 

29 consultations with regulatory agencies other than NRC. In a letter to the NRC dated June 21, 

30 2011, the NMGF recommended additional mitigation measures such as a noxious weed 

31 management plan, protective screening of all open stacks and vents to exclude birds or bats, 

32 and designing stormwater retention ponds to exclude wildlife or to provide a means of escape 

33 from the ponds. A copy of this letter is included in Appendix B Consultation / Coordination) of 

34 this EIS. 

35 
 5-2 

Table 5-1. Summary of Potential Mitigation Measures Proposed by IIFP for Construction (including preconstruction 1 activities) 2 

Impact Area Activity Mitigation Measures 

Land Use Land disturbance • The construction footprint would be minimized to the extent possible. 

• After construction is complete, disturbed areas of the site would be stabilized with native, 

drought-resistant landscaping; and areas expected to handle regular vehicular and pedestrian traffic would be stabilized with pavement or gravel. 

• To the extent possible utilities would be placed within existing rights-of-way. 

Historic and Cultural Resources 

Disturbance of historic and cultural resources eligible for listing on the National Register of Historic Places (NRHP) 

• In the event that human remains or items of archaeological significance were discovered 

during construction, IIFP would cease work in the area around the discovery and notify the NM SHPO and Native American Tribes, so that they could determine the appropriate measures to identify, evaluate, and treat these discoveries. 

• Avoidance and data collection are the two most common forms of mitigation for sites 

considered eligible based on NRHP. When possible, avoidance is the preferred alternative because the site is preserved in place and mitigation costs are minimized. When avoidance 

is not possible, data collection becomes the preferred alternative. Data collection proceeds after the sites have been determined eligible. A treatment plan would be submitted to the appropriate regulatory agencies. The plan would describe the expected data content of the sites and how data would be collected, analyzed, and reported. A treatment/mitigation plan would be developed by IIFP, if necessary. 

Visual Resources Change in visual 

character 

• Native, drought-resistant landscaping would be used to limit visual impacts. • Disturbed areas would be promptly re-vegetated or covered 

Water Resources Runoff • Stormwater would be controlled at the proposed facility during preconstruction and 

construction by complying with the NPDES Construction General Permit requirements and by applying BMPs as detailed in the Stormwater Pollution Prevention Plan. 

• Construction equipment would be in good repair and without visible leaks of oil, grease, or 

hydraulic fluid, and would be periodically maintained and inspected. 

• BMPs would be used for dust control associated with excavation and fill operations during 

construction. Water conservation would be considered when deciding how often dust suppression sprays would be applied. 

• Stone construction pads would be placed at entrance/exits where an unpaved construction 

access road intersects a publicly maintained road. 

• Stormwater basins would be designed to facilitate the prompt, systematic sampling of runoff 

in the event of any special needs. 

3 
 5-3 

Table 5-1. Summary of Potential Mitigation Measures Proposed by IIFP for Construction (including preconstruction activities) (Continued) 

Impact Area Activity Mitigation Measures 

Water Resources (continued 

• A spill control program would be implemented for accidental oil spills. An SPCC Plan would 

be prepared prior to the start of construction or prior to the storage of oil on site in excess of de minimis quantities and would 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 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 

• As part of the SPCC Plan, other measures would 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, as appropriate. 

• Sanitary wastes generated during site construction would be handled by portable systems 

until the plant sanitary waste treatment facility was available for use. 

Air Quality Fugitive dust and 

point-source releases of criteria pollutants 

• Construction BMPs would minimize fugitive dust: Water or dust suppressants would be 

used to control dust on dirt roads. Water conservation will be considered when deciding how often dust suppression sprays would be applied. 

• Designate personnel to monitor dust emissions and direct increased watering where 

necessary. 

• Implement monitoring and inspection programs to identify equipment malfunction so that 

corrective action can be taken promptly. 

• Work practices would prevent or reduce air emissions releases. • Beds of open-bodied trucks transporting materials likely to give rise to airborne dust would 

be covered when in motion. 

• Construction equipment and related vehicles would be equipped with standard pollution 

control devices and maintained in good working order. 

Geology, Minerals, and Soil 

Soil disturbance • Erosion impacts due to site clearing and grading would be mitigated by use of construction 

and erosion control BMPs. 

• The construction footprint would be minimized to the extent possible. • Disturbed soils would be stabilized by placing crushed stone on areas of concentrated runoff 

to reduce potential for erosion and sedimentation. 
 5-4 

Table 5-1. Summary of Potential Mitigation Measures Proposed by IIFP for Construction (including preconstruction activities) (Continued) 

Impact Area Activity Mitigation Measures 

Geology, Minerals, and Soil (Continued) 

• Earthen berms, dikes, and sediment fences would be installed as necessary to limit 

suspended solids in runoff. 

• Cleared areas not covered by structures or pavement would be stabilized by acceptable 

means as soon as practical. 

• Watering or dust suppressants would be used to control fugitive dust and prevent loss of 

topsoil. 

• The facility would be designed and constructed to collect surface runoff in temporary 

detention basins. 

• Standard drilling and blasting techniques, if required, would be used to minimize impacts to 

bedrock, reducing the potential for over-excavation and thereby minimizing damage to the surrounding rock. 

• Drainage culverts and ditches would be stabilized and lined with rock aggregate to reduce 

flow velocity and trap sediments. 

• Soil stockpiles would be constructed in a manner to reduce erosion. • Site slopes would be limited to a horizontal-to-vertical ratio of three to one. • Excavated materials would be reused whenever possible. • An SPCC Plan would be implemented. 

Waste Management Waste generation 

and management 

• The quantities of waste generated would be minimized by collecting and sorting waste for 

recycling or disposal. 

• An assessment for each onsite waste storage area would be performed to identify and 

prevent potential accidental releases to the environment. 

• Onsite waste storage facilities would be monitored and inspected on an established 

schedule to detect any leaks or releases to the environment, so that corrective action could be taken promptly. 

• Waste that requires offsite storage, treatment, or disposal would be shipped to a licensed 

facility appropriate for the waste type and in compliance with State and Federal requirements. 

Ecological Resources Disturbance to 

plant and animal habitat 

• The construction footprint would be minimized to the extent possible. • Site stabilization practices would be implemented to reduce the potential for soil erosion and 

deposition of sediment into down slope wildlife and aquatic habitats. 

• Unused open areas would be left undisturbed and managed for the benefit of wildlife. 
 5-5 

Table 5-1. Summary of Potential Mitigation Measures Proposed by IIFP for Construction (including preconstruction activities) (Continued) 

Impact Area Activity Mitigation Measures 

Ecological Resources Disturbance to 

plant and animal habitat (continued) 

• Security lighting for all ground level facilities and equipment would be directed downward. • The use of native plant species in disturbed areas for revegetation would enhance and 

maximize the opportunity for native wildlife habitat to be reestablished at the site. 

• No herbicides would be used during construction 

Transportation Dust deposition 

on roadways 

• To control fugitive dust production, reasonable precautions would be taken to prevent 

particulate matter from becoming airborne, including the following actions: • Use water or dust-suppressants to control dust on dirt roads and in clearing and grading 

operations and construction activities. Water conservation would be considered when deciding how often dust suppression sprays would be applied. 

• Adequate containment methods would be used during excavation. • Open-bodied trucks transporting materials likely to give rise to airborne dust would be 

covered when in motion. 

• Disturbed areas would be stabilized or covered promptly once earth moving activities are 

completed. 

• Construction equipment and related vehicles would be operated with standard pollution 

control devices maintained in good working order. 

• Designated personnel would be assigned to monitor dust emissions and increase 

watering or application of dust suppressants where necessary. 

Traffic • During the course of construction, short-duration activities (e.g., concrete and other 

construction material deliveries) would be scheduled to minimize traffic impacts. 

• Work shifts would be implemented during construction to minimize impacts to traffic. 

Noise Operation of 

construction vehicles 

• Heavy truck and earth moving equipment usage would be prohibited after twilight and during 

early morning hours. 

• Noise suppression systems (mufflers) on construction vehicles would be kept in proper 

operation. 

• When possible, quiet equipment or methods to minimize noise emissions would be utilized 

during an activity. 

• When possible and practical, equipment with internal combustion engines would be operated 

at the lowest operating speed to minimize noise emissions. 

• Engine housing doors would be closed during operation of the equipment to reduce noise 

emissions from the engine. 

• Equipment engine idling would be avoided to the extent possible. 
 5-6 

Table 5-1. Summary of Potential Mitigation Measures Proposed by IIFP for Construction (including preconstruction activities) (Continued) 

Impact Area Activity Mitigation Measures 

Public and Occupational Health 

Hazardous materials worker safety 

• Integrated Safety Management System program and procedures would be adhered to. • All construction personnel would be required to take safety training and IIFP and all 

construction contractors would ensure that OSHA practices for construction are implemented and followed. 

Source: IIFP, 2009; IFP 2011 

1 

Table 5-2. Summary of Potential Mitigation Measures Proposed by IIFP for Operations 2 

Impact Area Activity Mitigation Measures 

Land Use No mitigation measures necessary Geology, Minerals, and Soil 

Materials storage • Aboveground storage tanks would be constructed of appropriate materials according to 

industry standards and applicable regulations and appropriate measures for spill containment would be installed. 

• Tanks storing petroleum products and hazardous chemicals would be equipped with 

secondary containment. 

• Routine visual inspections and preventive maintenance would be conducted. • Spill cleanup materials would be stored in the areas of fuel line and tank hose connections 

and maintained in good working order. 

• Contaminated soils would be sampled, analyzed, and managed in accordance with NRC, 

State, and other Federal requirements. 

• An SPCC plan would be developed and implemented. 

Water Resources Runoff • All aboveground petroleum storage tanks would be surrounded by berms to contain spills or 

leaks. 

• Routine visual inspections and preventive maintenance would be conducted. • Any hazardous materials would be handled by approved methods and hazardous wastes 

would be shipped offsite to licensed disposal sites. 

• The facility’s liquid effluent collection and treatment system would provide a means to control 

liquid waste within the plant, including the collection, evaporation, and minimization of liquid wastes for disposal. 

• Radioactive liquid effluent releases to the evaporative tank would be maintained at 

concentrations below 10 CFR 20 uncontrolled release limits. 

3 
 5-7 

Table 5-2. Summary of Potential Mitigation Measures Proposed by IIFP for Operations (Continued) 

Impact Area Activity Mitigation Measures 

Water Resources (Continued) 

• Control of surface water runoff would be required for activities as required by the NPDES 

General Permit. 

• Stormwater and effluent sampling would be conducted as required by the NPDES permit to 

protect surface water quality. In addition, groundwater would be monitored to confirm that the impacts to groundwater from the IIFP facility were minimal. 

• An SPCC plan would be implemented which would include: • 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. 

 Water use • Identification 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. • Control of drainage of rain water from dike areas. • Containment of oil and diesel fuel in bulk storage tanks. • Aboveground tank integrity testing. • Oil and diesel fuel transfer operational safeguards. 

• Native, drought-resistant vegetation would be planted. • Floor washing using mops and self-contained cleaning machines would be used to reduce 

water usage, as opposed to conventional washing with a hose. 

• High-efficiency washing machines would be installed. • Closed-loop cooling systems would be incorporated where possible. • Process waste water would be treated and recycled. Any small amounts of excess water 

from miscellaneous processes would be retained in a storage tank and sent to an evaporator. 

Waste Management Waste generation 

and management 

• Minimize the quantities of waste by collecting and sorting waste for recycling or disposal. • Perform an assessment for each onsite waste storage area to identify and prevent potential 

accidental releases to the environment. 

• Monitor and inspect onsite waste storage facilities on an established schedule to detect any 

leaks or releases to the environment due to equipment malfunctions, so that corrective action could be taken promptly. 

Waste Management • Ship waste that requires offsite storage, treatment, or disposal to a licensed facility 
 5-8 

Table 5-2. Summary of Potential Mitigation Measures Proposed by IIFP for Operations (Continued) 

Impact Area Activity Mitigation Measures 

(Continued) appropriate for the waste type and in compliance with State and Federal requirements. Air Quality Emissions • Process design features would be developed to lower the potential for air emissions. 

• Implement monitoring and inspection programs to detect any air emissions from equipment 

malfunction during operations, so that corrective action can be taken promptly. 

• Work practices would be employed to prevent or reduce air emissions releases. • Air emissions control systems (i.e., scrubber systems and dust collectors) would be 

designed to collect and strip potentially hazardous gases from plant effluents prior to release into the atmosphere. 

• Emission stacks would be sampled continuously and routinely analyzed. 

Ecological Resources Removal of plant 

and animal habitat 

• A raptor perch would be placed in an unused open area. • Bird feeders would be installed at the visitor’s center and quail feeders would be placed in 

unused open areas away from buildings. 

• Unused open areas, including areas of native grasses and shrubs, would be managed for 

the benefit of wildlife. 

• Drought-resistant native plant species would be used to revegetate disturbed areas and to 

enhance wildlife habitat. 

• Netting or other suitable material would be used to ensure birds are excluded from retention 

(evaporation) basins that do not meet New Mexico Water Quality Control Commission surface water standards for wildlife usage. 

• Animal-friendly fencing would be used within the site so that wildlife would not be injured or 

entangled. 

• The number of open trenches would be minimized at any given time. • Air-scrubbers system liquids would be treated prior to disposal or recycled. • Security lighting for all ground level facilities and equipment would be directed downward. 

• Herbicides would be used in limited amounts according to government regulations and 

manufacturer’s instructions to control unwanted noxious vegetation. 

Transportation Traffic • Shift changes and truck shipments would be scheduled for off-peak traffic periods, when 

practical. 

Noise Operation of 

Equipment and Vehicles 

• The facility would be designed so that the reaction vessel systems, valves, transformers, 

pumps, generators, and other equipment would generally be located inside structures; the buildings themselves would limit noise outside the facility. 

• Distance, vegetation, and site buildings and structures would mitigate noise from equipment 

located outside of structures. 
 5-9 

Table 5-2. Summary of Potential Mitigation Measures Proposed by IIFP for Operations (Continued) 

Impact Area Activity Mitigation Measures 

Public and Occupational Health 

Hazardous materials processing 

• To protect the public and workers, the plant design would incorporate features to minimize 

gaseous and liquid effluent releases and to keep them well below regulatory limits. 

• The radiation protection program would require routine radiation surveys and air sampling to 

assure that worker exposures are maintained ALARA. Exposure-monitoring techniques at the plant would include use of personal dosimeters by workers, personnel breathing zone air sampling, and annual whole-body counting. 

• Annual radiation exposure for an employee would be controlled, monitored, and maintained 

ALARA through the IIFP Radiation Protection Program. 

• Worker health and safety would be protected by a Chemical Safety Program, a Radiation 

Protection Program, and an Industrial Safety Program. 

• Handling of all chemicals and wastes would be conducted in accordance with an 

Environment, Health, and Safety Program which would conform to 29 CFR 1910 and specify the use of appropriate engineered controls, and personnel protective equipment to minimize potential chemical exposures. 

• Laboratory and maintenance operations activities involving hazardous gaseous or respirable 

emissions would be conducted with ventilation control (i.e., fume hoods, local exhaust or similar) and/or with the use of respiratory protection. 

Source: IIFP, 2009; IIFP 2011 
 5-10 

1 5.1 References 

2 (IIFP, 2009) International Isotopes Fluorine Products, Inc. 2009. Fluorine Extraction Process 

3 and Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A, ER4 IFP-001. December 27, 2009. ADAMS Accession No. ML100120758. 

5 (IIFP, 2011) International Isotopes Fluorine Products, Inc. 2011. Fluorine Extraction Process 

6 and Depleted Uranium De-conversion Plant (FEP/DUP) Official Responses to Environmental 

7 Report RAI’s. Revision A. March 31, 2011. ADAMS Accession No. ML110970481. 
 6-1 

1 6.0 ENVIRONMENTAL MEASUREMENTS AND MONITORING 

2 PROGRAMS 

3 This chapter describes programs that would be used to measure and monitor radiation, 

4 radiological materials, and chemicals associated with operation of the proposed IIFP facility. It 

5 also provides data on principal pathways of exposure to the public and biota. This chapter is 

6 organized as follows: Section 6.1 describes the radiological monitoring program; Section 6.2 

7 describes the physicochemical (i.e., chemical and meteorological properties that affect 

8 measurements) monitoring program; and Section 6.3 describes the ecological monitoring 

9 program. 

10 These monitoring programs would comprise soil and vegetation sampling, water/sediment 

11 sampling, continuous airborne emission particulate monitoring and measuring, groundwater 

12 monitoring, direct radiation measuring, and sampling of stack emissions and air vents within the 

13 facility. Exact sampling locations would be determined at a later date based on site information 

14 (IIFP, 2009). 

15 The facility would have an onsite analytical environmental monitoring laboratory equipped with 

16 analytical instruments necessary to ensure that the operation of the plant activities complies 

17 with Federal, State and local regulations and requirements. Compliance would be 

18 demonstrated by monitoring/sampling at various plant and process locations, and in the 

19 environment surrounding the facility, analyzing the samples and reporting the results of these 

20 analyses to the appropriate agencies. The environmental sampling/monitoring locations would 

21 be selected by the Health, Safety and Environmental staff in accordance with facility permits 

22 and good sampling practices. 

23 The onsite laboratory would perform analyses on air, water, soil, flora, and fauna samples 

24 obtained from designated release points and areas around the plant. In addition to its 

25 environmental and radiological capabilities, the environmental monitoring laboratory also would 

26 be capable of performing bioassay analyses when necessary. Commercial, offsite laboratories 

27 may also be contracted to perform bioassay analyses. 

28 6.1 Radiological Monitoring Program 

29 The proposed IIFP facility would address radiological monitoring through two programs: the 

30 Effluent Monitoring Program and the Radiological Environmental Monitoring Program. The 

31 Effluent Monitoring Program would monitor, record, and report data for radiological 

32 contaminants being discharged from specific emission points such as an airborne release stack. 

33 Radiological Environmental Monitoring Program would monitor radioactivity in environmental 

34 media (i.e., soil, sediment, groundwater, biota, and air) within and outside the proposed IIFP 

35 facility site boundary. The following subsections provide information on the two radiological 

36 monitoring programs. 

37 6.1.1 Effluent Monitoring Program 

38 The NRC requires nuclear fuel cycle facilities such as the proposed IIFP facility to monitor and 

39 report the release of radiological airborne and liquid effluents to the environment in accordance 

40 with Title 10, “Energy,” of the U.S. Code of Federal Regulations (10 CFR), 20.1501(a) and (b). 

41 Table 6-1 lists the guidance documents that apply to the radiological monitoring program. 
 6-2 

1 Table 6-1. Guidance Documents Applicable to Radiological Monitoring Program 

Document Applicable Guidelines 

Regulatory Guide 4.151 Quality Assurance for Radiological Monitoring Programs (Inception to 

Normal Operations to License Termination) - Effluent Streams and the 

Environment. This guide describes a method acceptable to the NRC for 

designing a program to ensure the quality of the results of measurements 

for radioactive materials in the effluents and the environment outside of 

nuclear facilities during normal operations. 

Regulatory Guide 4.162 Monitoring and Reporting Radioactive Materials in Liquid and Gaseous 

Effluents from Nuclear Fuel Cycle Facilities. This guide describes a 

method acceptable to the NRC for submitting semiannual reports that 

specify the quantity of each principal radionuclide released to unrestricted 

areas to estimate the maximum potential annual dose to the public 

resulting from effluent releases. 1 2 NRC, 2007 

2 3 NRC, 2010 

4 

5 Public exposure to radiation from routine operations at the proposed IIFP facility may occur as 

6 the result of the discharge of liquid and gaseous effluents, including controlled releases from the 

7 uranium deconversion process lines during decontamination and maintenance of equipment. In 

8 addition, radiation exposure to the public may result from the transportation and storage of DUF6

9 feed cylinders. Of these potential pathways, discharge of gaseous effluent has the highest 

10 potential to introduce uranium into the environment (IIFP, 2009). Section 4.1.2.11 of this draft 

11 EIS presents the potential impacts from the potential release pathways. 

12 Compliance with 10 CFR 20.1301, Dose limits for individual members of the public, would be 

13 demonstrated using a calculation of the total effective dose equivalent (TEDE) to the individual 

14 likely to receive the highest dose in accordance with 10 CFR 20.1302(b)(1) (IIFP, 2009). The 

15 determination of the TEDE pathway analysis is supported by appropriate models, codes, and 

16 assumptions that accurately represent the facility, site, and the surrounding area. The computer 

17 codes used to calculate dose associated with potential gaseous and liquid effluent from the 

18 plant follow the methodology for pathway modeling, as described in Regulatory Guide 1.109 

19 (NRC, 1977), and have undergone validation and verification by NRC. 

20 Administrative action levels are established for effluent samples and monitoring instrumentation 

21 as an additional check in the effluent control process. These action levels are well below 

22 regulatory limits; their purpose is to support implementation of corrective actions before releases 

23 approach regulatory limits. Effluent samples that exceed the action level are cause for an 

24 investigation into the source of elevated radioactivity. For example, radiological analyses would 

25 be performed more frequently on ventilation air filters if there is an unexplained increase in 

26 gross radioactivity, or when a process change or other circumstance change radioactivity 

27 concentrations in the effluent stream. Progressively more rigorous corrective actions would be 

28 implemented based on the radioactivity level, through means of automatic shutdown 

29 programming and operating procedures to be developed in the detailed alarm design (IIFP, 

30 2009). 

31 Under routine operating conditions, radioactive material in effluent discharged from the facility 

32 would comply with regulatory release criteria. Compliance would be demonstrated through 

33 effluent and environmental sampling data. Processes are designed to include, when practical, 

34 provision for automatic shutdown in the event action levels are exceeded. Appropriate action 
 6-3 

1 levels and actions to be taken are specified for liquid effluents and gaseous releases (IIFP, 

2 2009). 

3 The effluent monitoring program would be overseen by IIFP Radiation Safety Program, Quality 

4 Assurance (QA) personnel and would be subject to periodic audits. Written procedures would 

5 specify the collection of representative samples, use of appropriate sampling methods and 

6 equipment, appropriate locations for sampling points, and proper handling, storage, transport, 

7 and analyses of effluent samples. In addition, IIFP would develop written procedures for 

8 maintaining and calibrating sampling and measuring equipment, including ancillary equipment 

9 such as airflow meters, to ensure that all radiological monitoring equipment is properly 

10 maintained and calibrated at regular intervals. The effluent monitoring program procedures 

11 would include functional testing and routine checks to demonstrate that monitoring and 

12 measuring instruments are in working condition. Employees involved in implementation of this 

13 program would be trained in the program procedures (IIFP, 2009). 

14 6.1.1.1 Gaseous Effluent Monitoring 

15 To ensure compliance with regulatory requirements, potentially radioactive effluents from the 

16 facility would be discharged only through monitored pathways. The effluent sampling program 

17 would measure the quantities and concentrations of radionuclides discharged to the 

18 environment. Uranium isotopes and daughter products are expected to be the most common 

19 radionuclides in the gaseous effluent. 

20 Effluents would be sampled as shown in Table 6-2. Representative samples would be collected 

21 from each release point. Because uranium in gaseous effluents may exist in a variety of 

22 compounds (e.g., UF6, uranium oxide, UF4, and uranyl fluoride), effluent data would be 

23 maintained, reviewed, and assessed by the facility’s Radiation Protection Manager to ensure 

24 that all gaseous effluent discharges comply with regulatory release criteria for uranium. 

25 However, the gaseous effluent monitoring program for the IIFP plant would be designed to 

26 determine the quantities and concentrations of all gaseous discharges to the environment, not 

27 just uranium. The process exhaust stacks would be equipped with monitors for particulates, HF, 

28 and gross radioactivity (IIFP, 2009). 

29 Table 6-2. Gaseous Effluent Sampling Program 

Area Type Sample Type of Analysis Frequency 

Dust Collector Stacks Continuous Air Filter Gross Alpha/Beta 

Isotopic 

Weekly/Composite/ 

Quarterly 

Process Stacks Continuous Air Filter Gross Alpha/Beta 

Isotopic/Fluoride 

Weekly/Composite/ 

Quarterly 

Air Vents Continuous Air Filter Gross Alpha/Beta 

Isotopic 

Weekly/Composite/ 

Quarterly 

30 Source: IIFP, 2009 

31 

32 Monitoring for uranium isotopes would be performed continuously and samples would be 

33 analyzed at least once per operating shift. If an unacceptable level of uranium is detected 

34 (i.e., if it exceeded the administrative action level), IIFP would investigate the cause and 

35 corrective action would be taken. The gaseous effluent sampling program would support the 

36 determination of quantity and concentration of radionuclides discharged from the facility and 

37 support the collection of other information required for 10 CFR 20.1501(a) and (b) (IIFP, 2009). 
 6-4 

1 6.1.1.2 Liquid Effluent Monitoring 

2 Liquids potentially contaminated with low concentrations of uranium could be generated from 

3 equipment decontamination, floor washings, and laundry. Except for discharges from the 

4 Sanitary Treatment System, liquid effluents would be contained on the proposed IIFP site via 

5 collection tanks and retention basins (IIFP, 2009). 

6 Potentially contaminated liquid effluent would be routed to the Decontamination Area for 

7 treatment. In the Decontamination Area, radioactive material would be removed from waste 

8 water through a combination of clean-up processes that would include precipitation, filtration, 

9 and ion exchange. Representative sampling would be ensured through the use of tank agitators 

10 and recirculation lines. Collection tanks would be sampled before the contents were sent 

11 through any treatment process. Treated water would then be collected in other tanks, which 

12 would be sampled. Concentrated radioactive solids generated by the liquid treatment 

13 processes would be disposed of as LLW at an off-site licensed disposal facility (IIFP, 2009). 

14 6.1.2 Radiological Environmental Monitoring Program 

15 The primary objective of the Radiological Environmental Monitoring Program (REMP) would be 

16 to provide verification that IIFP operations do not result in detrimental radiological impacts to the 

17 environment. The REMP data would confirm the effectiveness of effluent controls and provide 

18 additional verification of the power of the effluent monitoring program to produce results. The 

19 REMP would establish a process for collecting data for assessing radiological concentrations in 

20 the environment, estimate the potential impacts on the public, and support the demonstration of 

21 compliance with applicable radiation protection standards and guidelines. 

22 6.1.2.1 Sampling Program 

23 To meet the REMP objectives, representative samples from various environmental media would 

24 be collected and analyzed for radioactivity. The types and frequency of sampling and analyses 

25 are summarized in Table 6-3. Environmental media identified for sampling consist of ambient 

26 air, groundwater, soil/sediment, and vegetation. 

27 Environmental samples would generally be analyzed at the on-site analytical laboratory. 

28 However, samples could be shipped to a qualified independent laboratory for analyses. 

29 Monitoring and sampling activities, laboratory analyses, and reporting of radioactivity in the 

30 environment would be conducted in accordance with industry-accepted and agency-approved 

31 methodologies. 

32 The REMP would include the collection of data during pre-operational years in order to establish 

33 baseline radiological information that would be used in determining and evaluating releases 

34 from plant operations to the local environment. The REMP would be initiated at least 12 months 

35 prior to initiation of plant operations in order to develop a sufficient database before the arrival of 

36 the first uranium hexafluoride shipment. Radionuclides in environmental media would be 

37 identified using technically appropriate, accurate, and sensitive analytical instruments. 

38 Data collected during the operational years would be compared to the baseline generated by 

39 the pre-operational data. Such comparisons would provide a means of assessing the 

40 magnitude of potential radiological impacts on members of the public and in demonstrating 

41 compliance with applicable radiation protection standards. 
 6-5 

1 Table 6-3. Radiological Sampling and Analysis Program 

Sample Type Location Sampling 

Collection 

Frequency 

Type of 

Analysis 

Continuous 

Airborne particulate 

Six locations along 

fence line and in 

the region of 

influence, including 

the location of the 

nearest resident 

Continuous 

operation of air 

sampler with 

sample collection 

as necessary 

based on dust 

loading, but at 

least biweekly 

Quarterly 

composite 

samples by 

location 

Gross beta/gross 

alpha analyses 

each filter 

change. 

Quarterly 

isotopic analysis 

on composite 

sample 

Vegetation/Soil 

Analyses 

Five (including four 

locations along 

fence line and a 

control at an offsite 

location some 

distance away) 

For each 

vegetation and 

soil sample, 1 to 

2 kg (2.2 to 

4.4 lbs) 

Quarterly preoperation/semiannual during 

operation 

Isotopic 

analyses/fluoride 

Groundwater Four wells Samples [4 L 

(1.1 gal)] 

Semiannually Isotopic 

analyses 

Thermoluminescent 

Dosimeters (TLDs) 

Eight locations 

along fence line 

Samples 

collected 

quarterly 

Quarterly Gamma and 

neutron 

equivalent 

Stormwater Site Stormwater 

Retention Basin, 

DUF6 Cylinder 

Storage Pads, 

Stormwater 

Retention Basins 

Water sample 4 L 

(1.1 gal). 

Sediment 

samples 1 to 2 kg 

(2.2 to 4.4 lbs) 

Semiannually Isotopic 

analyses 

2 Source: IIFP, 2009 

3 

4 Over time, revisions to the REMP may be necessary and appropriate to assure reliable 

5 sampling and collection of environmental data. The rationale and actions behind such revisions 

6 to the program would be documented and reported to the appropriate regulatory agency, as 

7 required. REMP sampling focuses on locations within 1.6 km (1 mi) of the facility, but may also 

8 include distant locations as control sites. The sampling locations may be subject to change, as 

9 determined from the results of periodic review of land use. 

10 The concentrations of radioactive material in gaseous effluent from the proposed IIFP facility are 

11 expected to be very low because of process and effluent controls. Consequently, air samples 

12 collected at locations that are close to the facility would provide the best opportunity to detect 

13 and identify plant-related radioactivity in the ambient air. Therefore, air monitoring activities 

14 would concentrate on locations close to the plant, such as the plant perimeter fence or the plant 

15 property line. Air monitoring stations would be situated along the fence perimeter, at the 

16 nearest residence, and at “control comparative” locations. In addition, an air monitoring station 

17 would be located next to the Stormwater Retention Basins to measure for particulate 

18 radioactivity that may be resuspended into the air from sediment when the basin is dry. 

19 Environmental air samplers would operate on a continuous basis with sample retrieval for a 

20 gross alpha and beta analysis occurring weekly (or more often if dust loads are heavy) 

21 (IIFP, 2009). 
 6-6 

1 Vegetation and soil samples, from on and offsite locations would be collected quarterly in each 

2 compass sector during the pre-operational REMP. This would ensure the development of an 

3 adequate baseline. During the operational years, vegetation and soil sampling would be 

4 performed semiannually in five compass sectors, including the three with the highest predicted 

5 atmospheric deposition (based on the prevailing wind direction). Vegetation samples may 

6 include garden vegetables or grass, depending on availability. Soil samples would be collected 

7 in the same vicinity as the vegetation samples (IIFP, 2009). 

8 On October 15, 2010, soil and vegetation samples were collected and shipped to analytical 

9 laboratories for analysis (GL Environmental, 2010) to establish baseline conditions. Table 6-4 

10 presents the results of these samples. 

11 Table 6-4. Baseline Radiological Soil and Vegetation Samples 

Soil Sample 

Bq/g (μCi/g) Vegetation Sample 

U-234 0.016 to 0.022 

(4.42 x 10-7 to 5.95 x 10-7) 

Less than minimum detectable 

concentrations 

U-235/U-236 2.06 x 10-4 to 9.62 x 10-4

(5.58 x 10-9 to 2.60 x 10-8) 

Less than minimum detectable 

concentrations 

U-238 0.0217 to 0.0220 

(5.86 x 10-7 to 5.95 x 10-7) 

3.85 x 10-4

(1.04 x 10-8) 

Other Isotopic Uranium Less than minimum detectable 

concentrations 

Less than minimum detectable 

concentrations 

12 Source: GL Environmental, 2010 

13 Bq/g = becquerel/gram 

14 μCi/g = microcurie/gram 

15 

16 Groundwater samples from onsite monitoring wells would be collected semiannually for 

17 radiological analysis. Two monitoring wells would be downgradient of the proposed IIFP site, 

18 one would be located downgradient of the DUF6 Cylinder Storage Pads, and one (background 

19 monitoring well) would be upgradient of the site. Sediment samples would be collected 

20 semiannually from the stormwater runoff retention basins on site to analyze for any buildup of 

21 uranic material being deposited (IIFP, 2009). 

22 Direct radiation in offsite areas from processes inside the facility buildings is expected to be 

23 minimal because the low-energy radiation associated with the uranium would be shielded by 

24 process piping, equipment, and cylinders. Because the offsite dose equivalent rate from stored 

25 DUF6 cylinders is expected to be very low and difficult to distinguish from the variance in normal 

26 background radiation beyond the site boundary, demonstration of compliance would rely on a 

27 system that combines direct dose equivalent measurements and computer modeling to 

28 extrapolate the measurements. Environmental TLDs would be placed at the plant perimeter 

29 fence line or other location(s) close to the DUF6 cylinders to provide quarterly direct dose 

30 equivalent information. The direct dose equivalent at offsite locations would be estimated 

31 through extrapolation of the quarterly TLD data using computer programs (IIFP, 2009). 

32 6.1.2.2 Procedures 

33 Monitoring procedures would employ approved analytical methods and instrumentation. The 

34 instrument maintenance and calibration program would comply with manufacturers 
 6-7 

1 recommendations. The onsite laboratory and any contract laboratory used to analyze the IIFP 

2 facility samples would participate in third-party laboratory intercomparison programs appropriate 

3 to the media and analyses being measured. The following are examples of these third-party 

4 programs: 

5 • The DOE Mixed Analyte Performance Evaluation Program and DOE Quality Assurance 

6 Program 

7 • Analytics, Inc., Environmental Radiochemistry Cross-Check Program 

8 IIFP would require that all radiological and nonradiological laboratory vendors are certified by 

9 the National Environmental Laboratory Accreditation Program or an equivalent State laboratory 

10 accreditation agency for the analytes being tested (IIFP, 2009). 

11 The REMP would fall under the oversight of IIFP’s Quality Assurance Program. Quality 

12 assurance procedures would be implemented to ensure representative sampling, proper use of 

13 appropriate sampling methods and equipment, proper locations for sampling points, and proper 

14 handling, storage, transport, and analyses of effluent samples. In addition, written procedures 

15 would ensure that sampling and measuring equipment, including ancillary equipment such as 

16 airflow meters, would be properly maintained and calibrated at regular intervals according to 

17 manufacturer recommendations. The implementing procedures would include functional testing 

18 and routine checks to demonstrate that monitoring and measuring instruments were in working 

19 condition. 

20 IIFP would periodically conducted as part of its Quality Assurance Program (IIFP, 2009). The 

21 quality control procedures used by the analytical laboratories would conform to the guidance in 

22 Regulatory Guide 4.15 (NRC, 2007). These quality control procedures would include the use of 

23 established standards such as those provided by the National Institute of Standards and 

24 Technology and the use of standard analytical procedures such as those established by the 

25 National Environmental Laboratory Accreditation Conference (IIFP, 2009). 

26 6.1.2.3 Reporting 

27 Reporting procedures would comply with the requirements of 10 CFR 70.59 and the guidance 

28 specified in Regulatory Guide 4.16 (NRC, 2010). Reports of the concentrations of principal 

29 radionuclides released to unrestricted areas in effluents would be provided and would include 

30 the minimum detectable concentration (MDC) for the analysis and the error for each data point. 

31 Each year, IIFP would submit a summary report of the environmental sampling program to the 

32 NRC, including all associated data, as required by 10 CFR 70. The report also would include 

33 the types, numbers, and frequencies of environmental measurements and the identity and 

34 concentrations of nuclides found in the environmental samples. Significant positive trends 

35 would also be noted in the report, along with any adjustment to the program, unavailable 

36 samples, and deviations from the sampling program. 

37 6.2 Physicochemical Monitoring 

38 6.2.1 Introduction 

39 The primary objective of physicochemical monitoring would be to provide verification that the 

40 operations at the IIFP plant do not result in detrimental chemical impacts on the environment. 

41 Effluent controls would be in place to ensure that chemical concentrations in gaseous and liquid 
 6-8 

1 effluents are maintained ALARA. In addition, physicochemical monitoring would provide data to 

2 confirm the effectiveness of effluent controls. 

3 Administrative action levels would ensure that chemical discharges remain below the limits 

4 specified in the facility discharge permits: the EPA Region 6 NPDES General Discharge 

5 Permits and the New Mexico Environment Department / Water Quality Bureau WQB) 

6 Groundwater Discharge Permit/Plan. Physicochemical monitoring would be performed for 

7 routine operations with provisions for additional evaluation in response to potential accidental 

8 releases. 

9 Physicochemical monitoring would sample stormwater, soil, sediment, vegetation, and 

10 groundwater (Table 6-5) to confirm that chemical discharges are below regulatory limits. There 

11 are no surface waters on the site; therefore, no surface water monitoring program would be 

12 implemented. However, soil sampling would include outfall/overflow areas such as the outfall at 

13 the Site Stormwater Retention Basins. In the event of any accidental release from the facility, 

14 these sampling protocols would be initiated immediately and on a continuing basis to document 

15 the extent/impact of the release until conditions have been abated and mitigated (IIFP, 2009). 

16 Table 6-5. Physicochemical Sampling 

Sample Type Sample Location Frequency 

Sampling and 

Collections2

Stormwater Stormwater Detention 

Basins Quarterly Analytes as determined by baseline program 

Vegetation 5 minimum1 Quarterly/ 

Semiannually3

Fluoride Uptake 

(growing seasons) 

Soils 5 minimum1 Quarterly/ 

Semiannually3

Metals, Organics, 

Pesticides, and 

Fluoride Uptake 

Water/Sediment 2 minimum1 Quarterly/ 

Semiannually3

Analytes as determined 

by baseline program 

Groundwater Selected Groundwater 

Wells Semiannually Metals, Organics, and Pesticides 

17 Source: IIFP, 2009 

1 18 Locations to be established by Health Safety &Environmental organization. 

2 19 Analyses will meet EPA Lower Limits of Detection (LLD), as applicable, and will be based on the baseline surveys 

20 and the sample type. 3 21 Quarterly during pre-operations; semiannual during operations. 

22 

23 Waste liquids, solids and gases from related processes and decontamination operations would 

24 be analyzed and/or monitored for chemical contamination to determine safe disposal methods 

25 or further treatment requirements. 

26 6.2.2 Evaluation and Analysis of Samples 

27 Samples of liquid effluents, solids and gaseous effluents from plant processes would be 

28 analyzed in the environmental monitoring laboratory. Results of process sample analyses 

29 would be used to verify that process parameters were operating within expected performance 

30 ranges. Results of liquid effluent sample analyses would be characterized to determine if 

31 treatment is required prior to discharge or disposal. 
 6-9 

1 6.2.3 Quality Assurance 

2 Quality assurance would be achieved by following a set of formalized and controlled procedures 

3 that IIFP would create, implement and periodically review for sample collection, lab analysis, 

4 chain of custody, reporting of results, and corrective actions. Corrective actions would be 

5 instituted if an action level is exceeded for any of the measured parameters. IIFP would 

6 establish three action levels: the sample parameter is three times the normal background level, 

7 the sample parameter exceeds any existing administrative limits, or the sample parameter 

8 exceeds any regulatory limit. The third scenario represents the worst case, which is not 

9 expected, however, triggering any of the three action levels would initiate an action plan. 

10 Corrective actions would be implemented to ensure that the cause for the action level 

11 exceedance is identified and immediately corrected; applicable regulatory agencies are notified, 

12 if required; communications to address lessons learned are dispersed to appropriate personnel; 

13 and applicable procedures are revised accordingly, if needed. Action plans would be 

14 commensurate with the severity of the exceedance. 

15 IIFP would ensure that the onsite laboratory and any contract laboratory used to analyze IIFP 

16 samples participates in third-party laboratory intercomparison programs appropriate to the 

17 media and analytes being measured. The IIFP facility would require all radiological and non18 radiological laboratory vendors to be certified by the National Environmental Laboratory 

19 Accreditation Conference or an equivalent State laboratory accreditation agency for the analytes 

20 being tested. 

21 6.2.4 Lower Limits of Detection 

22 Lower limits of detection (LLDs) for the parameters sampled for in the Stormwater Monitoring 

23 Program are listed in Section 6.2.6. LLDs for the non-radiological parameters would be based 

24 on the results of the baseline surveys and the sampled media. Minimum detectable 

25 concentrations for environmental samples are listed in Table 6-6. 

26 Table 6-6. Required Minimum Detectable Concentrations for Environmental Sample 

27 Analyses 

Medium Analysis 

Minimum Detectable 

Concentrations 

Bq/ml (μCi/ml) 

Ambient Air gross alpha 3.7 x 10-14 (1.0 x 10-18) 

Vegetation isotopic uranium 3.7 x 10-6 (1.0 x 10-10) 

Soil/Sediment isotopic uranium 1.1 x 10-2 (3.0 x 10-7) 

Groundwater isotopic uranium 3.7 x 10-8 (1.0 x 10-12) 

28 Source: IIFP, 2009. 

29 Bq/ml = becquerel/milliliter 

30 μCi/ml = microcurie/milliliter 

31 

32 6.2.5 Effluent Monitoring 

33 Chemical constituents that may be discharged to the environment would be below 

34 concentrations established by State and Federal regulatory agencies as protective of the public 

35 health and the natural environment. Under routine operating conditions, no significant quantities 

36 of contaminants would be released from the facility. This would be confirmed through 
 6-10 

1 monitoring and collection and analysis of environmental data. The facility would not directly 

2 discharge any industrial effluents to surface waters or to offsite locations, and there would be no 

3 plant tie-in to a publicly owned wastewater treatment works. Except for discharges from the 

4 sanitary treatment system, liquid effluents would be contained in the IIFP facility in collection 

5 tanks and retention basins. 

6 No chemical sampling is planned for sanitary wastes because no plant process related effluents 

7 would be introduced into that system. 

8 6.2.6 Stormwater Monitoring Program 

9 A stormwater monitoring program would be initiated during construction. Data collected from 

10 the program would be used to evaluate the effectiveness of measures taken to prevent the 

11 contamination of stormwater and to retain sediments within site boundaries. A temporary 

12 detention basin would be used as a sediment control basin during construction as part of the 

13 overall sedimentation erosion control plan. 

14 Stormwater monitoring would continue with the same frequency upon initiation of facility 

15 operation. During plant operation, samples would be collected from the DUF6 Cylinders Storage 

16 Pad Stormwater Retention Basin and the Site Stormwater Detention Basin to demonstrate that 

17 runoff does not contain contaminants. A list of parameters to be monitored and monitoring 

18 frequencies is presented in Table 6-7. 

19 Table 6-7. Stormwater Monitoring Program 

Parameter Frequency Sampling Method 

Lower Limit of 

Detection 

Oil & Grease Quarterly Grab 0.5 ppm 

Total Suspended Solids Quarterly Grab 0.5 ppm 

5-Day Biological Oxygen 

Demand Quarterly Grab 2 ppm 

Chemical Oxygen Demand Quarterly Grab 1 ppm 

Total Phosphorous Quarterly Grab 0.1 ppm 

Total Kjeldahl Nitrogen Quarterly Grab 0.1 ppm 

pH Quarterly Grab 0.01 units 

Nitrate plus Nitrite Nitrogen Quarterly Grab 0.2 ppm 

Metals Quarterly Grab Varies1

20 Source: IIFP, 2009. 

1 21 Analyses will meet EPA LLD, as applicable, and will be based on the baseline surveys and the sample type. 

22 ppm = parts per million 

23 

24 The monitoring program would be refined to reflect applicable requirements as determined 

25 during the NPDES permit application process. Additionally, the Site Stormwater Retention 

26 Basin would adhere to the requirements of the Groundwater Discharge Permit/Plan from the 

27 New Mexico Water Quality Board. 
 6-11 

1 6.2.7 Environmental Monitoring 

2 The purpose of this section is to describe the surveillance monitoring program, which would be 

3 implemented to measure non-radiological chemical impacts on the environment. The ability to 

4 detect and contain any potentially adverse chemical releases from the facility to the environment 

5 would depend on chemistry data collected as part of the effluent and stormwater monitoring 

6 programs described in the preceding sections. Data acquisition from these programs 

7 encompasses both onsite and offsite sample collections. Final constituent analysis 

8 requirements would be in accordance with permit mandates. Sampling locations would be 

9 determined based on meteorological information and current land use. The sampling locations 

10 may be subject to change as determined from the results or any significant changes in land use. 

11 The chemical monitoring program is designed to identify chemical concentrations in the 

12 environment that could be attributed to plant operations. 

13 Vegetation samples would include grasses and shrub brush. Soil would be collected in the 

14 same vicinity as the vegetation sample. The samples would be collected from sectors chosen 

15 based on predicted direction of the prevailing winds. Sediment samples would be collected 

16 from the discharge points of the stormwater collection basins. Groundwater samples would be 

17 collected from the series of wells described in Section 6.1.2.1. Stormwater samples collected in 

18 the DUF6 Cylinder Storage Pad Stormwater Retention Basin would be sampled to ensure no 

19 contaminants are present. 

20 Operational sample results would be compared to baseline data collected during preoperational 

21 sampling to identify any positive trends. On October 15, 2010, two soil and two vegetation 

22 baseline samples were collected for analysis. Tables 6-8 and 6-9 present the results of these 

23 samples. 

24 Operational monitoring surveys would be conducted at locations and frequencies established 

25 from baseline sampling data and as determined by requirements in EPA Region 6 NPDES 

26 General Discharge Permits and the New Mexico Water Quality Board Groundwater Discharge 

27 Permit/Plan. 

28 Annually IIFP would submit a summary of the environmental sampling program results to 

29 regulatory authorities, as required. This summary would include the types, numbers and 

30 frequencies of samples collected, analytical results, and a discussion of any observed trends. 

31 Significant positive trends would be discussed, along with any adjustments to the program, 

32 unavailable samples, or deviations from the sampling protocol. 

33 Table 6-8. Baseline Physicochemical Soil Sample Results 

Soil Sample 1 

(mg/kg) 

Soil Sample 2 

(mg/kg) 

Barium 88.5 109 

Cadmium 0.27 0.42 

Chromium 10.0 12.2 

Lead 11.7 14.7 

All other Resource 

Conservation and Recovery Act 

Metal Concentrations 

Less than minimum detectable 

concentrations 

Less than minimum detectable 

concentrations 

34 Source: GL Environmental, 2010 

35 mg/kg = milligrams/kilogram 
 6-12 

1 Table 6-9. Baseline Physicochemical Vegetation Sample Results 

Vegetation Sample 1 

(mg/kg) 

Vegetation Sample 2 

(mg/kg) 

Resource Conservation and 

Recovery Act Metal 

Concentrations 

Less than minimum detectable 

concentrations 

Less than minimum detectable 

concentrations 

Barium 10.6 10.9 

Benzoic acid 0.48 0.46 

Bis(2-ethylhexyl) phthalate 0.26 0.19 

Phenol 0.40 Less than minimum detectable 

concentrations 

2 Source: GL Environmental, 2010 

3 mg/kg = milligrams/kilogram 

4 

5 6.2.8 Meteorological Monitoring 

6 Atmospheric conditions (e.g., wind speed, wind direction, temperature, precipitation, relative 

7 humidity) would be monitored by electronic sensors mounted on a 40 m (131 ft) tower located 

8 on site. Data from this monitoring program would be used to characterize the site’s 

9 meteorological conditions (both normal and extreme) in order to predict patterns of radionuclide 

10 and chemical dispersion and deposition. The meteorological tower would be at the same 

11 elevation as the finished facility grade. The tower would be located at a distance at least ten 

12 times the height of any obstruction to ensure that wind flow around structures would interfere 

13 with meteorological sampling. IIFP would establish instrument maintenance and calibration 

14 schedules, keep back-up monitoring equipment on hand, and deploy redundant data recorders 

15 to ensure at least 90 percent data recovery. 

16 6.3 Ecological Monitoring 

17 The ecological monitoring program would be designed to characterize changes that may occur 

18 in the composition of biotic communities as a result of site preparation, construction, operation, 

19 and decommissioning of the proposed IIFP facility. The program would focus on observable 

20 changes in habitat characteristics and wildlife populations. 

21 The ecological monitoring program would be carried out in accordance with generally accepted 

22 monitoring practices and the requirements of the USFWS and NMGF. Under the program, data 

23 would be collected and analyzed. Procedures would be established, as appropriate, for data 

24 collection, storage, analysis, reporting, and corrective actions. 

25 6.3.1 General Ecological Conditions of the Site 

26 Section 3.8 describes the natural environment of the proposed site and vicinity. The area is a 

27 transitional zone between the shortgrass prairie north of the Mescalero Ridge (Western Great 

28 Plains Shortgrass Prairie) and the desert communities south of the Mescalero Ridge 

29 (Apacherian-Chihuahuan Mesquite Upland Scrub). These habitat types commonly occur in the 

30 vicinity of the IIFP site (Figure 3-19). The vegetation in this area is dominated by deep sand 

31 tolerant- and extreme drought- and grazing-tolerant plant species. The natural habitats on the 

32 IIFP site and the region surrounding the site have been degraded by livestock grazing, oil and 

33 gas pipeline rights-of-way and access roads. As described in Section 3.7.2 of this draft EIS, 
 6-13 

1 there are no wetlands or stream systems on the facility footprint, and therefore, no riparian 

2 habitat. 

3 There are no important ecological communities on site that are vulnerable to change or that 

4 contain important species habitats, such as breeding areas, nursery, feeding, or other areas 

5 important to important species (Section 3.8). 

6 6.3.2 Monitoring Program Elements 

7 Several ecological elements would be monitored vegetation, birds, mammals, reptiles and 

8 amphibians. Currently there are no known actions or reporting levels for any of these elements. 

9 However, discussions with the responsible agencies (NMGF and USFWS) would continue and 

10 agency recommendations would be considered when developing action and/or reporting levels 

11 for each element. 

12 IIFP would periodically monitor the proposed site property during the construction phases, 

13 operation phases, and decommissioning to ensure the risk to wildlife is minimized. 

14 6.3.3 Observations and Sampling Design 

15 The monitoring program would establish site baseline data collected before commencement of 

16 preconstruction activities. The procedures to characterize the baseline plant and animal 

17 populations would also be used for the construction and operations monitoring programs. 

18 Monitoring surveys during operations would be conducted annually for vegetation and 

19 semiannually for animals using the same sampling sites established during the baseline 

20 monitoring program (IIFP, 2009). 

21 These surveys are intended to be sufficient to characterize broad changes in the composition of 

22 the ecological community in the vicinity of the facility that could be attributed to activities at the 

23 facility. 

24 The analyses would comprise descriptive statistics (sample size, mean, standard deviation, 

25 standard error, and confidence interval for the mean). For these studies, a significance level of 

26 5 percent would be used, resulting in a 95 percent confidence level (IIFP, 2009). 

27 The data collected would be analyzed by the Environment, Health, and Safety staff. Annually 

28 report summarizing the results would be prepared (IIFP, 2009). The monitoring program for 

29 each of the ecological elements described below would be used for the duration stipulated in the 

30 terms of the NRC license agreement, if granted. The anticipated duration would most likely be 

31 the first three years of operation of the proposed IIFP facility. Following that initial monitoring 

32 period, program changes could be initiated based on operational experience and the results of 

33 the initial monitoring. 

34 6.3.3.1 Vegetation 

35 The following vegetation parameters would be monitored: species composition, percent ground 

36 cover, stem frequency, woody plant density, and production data. Sampling from 16 permanent 

37 sampling locations on the IIFP site would occur annually in September or October. Annual 

38 sampling is scheduled to coincide with the mature flowering stages of the dominant perennial 

39 species. 
 6-14 

1 The sampling locations would be selected in areas outside of the proposed footprint of the IIFP 

2 facility. The selected sampling locations would be clearly marked (i.e., staked or flagged) on 

3 site, and the Global Positioning System (GPS) coordinates recorded. Permanent sampling 

4 locations would facilitate a long-term monitoring system designed to evaluate vegetation trends 

5 and characteristics. 

6 Transects used for data collection would extend out 30-m (98-ft) in a given compass direction at 

7 each sampling location. Ground cover and stem occurrence frequency would be determined 

8 utilizing the line intercept method. Cover measurements would be read to the nearest 0.03-m 

9 (0.1-ft). Woody plant densities would be determined using the belt transect method. All 

10 individual shrubs and trees within 2-m (6.6-ft) of the 30-m (98-ft) transect would be counted. 

Productivity would be determined by estimating the production within three 0.25-m2

 (2.7-ft2 11 ) 

plots and harvesting each species in one 0.25-m2

 (2.7-ft2 12 ) plot along the transect and converting 

13 the dry weight of the plot vegetation into kg of forage per ha (lbs/ac). 

14 6.3.3.2 Birds 

15 Site-specific avian surveys would be conducted in both the wintering and breeding seasons to 

16 verify the presence of particular bird species. For the winter survey, the distinct habitats at the 

17 site would be identified and the bird species composition within each of the habitats described. 

18 Transects, 100-m (328-ft) in length, would be established within each distinct homogenous 

19 habitat, and data would be collected along each transect. Species composition and relative 

20 abundance would be determined based on visual observations and call counts. The spring 

21 survey would also determine the nesting and migratory status of the species observed and (as a 

22 measure of the nesting potential of the site) the occurrence and number of male territories. The 

23 area would be surveyed using the standard point count method. 

24 All birds seen or heard by a qualified observer at each point would be recorded. Surveys would 

25 begin 15 minutes prior to sunrise and conclude by 10:00 am (or earlier on warm days) to 

26 coincide with the territorial males’ peak singing times. The points would be recorded using a 

27 GPS, enabling return visits. Data would be compared with species known to exist in the area. 

28 6.3.3.3 Mammals 

29 All mammals observed during other ecological sampling will be noted and results compared to 

30 the species list compiled for the area. 

31 6.3.3.4 Reptiles and Amphibians 

32 A combination of pitfall trapping and walking transects (at trap sites) would provide data in 

33 sufficient quantity to allow statistical measurements of population trends, community 

34 composition, body size distributions and sex ratios that would reflect environmental conditions 

35 and changes at the site over time. 

36 Each sample site would be located to maximize the total catch of reptile and amphibian species, 

37 rather than data on each individual caught. Each animal caught would be identified, sexed, 

38 snout-vent length measured, examined for morphological anomalies and released (sample with 

39 replacement design). There would be two sample periods, at the same time each year, in May 

40 and late June/early July, which would coincide with breeding activity for lizards; most snakes; 

41 and depending on rainfall, amphibians. 
 6-15 

1 Because reptile and amphibian species are sensitive to climatic conditions, and to account for 

2 the spotty effects of rainfall, each sampling event would also record rainfall, relative humidity 

3 and temperatures. The rainfall and temperature data would act as a covariant in the analysis. 

4 In addition to the monitoring plan described above, general observations would be gathered and 

5 recorded concurrently with other wildlife monitoring. The data would be compared to all the 

6 species known to exist in the area. 

7 6.4 References 

8 (GL Environmental, 2010) GL Environmental, Inc. 2010. 2010 Soil and Vegetation 

9 Characterization Report. Prepared for International Isotopes Fluorine Products. ADAMS 

10 Accession No. ML112140543 

11 (IIFP, 2009) International Isotopes Fluorine Products, Inc. 2009. Fluorine Extraction Process & 

12 Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A. 

13 December 27, 2009. ADAMS Accession No. ML100120758. 

14 (NRC, 1977) U. S. Nuclear Regulatory Commission. 1977. Calculation of Annual Doses to Man 

15 from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 

16 10 CFR 50, Appendix I. Regulatory Guide 1.109, Revision 1. October, 1977. 

17 (NRC, 2007) U.S. Nuclear Regulatory Commission. 2007. Quality Assurance for Radiological 

18 Monitoring Programs (Inception Through Normal Operations to License Termination)-Effluent 

19 Streams and the Environment. Regulatory Guide 4.15. Revision 2. 2007. 

20 (NRC, 2010) U.S. Nuclear Regulatory Commission. 2010. Monitoring and Reporting 

21 Radioactive Materials in Liquid and Gaseous Effluents from Nuclear Fuel Cycle Facilities. 

22 Regulatory Guide 4.16. Revision 2. 2010.

 7-1 

1 7.0 COST-BENEFIT ANALYSIS SUMMARY 

2 This chapter summarizes benefits and costs associated with the proposed action and the no3 action alternative. Chapter 4 (Environmental Impacts) of this draft EIS discusses the potential 

4 impacts of the construction, operation, and decommissioning of the proposed IIFP facility. 

5 Implementation of the proposed action would generate national, regional, and local benefits and 

6 costs. The primary national benefit of the proposed IIFP facility would be a benefit to the 

7 national uranium fuel cycle by ensuring that commercial enrichment facilities throughout the 

8 nation do not have to rely on long-term storage of DUF6. The regional benefits of the proposed 

9 project would be increased employment, economic activity, and tax revenues in the region 

10 around the proposed site. Some of these regional benefits, such as tax revenues, would accrue 

11 specifically to Lea County and the City of Hobbs. Other benefits may extend to neighboring 

12 Eddy County. Environmental costs associated with the proposed IIFP facility are, for the most 

13 part, limited to the area immediately surrounding or on the site. 

14 The data for this analysis are drawn largely from Chapter 4, the assessment of environmental 

15 impacts. Monetary cost data is taken from IIFP’s environmental report prepared for the license 

16 application (IIFP, 2009) and subsequent responses to NRC staff’s requests for additional 

17 information (IIFP, 2011). The analysis separately covers both the construction (including 

18 preconstruction) and operations phases. As described in Section 4.1.3, NRC regulation 

19 10 CFR 40.36 requires IIFP to have a decommissioning plan and provide for funding of the 

20 decommissioning. Decommissioning costs are evaluated in this analysis only in terms of 

21 payments to a decommissioning fund. 

22 Section 7.1 presents the costs and benefits of the no-action alternative. Section 7.2 presents 

23 costs of the proposed action. Section 7.3 presents benefits of the proposed action. Section 7.4 

24 presents a summary of the cost-benefit analysis, including NRC staff’s determination of cost25 effectiveness. 

26 7.1 Costs and Benefits of the No-Action Alternative 

27 Under the no-action alternative, NRC would not grant a license to IIFP to construct, operate and 

28 decommission the facility. No DUF6 would be deconverted into fluoride products (for 

29 commercial resale) and depleted uranium oxides (for disposal). Without a deconversion facility 

30 such as the proposed facility, DUF6 would continue to be stored, primarily at commercial 

31 uranium enrichment facilities in the United States. Fluoride products would not be 

32 manufactured and sold to end users. Planned or existing commercial enrichment facilities 

33 would not be able to send their DUF6 to the IIFP facility for deconversion. As a result, the 

34 proposed site would not be disturbed by the proposed project activities. Ecological, natural, and 

35 socioeconomic resources would remain unaffected by the proposed action, except for what 

36 occurred during preconstruction. All potential environmental impacts from the proposed action 

37 (that is, not including preconstruction) would be avoided. Similarly, all project-specific 

38 socioeconomic impacts (e.g., related to employment, economic activity, population, housing, 

39 local finance) would be avoided. 

40 Table 2.5 of Section 2.3 summarizes and compares the external environmental costs and 

41 benefits of both the proposed action and the no-action alternatives. Section 4.1 provides details 

42 on these external environmental and socioeconomic costs and benefits for the proposed action. 

43 Section 4.3 provides details for the no-action alternative. 
 7-2 

1 7.2 Costs of the Proposed Action 

2 The costs for a project are usually presented as internal and external costs. Internal costs are 

3 those that are borne by the owner, IIFP in this instance. These costs are most easily expressed 

4 as monetary costs. External costs are those borne by others or by the environment. Such 

5 costs can be monetary, but most often include both quantitative and qualitative environmental 

6 impacts. As described in Sections 2.1 and 2.2.2.2.1, IIFP intends to develop this project in two 

7 phases, with the Phase 1 component the subject of the current license application. Because 

8 Phase 2 is closely related to Phase 1 and is a reasonably foreseeable action for which analysis 

9 of cumulative impacts is required, this section presents both Phase 1 and Phase 2 costs. 

10 Section 7.2.1 discusses costs during the construction phase, and Section 7.2.2 discusses costs 

11 during the operations phase. 

12 7.2.1 Construction Costs 

13 7.2.1.1 Internal Costs 

14 Internal construction costs include capital costs and labor costs. All costs are presented in 2009 

15 dollars. 

16 IIFP’s environmental report provides cost estimates based on the assumptions presented there. 

17 Table 7-1 of this section presents the capital costs and labor costs. Both capital and labor costs 

18 are spread out over the years of construction (2012 through 2013 for Phase 1 and 2015 through 

19 2016 for Phase 2). 

20 Table 7-1. Construction Capital and Labor Costs for the IIFP Facility (millions of 2009 

21 dollars) 

Cost Category 

Phase 1 

Costsa 

(in millions of 

dollars) 

Phase 2 

Costsa 

(in millions of 

dollars)

Total Phases 1 

and 2 Costs 

(in millions of 

dollars) 

Capital Costs 

Fixed Capital 

DUF4 plant $9 – $12 0 $9 – $12 

FEP plant $15 – $19 0 $15 – $19 

Oxide add-on plant 0 $26 – $34 $26 – $34 

Balance of Plant $15 – $20 $1 – $1.5 $16 – $21.5 

Engineering, procurement, and 

construction management $7 – $11 $7 – $9 $14 – $20 

Project management and programs $2 – $3 $1 – $1.5 $3 – $4.5 

Contractor fees $2 – $3 $1 – $2 $3 – $5 

Contingency $5 – $6 $3 – $4 $8 – $10 

Subtotal Fixed Capital $55 – $74 $39 – $52 $94 – $126 

Development/Startup Capital 

Regulatory, licenses, permits $3 – $4 $1 – $1.5 $4 – $5.5 

Pre-startup working capital $9 – $12 $1 – $2 $10 – $14 
 7-3 

1 Table 7-1. Construction Capital and Labor Costs for the IIFP Facility (millions of 2009 

2 dollars) (Continued) 

Cost Category 

Phase 1 

Costsa 

(in millions of 

dollars) 

Phase 2 

Costsa 

(in millions of 

dollars) 

Total Phases 1 

and 2 Costs 

(in millions of 

dollars) 

Spare parts and startup inventories $3 – $4 $1 – $1.5 $4 – $5.5 

Subtotal Development/Startup $15 – $20 $3 – $5 $18 – $25 

Total Capital Costs $70 – $94 $42 – $57 $112 – $151 

Labor Costs 

Construction and installation $22.3 – $34.1 $13.7 – $20.9 $36 – $55 

Engineering, procurement, and 

construction management $6.1 – $9.2 $3.7 – $5.7 $9.8 – $14.9 

Project management $1.6 – $2.3 $0.9 – $1.4 $2.5 – $3.7 

Total Labor Costs $29.9 – $45.6 $18.4 – $28.0 $48.3 – $73.6 

Total Capital and Labor costs $99.9 – $139.6 $60.4 – $85.0 $160.3 – $224.6 

3 Source: IIFP, 2009 

a 4 Phase 1 and Phase 2 labor costs are estimated from the cumulative costs, based on the 62 percent-38 percent 

5 cost split for capital costs as found in the capital costs. 

6 

7 7.2.1.2 External Costs 

8 External construction costs are summarized here. 

9 Land Use: 259 ha (640 ac) of grazing land converted to industrial use 

10 Historic and Cultural Resources: no resources expected to be affected 

11 Visual Resources: no adverse impact expected 

12 Climatology, Meteorology, and Air Quality: small, temporary, and local impacts to air quality; 

13 some small amount of CO2 and other GHGs, criteria pollutants, and HAPs released 

14 Geology, Mineral, and Soils: no prime farmland affected; 16 ha (40 ac) cleared 

15 Water Resources: groundwater withdrawal a small percentage of that available; groundwater 

16 quality not expected to be adversely impacted; no surface water use or discharge 

17 Ecological Resources: 16 ha (40 ac) of grassland removed; no threatened or endangered 

18 species expected to be affected 

19 Socioeconomic Resources and Local Community Services: small decrease in available public 

20 service capacities; small increases in local tax revenues; small influx of money to the local 

21 economy; small improvement in employment rate 

22 Traffic and Transportation: small increase in traffic near the intersection of NM 483 and 

23 US 62/180, but not sufficient to warrant mitigation 
 7-4 

1 Noise: no adverse impact expected 

2 Public and Occupational Health Impacts: construction injuries typical for industrial construction; 

3 no fatalities expected statistically 

4 Waste Management: waste generation a small percentage of existing disposal capacities 

5 7.2.2 Operations Costs 

6 7.2.2.1 Internal Costs 

7 Internal operations costs include raw materials, utilities, marketing and distribution, operations 

8 and maintenance, labor, waste disposal, and replacement capital costs. All costs are presented 

9 in 2009 dollars. The annual costs presented were estimated based on a 40-year plant operating 

10 life. The data presented here are from IIFP’s environmental report (IIFP, 2009) and subsequent 

11 responses to NRC staff’s requests for additional information (IIFP, 2011), and based on the 

12 assumptions presented in these documents. 

13 Raw Materials 

14 IIFP states (IIFP, 2009) that the proposed plant would use relatively small amounts of raw 

15 materials. This is because the primary input to the plant is a waste product from existing and 

16 proposed commercial enrichment facilities. The primary raw materials, other than the DUF6

17 feedstock, are SiO2, B2O3, Ca(OH)2, KOH, and hydrogen gas. These materials are not 

18 expected to be procured in the region of influence (Lea and Eddy counties). The annual costs 

19 (in 2009 dollars) for raw materials are as follows: 

20 Phase 1: $1.89 million 

21 Phase 2 (incremental): $0.82 million 

22 Cumulative: $2.71 million 

23 Utilities 

24 Utilities include electricity, natural gas, water, nitrogen, steam, and compressed air. Some of 

25 these utilities would be produced on site. However, approximately $1.5 million (2009 dollars) 

26 per year of utilities would be procured during the Phase 1 only facility operations between 2013 

27 and the beginning of 2017. An additional $1.7 million per year of utilities for Phase 2 would be 

28 procured each year from 2017 through 2050 as a result of the expansion to the Phase 2 facility. 

29 Beginning in 2017, the cumulative utilities procured from utility companies located in the region 

30 or State would cost approximately $3.2 million each year, thereby benefiting the local and state 

31 economies. 

32 Marketing and Distribution 

33 IIFP reports that the marketing and distribution of FEP products would likely amount to 

34 8 percent of the SiF4 cost or approximately $200,000 to $250,000 annually (2009 dollars). Only 

35 SiF4 is accompanied by any marketing and distribution costs because the other products are 

36 sold to only a few customers under contracts. This is an annual cost that would be incurred 

37 irrespective of the startup of Phase 2, because SiF4 is generated in the Phase 1 process. 
 7-5 

1 Operations and Maintenance 

2 Operations and maintenance (O&M) costs would be those associated with purchasing materials 

3 for repair and replacement of equipment or infrastructure, and operating supplies such as office 

4 supplies, safety equipment, or laboratory chemicals. IIFP estimates that the annual O&M costs 

5 (2009 dollars) would be: 

6 Phase 1: $2.7 million 

7 Phase 2 (incremental): $1.6 million 

8 Cumulative O&M cost: $4.3 million 

9 Not all of these monies would be spent in the region of influence. 

10 Labor 

11 Section 4.1.2.8 presents the workforce requirements for the IIFP facility operations. In 

12 Tables 7-8 and 7-9 of IIFP’s environmental report (IIFP, 2009), IIFP projects the annual labor 

13 costs for both Phase 1 and Phase 2. These are as follows, in 2009 dollars: 

14 Phase 1: $7.9 million to $9.1 million 

15 Phase 2 (incremental): $1.4 million to $1.7 million 

16 Cumulative labor cost: $9.6 million to $10.5 million 

17 Waste Disposal 

18 The types and quantities of waste for disposal are reported in Section 4.1.2.12. The largest 

19 disposal costs would be associated with depleted uranium oxide; however, other LLW, RCRA 

20 waste, and sanitary waste would be disposed as well. The costs for Phase 1 and Phase 2 

21 waste disposal are presented in Table 7-10 of the IIFP’s environmental report (IIFP, 2009 as 

22 modified by IIFP [2011]) and are reproduced in Table 7-2. 

23 Table 7-2. Estimated Annual Waste Disposal Costs (millions of 2009 dollars) 

Waste Type 

Phase 1 

(in millions of 

dollars) 

Phase 2 

(in millions of 

dollars) 

Cumulative 

(in millions of 

dollars) 

Depleted uranium oxide $2.6 – $7.0 $5.4 – $15.5 $8.0 – $22.5 

Other process low-level waste $0.25 – $0.40 $0.01 – $0.05 $0.26 – $0.45 

Miscellaneous low-level waste $0.23 – $0.35 $0.22 – $0.30 $0.45 – $0.65 

RCRA waste $0.009 – $0.035 $0.005 – $0.010 $0.014 – $0.045 

Sanitary waste $0.002 – $0.003 negligible $0.002 – $0.003 

Total1 $3.1 – $7.8 $5.6 – $16 $8.7 – $24 1 24 Totals rounded to two significant digits. 

25 

26 Replacement Capital 

27 Replacement capital would be required to replace infrastructure and equipment over the life of 

28 the facility. IIFP estimates that replacement costs over the 40-year assumed life of the facility 

29 would be approximately $60 million to $85 million (2009 dollars); however, no replacement 
 7-6 

1 capital expenditures are expected for the first 7 years. The costs accumulate more heavily as 

2 the facility ages. The NRC staff calculated an average annual replacement capital cost of 

3 $1.8 million to $2.8 million over the 13 years of maximum replacement expenditures. 

4 Table 7-3 reports the values reported by IIFP in Chapter 7 of the environmental report 

5 (IIFP, 2009) and the subsequent response to NRC staff’s requests for additional information 

6 (IIFP, 2011). 

7 Table 7-3. Estimated Replacement Capital Expenditures (millions of 2009 dollars) 

Time Period 

Phase 11 

(in millions of 

dollars) 

Phase 21 

(in millions of 

dollars) 

Cumulative 

(in millions of 

dollars) 

2011 – 2016 0 0 0 

2017 – 2027 $4.6 – $5.6 $4.4 – $5.4 $9 – $11 

2028 – 2037 $17.9 – $21.9 $17.2 – $21.1 $35 – $43 

2038 – 2050 $16.3 – $19.9 $15.7 – $19.1 $32 – $39 

Total 40-year period $38.8 – $47.4 $37.3 – $45.6 $76 – $93 1 8 IIFP (2011) states that 51 percent and 49 percent of the replacement capital costs would be associated 

9 with Phase 1 equipment and Phase 2 equipment, respectively. 

10 

11 Summary of Internal Operations Costs 

12 Table 7-4 provides the total internal operations costs per year. 

13 Table 7-4. Total Annual Internal Operations Costs (millions of 2009 dollars) 

Type of Internal Cost 

Phase 1 

(in millions of 

dollars) 

Phase 2 

(in millions of 

dollars) 

Cumulative 

(in millions of 

dollars) 

Raw materials $1.89 $0.82 $2.71 

Utilities $1.5 $1.7 $3.2 

Marketing and distribution $0.20 – $0.25 0.0 $0.20 – $0.25 

O&M $2.7 $1.6 $4.3 

Labor $7.9 – $9.1 $1.4 – $1.6 $9.6 – $10.5 

Waste disposal $3.1 – $7.8 $5.6 – $16 $8.7 – $24 

Replacement capital $38.8 – $47.4 $37.3 – $45.6 $76 – $93 

Total1 $56 – $71 $48 – $67 $100 – $140 1 14 Totals rounded to two significant digits. 

15 

16 7.2.2.2 External Costs 

17 External operations costs are summarized here. 

18 Land Use: Land use would be consistent with other uses in the area 

19 Historic and Cultural Resources: no resources expected to be affected 
 7-7 

1 Visual Resources: no adverse impact expected 

2 Climatology, Meteorology, and Air Quality: small and local impacts to air quality 

3 Geology, Mineral, and Soils: no adverse impact 

4 Water Resources: groundwater withdrawal a small percentage of that available; groundwater 

5 quality not expected to be adversely impacted; no surface water use or discharge 

6 Ecological Resources: no adverse impact expected 

7 Socioeconomic Resources and Local Community Services: small decreases in public service 

8 capacities; small increases in local tax revenues; small influx of money to the local economy; 

9 small improvement in employment rate 

10 Traffic and Transportation: small increase in traffic near the intersection of NM 483 and 

11 US 62/180, but not sufficient to warrant mitigation; radiation doses to members of the public 

12 from transport of radioactive wastes and depleted uranium far less than normal background 

13 Noise: no adverse impact expected 

14 Public and Occupational Health Impacts: operation injuries typical for industrial plant operation; 

15 no fatalities expected statistically; radiological emissions produce immeasurably small impacts; 

16 chemical emissions small and localized 

17 Waste Management: waste generation a small percentage of existing disposal capacities 

18 7.3 Benefits of the Proposed Action 

19 7.3.1 Construction 

20 Taxes 

21 Phase 1 construction-related activities, purchases, and workforce expenditures would require 

22 several types of tax payments, including individual income taxes, gross receipts taxes, and 

23 property taxes. Increased tax revenues are considered a benefit to the State of New Mexico, 

24 Lea County, the Hobbs Municipal School District, the New Mexico Junior College, the 

25 communities in Lea County, and other locales where plant-related spending would occur. 

26 IIFP (2011) estimates that approximately $554,400 of fee in lieu of property taxes would be paid 

27 to the Hobbs Municipal School District and the New Mexico Junior College during the Phase 1 

28 construction period. IIFP is exempt from any other property tax. 

29 IIFP estimates (in 2009 dollars) that Phase 1 construction costs would be between $70 million 

30 and $94 million (Section 4.1.1.8). Some portion of those expenditures would occur within the 

31 ROI and other counties nearby. The expenditures would generate gross receipts tax revenues 

32 for both the affected counties and for the State of New Mexico (IIFP, 2011b). Because IIFP 

33 would have an industrial revenue bond with Lea County, some facility-related expenditures 

34 would be exempt from gross receipts taxes. 
 7-8 

1 Regional spending on goods and services by IIFP employees would generate gross receipts tax 

2 revenues for Lea and Eddy County municipalities, Lea County, Eddy County, New Mexico, and 

3 other locales where spending occurs. 

4 Employment 

5 During Phase 1 construction of the IIFP facility, 80 percent of the 140 IIFP construction jobs are 

6 expected to be filled by workers that already reside within the two-county ROI (Section 4.1.1.8). 

7 The 112 residents that would fill the construction jobs would represent 0.2 percent of the June 

8 2010 labor force within the region. If all 112 of the jobs were filled by unemployed workers, the 

9 unemployment rate in the region of influence would decrease by 0.2 percent. The remaining 

10 28 jobs would be filled by workers that would migrate into the ROI. The in-migrating workers 

11 would increase the labor force by 0.05 percent (Section 4.1.1.8). The 12 indirect jobs that would 

12 be created during Phase 1 construction of the IIFP facility would likely be filled by regional 

13 residents. If all 12 jobs were filled by unemployed workers, those workers would represent 

14 0.3 percent of the unemployed labor force in June 2010 (Section 4.1.1.8). 

15 Economy 

16 IIFP (2011b) estimates that between $9,140,000 and $13,900,000 (2009 dollars) would be 

17 infused into the economy annually during the construction period for labor and materials. Most 

18 of these values would be spent within the ROI. 

19 7.3.2 Operations 

20 Taxes 

21 Phase 1 operations-related activities, purchases, and workforce expenditures would require 

22 several types of tax payments, including corporate income taxes, individual income taxes, gross 

23 receipts taxes, and property taxes. Increased tax revenues are viewed as a benefit to the State 

24 of New Mexico, Lea County, the Hobbs Municipal School District, the New Mexico Junior 

25 College, the communities in Lea County, and other locales where plant-related spending would 

26 occur. 

27 Table 4-21 presents the estimated corporate income and gross receipts taxes that would be 

28 paid to the State of New Mexico and Lea County entities. The low estimate of corporate income 

29 and gross receipt taxes paid to the State is $144,200,000 and $6,500,000 to Lea County. The 

30 low estimate on property taxes is $8,700,000 to Lea County (IIFP, 2011b). 

31 In addition to IIFP’s income and gross receipts tax payments, plant employees would contribute 

32 state individual income and state and county gross receipts tax revenues. IIFP facility employee 

33 earnings would be taxed as individual income. Regional spending on goods and services by 

34 IIFP employees would generate gross receipts tax revenues for Lea County, Eddy County, the 

35 State of New Mexico, and other locales where their spending would occur. 

36 Employment 

37 Approximately 80 percent of the IIFP operation positions would be filled by people currently 

38 residing in the two-county ROI (Table 4-19). Those 112 workers would represent 0.2 percent of 

39 the June 2010 two-county labor force (Section 4.1.2.8). If all 112 of these jobs were filled by 

40 unemployed workers in the region, the unemployment rate would decrease by 0.2 percent. 
 7-9 

1 Approximately 20 percent of the IIFP operation positions (28 jobs) would be filled by people 

2 migrating into the region of influence from outside the region (Section 4.1.2.8). The in-migrating 

3 workers would represent a 0.2 percent increase of the June 2010 labor force (Section 4.1.2.8). 

4 The in-migration of 28 workers to fill operation positions would also create 51 new indirect jobs 

5 within the ROI because of the multiplier effect (Section 4.1.2.8). If unemployed workers fill the 

6 51 indirect jobs that would be created during the Phase 1 operation of the IIFP facility, they 

7 would represent 1.3 percent of the unemployed labor force in June 2010. 

8 Economy 

9 The regional economy would benefit from the capital investment expenditures and recurring 

10 costs associated with the operation of the IIFP facility. IIFP has provided estimates for some of 

11 these costs. The payroll associated with Phase 1 operating wages is within the range of 

12 $7,900,000 to $9,100,000 annually (Section 4.1.2.8). Operations employees and workers in 

13 indirect positions would spend earnings on goods and services within the region of influence. 

14 Additional costs associated with operations include replacement capital, waste disposal, 

15 insurance premiums, taxes, utilities, and maintenance materials and supplies. These 

16 expenditures would range from $17,315,000 to $23,727,000 annually (Section 4.1.2.8). 

17 National Benefits 

18 Long-term storage of DUF6 poses potential health risks because of the physical and chemical 

19 characteristics of DUF6. If DUF6 is released to the atmosphere, it reacts with water vapor in the 

20 air, forming HF fumes and a uranium-fluoride compound, UO2F2. These products are 

21 chemically toxic. HF is an extremely corrosive gas that can damage the lungs and cause death 

22 if inhaled. 

23 DUF6 has been stored at DOE sites for approximately 40 years. The Defense Nuclear Facilities 

24 Safety Board, in 1995, issued a Technical Report (DNFSB, 1995) calling for improved safety 

25 analysis, inspections, and handling procedures to ensure safe storage of DUF6. DOE has since 

26 embarked on a program of creating deconversion capability at two locations where uranium 

27 enrichment has been performed. 

28 The proposed IIFP facility would provide a benefit to the national uranium fuel cycle by ensuring 

29 that commercial enrichment facilities throughout the nation do not have to rely on long-term 

30 storage. 

31 Silicon tetrafluoride is used in the electronics industry. Boron trifluoride is used for ion 

32 implantation, as a catalyst for polymer reactions, and as a gas in neutron radiation detectors. 

33 Anhydrous hydrogen fluoride has many industrial uses. These byproducts of IIFP’s 

34 deconversion process are marketable. The benefit to the nation is that the IIFP plant would be 

35 an alternate source of inexpensive (because it is the byproduct of the main process) fluoride 

36 products. 

37 7.4 Evaluation Summary of the Proposed IIFP Facility 

38 The internal construction and operations costs for the IIFP facility are based on proprietary 

39 business analyses performed by IIFP. Given that company investors are willing to pursue the 

40 license in light of these costs, the NRC staff’s concern is primarily evaluation of costs to the 

41 communities around the facility and the State of New Mexico. Implementation of the proposed 
 7-10 

1 action would have a SMALL positive overall economic impact on the region of influence. The 

2 implementation of the proposed action would generate national, regional, and local benefits and 

3 costs. 

4 The primary national benefit of building the proposed IIFP facility would be improved 

5 management of the DUF6 part of the uranium fuel cycle. The regional benefits of building the 

6 proposed IIFP facility would be increased employment, economic activity, and tax revenues in 

7 the region around the site. Some of these regional benefits, such as tax revenues, accrue 

8 specifically to Lea County. Other benefits may extend to neighboring counties in the state of 

9 New Mexico. 

10 Costs associated with the proposed IIFP facility are, for the most part, limited to the area 

11 surrounding the site and the communities within commuting distance. These include monetary 

12 and environmental costs. As summarized above, the environmental costs are SMALL to 

13 MODERATE (for air quality). The influx of money into the State and local economies from the 

14 proposed action would appear to more than offset the small financial burdens placed on 

15 community services. The benefits to Lea County, Eddy County, the State of New Mexico, and 

16 the nation’s capacity to maintain the uranium fuel cycle weigh somewhat favorably for the 

17 benefit side of this comparison. 

18 7.5 References 

19 (DNFSB, 1995) U.S. Defense Nuclear Facilities Safety Board. 1995. Integrity of Uranium 

20 Hexafluoride Cylinders. Technical Report DNFSB/TECH-4. May 5, 1995. 

21 (IIFP, 2009) International Isotopes Fluorine Products. Inc. 2009. Fluorine Extraction Process 

22 and Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A, ER23 IFP-001. December 27, 2009. ADAMS Accession No. ML100120758. 

24 (IIFP, 2011) International Isotopes Fluorine Products. 2011. Fluorine Extraction Process and 

25 Depleted Uranium De-conversion Plant (FEP/DUP) Official Responses to Environmental Report 

26 RAIs, Revision A. March 31, 2011. ADAMS Accession No. ML110970481. 
 8-1 

1 8.0 SUMMARY OF ENVIRONMENTAL CONSEQUENCES 

2 On December 30, 2009, IIFP submitted an application to the NRC for a license to construct, 

3 operate, and decommission the proposed IIFP facility (IIFP, 2009). IIFP proposes to locate the 

4 facility in Lea County, New Mexico, approximately 22.5 km (14 mi) west of Hobbs, New Mexico. 

5 If licensed, the proposed facility would deconvert DUF6 into fluoride products (for commercial 

6 resale) and depleted uranium oxides (for disposal). 

7 Source material licenses, such as the one requested for the proposed IIFP facility, are regulated 

8 under Title 10, Code of Federal Regulations, Part 40 (10 CFR 40), in accordance with the 

9 Atomic Energy Act of 1954. Section 102 of the National Environmental Policy Act of 1969, as 

10 amended (NEPA) (Public Law 91-190; Title 42, Section 4321 et seq., United States Code

11 [42 U.S.C. 4321 et seq.]), directs that an Environmental Impact Statement (EIS) is required for 

12 major Federal actions that significantly affect the quality of the human environment. Section 

13 102(2)(C) of NEPA requires that an EIS include information about the following: 

14 • environmental impacts of the proposed action, 

15 • any adverse environmental effects that cannot be avoided, should the proposal be 

16 implemented, 

17 • alternatives to the proposed action, 

18 • the relationship between local short-term uses of the environment and the maintenance 

19 and enhancement of long-term productivity, and 

20 • any irreversible and irretrievable commitments of resources that would be involved if the 

21 proposed action is implemented. 

22 NRC’s regulations under 10 CFR 51 implement the requirements of NEPA. Because the NRC 

23 is responsible for licensing this facility, the licensing action is a Federal action, and must meet 

24 the requirements of NEPA. Based on the EIS and other information [including the original 

25 license application and responses to Requests for Additional Information (RAIs) received by 

26 NRC from the applicant] and analysis of the magnitude of potential impacts, the NRC staff will 

27 determine whether to issue a license to IIFP for the construction, operation, and 

28 decommissioning of the proposed IIFP facility. 

29 IIFP anticipates two phases to the project, but the current license application is for the first 

30 phase only. Phase 2, under NEPA, is considered a “reasonably foreseeable future action” 

31 (40 CFR 1508.7). Therefore, Phase 2 impacts are considered cumulative impacts, and have 

32 been addressed in Section 4.2 of this draft EIS. IIFP expects to begin preconstruction activities 

33 in late 2011. If the license application is approved, IIFP expects to begin facility construction in 

34 2012, which would continue for one year. Phase 2 construction would begin in 2015 and 

35 continue for one year. 

36 As part of its license application, IIFP submitted an Environmental Report (ER). Information in 

37 the ER and supplemental environmental documentation provided by IIFP has been reviewed 

38 and independently verified by the NRC staff and used, in part, by the NRC staff in preparing this 

39 draft EIS. Upon acceptance of the ER, the NRC staff began the environmental review process 

40 described in 10 CFR 51 by publishing, on July 15, 2010, in the Federal Register (75 FR 42142) 

41 a Notice of Intent to prepare an EIS and conduct scoping. The purpose of the EIS scoping 

42 process was to assist in determining the range of actions, alternatives to the proposed action, 
 8-2 

1 and potential impacts to be considered in the EIS, and to identify significant issues related to the 

2 proposed action. Comments and information from the public and government agencies were 

3 received during the scoping period. As part of the scoping process, the NRC staff held a public 

4 scoping meeting on July 29, 2010, in Hobbs, New Mexico. NRC staff considered the public 

5 comments received during the scoping process for preparation of this EIS; the summary of the 

6 EIS scoping process is provided in Appendix A. 

7 In addition to reviewing IIFP’s ER and supplemental documentation, the NRC staff consulted 

8 with appropriate Federal, State, and local agencies and Native American Tribes. 

9 Included in this draft EIS are (1) the results of the NRC staff’s analyses, which consider and 

10 weigh the environmental effects of the proposed action; (2) mitigation measures for reducing or 

11 avoiding adverse effects; (3) the environmental impacts of alternatives to the proposed action; 

12 and (4) the NRC staff’s assessment regarding the proposed action based on its environmental 

13 review. 

14 Potential environmental impacts are evaluated in this draft EIS using the three-level standard of 

15 significance – SMALL, MODERATE, or LARGE – developed by the NRC using guidelines from 

16 the Council on Environmental Quality (CEQ) (40 CFR 1508.27). Table B-1 of 10 CFR 51, 

17 Subpart A, Appendix B provides the following definitions of the three significance levels: 

18 • SMALL – Environmental effects are not detectable or are so minor that they would 

19 neither destabilize nor noticeably alter any important attribute of the resource. 

20 • MODERATE – Environmental effects are sufficient to alter noticeably, but not to 

21 destabilize, important attributes of the resource. 

22 • LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize 

23 important attributes of the resource. 

24 8.1 Unavoidable Adverse Environmental Impacts 

25 Section 102(2)(c)(ii) of NEPA requires that an EIS include information on any adverse 

26 environmental effects that cannot be avoided, should the proposed action be implemented. 

27 Unavoidable adverse environmental impacts are those potential impacts that cannot be avoided 

28 and for which no practical means of mitigation are available. 

29 This section summarizes the environmental consequences for the proposed action that cannot 

30 be avoided and for which no practical means of mitigation are available. Identification and 

31 description of the environmental impacts for the proposed action that would result from 

32 construction, operation, and decommissioning of the proposed IIFP facility are presented in 

33 Chapter 4, “Environmental Impacts.” The mitigation measures that would be incorporated into 

34 the proposed action to control and minimize potential adverse environmental impacts are 

35 summarized in Chapter 5, “Mitigation Measures and Commitments.” The monitoring programs 

36 that would be incorporated into the proposed action are listed in Chapter 6, “Environmental 

37 Measurements and Monitoring Programs.” 

38 Implementing the proposed action would result in unavoidable adverse impacts to land use, 

39 ecological resources, groundwater quantity, and air quality. Unavoidable adverse impacts to 

40 land use would occur at the initiation of the project, commencing with restricting the current land 

41 use, grazing, from the property and committing it, for the duration of the facility license, to 

42 industrial purposes. Site preparation will destroy up to 16 ha (40 ac) of Western Shortgrass 
 8-3 

1 Prairie or Apacherian-Chihuhuan Mesquite Upland Scrub habitat. However, both habitats are 

2 common throughout the region. Some topsoil would be lost during the grading and clearing, but 

3 this loss would be minimized with BMPs. Animal habitats would be destroyed and some 

4 mortality of individuals would occur during construction. The presence of the facility could 

5 prevent some animals from foraging or nesting in the vicinity of the facility. 

6 During construction and operation, facility operations will consume small amounts of 

7 groundwater; the greatest groundwater use would occur during operations. The facility would 

8 use a small amount (approximately 0.5 percent) of the estimated annual 40-year planning 

9 period groundwater demand for Lea County, and 0.15 percent annually of the unappropriated 

10 water rights assigned to Lea County by the New Mexico Office of the State Engineer. 

11 Construction and operation would release small quantities of pollutants, including radionuclides 

12 to the atmosphere. Emissions of CO2 and other greenhouse gases, and CO and SO2 during 

13 construction would be SMALL, however, construction could result in MODERATE impacts from 

14 NO2, PM2.5 and PM10 emissions. Construction impact to air quality would be localized and 

15 temporary. BMPs would minimize impacts to air quality during construction. Plant design would 

16 minimize emissions of radiological and chemical pollutants to levels well below regulatory limits; 

17 concentrations higher than background will not be detectable beyond the site boundary, and the 

18 releases will not adversely affect local or regional air quality. 

19 8.2 Irreversible and Irretrievable Commitments of Resources 

20 Environmental Review Guidance for Licensing Actions Associated with NMSS Programs 

21 [NUREG-1748 (NRC, 2003)], defines an “irreversible” commitment and an “irretrievable” 

22 commitment as follows: 

23 • “Irreversible” refers to the commitment of environmental resources that cannot be 

24 restored. 

25 • “Irretrievable” refers to the commitment of material resources that once used cannot be 

26 recycled or restored for other uses by practical means. 

27 The implementation of the proposed action as described in Section 2.1 would include the 

28 commitment of land, water, energy, raw materials, and other natural and manmade resources. 

29 Approximately 16 ha (40 ac) on the 259-ha (640-ac) site would be affected by the construction, 

30 operation, and decommissioning of the proposed IIFP facility. 

31 It is likely that, once the land has been committed to an industrial use, it will remain in industrial 

32 use in perpetuity, so this should be considered an irreversible commitment. 

33 Groundwater use by the facility during both construction and operation would be consumptive. 

34 Groundwater withdrawn from the Ogallala aquifer will not be returned to the aquifer. Some will 

35 be lost to evaporation in the process, and the treated sanitary wastewater used to irrigate 

36 landscaping will transpire to the atmosphere through the process of photosynthesis. The depth 

37 to groundwater at the site is approximately 30 ft, so it is unlikely any landscape water will return 

38 to the groundwater. 

39 Energy consumption will be in the form of gasoline and diesel fuel for construction equipment 

40 and generators, and coal or natural gas to generate electricity to power the facility. Some 

41 natural gas will be consumed in the production of hydrogen at the facility. These represent 

42 irretrievable uses of those resources. 
 8-4 

1 The construction and operation of the proposed IIFP facility would require commitments of 

2 significant quantities of concrete, steel, nonferrous metals, plastics, and other material 

3 resources. At decommissioning, certain building materials and equipment could be recycled, 

4 however some materials would not be recyclable, and some materials would have been 

5 consumed by the deconversion process. Resources used in the construction and operation of 

6 the facility that could not be reused or recycled at the end of their useful life would represent an 

7 irreversible commitment. Materials consumed during the deconversion process would be 

8 irreversible commitments of resources. Hazardous and radioactive waste streams would be 

9 irreversible commitments of resources, as would the land needed to properly dispose of those 

10 waste streams. 

11 No other irreversible or irretrievable commitments of resources were identified for the 

12 construction, operation, and decommissioning of the proposed IIFP facility. 

13 8.3 Relationship between Local Short-Term Uses of the Environment and the 

14 Maintenance and Enhancement of Long-Term Productivity 

15 Consistent with the CEQ definition in 40 CFR 1502.16 and the definition provided in NUREG16 1748 (NRC, 2003), this draft EIS defines short-term uses and long-term productivity as follows: 

17 • Short-term uses generally affect the present quality of life for the public (i.e., the 40-year 

18 license period for the proposed IIFP facility). 

19 • Long-term productivity affects the quality of life for future generations on the basis of 

20 environmental sustainability (i.e., long-term is the period after license termination for the 

21 proposed IIFP facility). 

22 Construction, operation, and decommissioning of the proposed IIFP facility would necessitate 

23 short-term commitments of resources. The short-term commitment of resources would include 

24 land, water and energy sources, and materials which could be recovered or recycled. Impacts 

25 would be minimized by mitigation measures and resource management. The short-term use of 

26 these resources would result in potential long-term socioeconomic benefits to the local area and 

27 the region, such as improvements to the local economy and infrastructure supported by worker 

28 income and tax revenues and the maintenance and enhancement of a skilled worker base. 

29 Workers, the public, and the environment would be exposed to slightly elevated concentrations 

30 of radioactive and hazardous materials over the short term from the operation of the proposed 

31 IIFP facility due to process emissions and the transport and disposal of hazardous and 

32 radioactive waste. 

33 Upon expiration of the license, IIFP would decommission the facility, recycle some equipment 

34 and restore the facility for another use. The use of the site and the buildings for other industrial 

35 purposes would constitute a long-term benefit to the community and would increase long-term 

36 productivity. Continued employment, expenditures, and tax revenues generated during 

37 preconstruction, construction, and operation of the proposed IIFP facility and from future site 

38 uses after the facility is decommissioned would directly benefit the local, regional, and State 

39 economies and would be considered a long-term benefit. 
 8-5 

1 8.4 References 

2 (IIFP, 2009) International Isotopes Fluorine Products, Inc. 2009. Fluorine Extraction Process & 

3 Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A, ER-IFP4 001. December 27, 2009. ADAMS Accession No. ML100120758. 

5 (NRC, 2003) U.S. Nuclear Regulatory Commission. 2003. Environmental Review Guidance for 

6 Licensing Actions Associated with NMSS Programs, NUREG-1748, Washington D.C., 2003. 

7 ADAMS Accession No. ML032450279.

 9-1 

1 9.0 LIST OF PREPARERS 

2 9.1 U.S. Nuclear Regulatory Commission Contributors 

3 Matt Bartlett; NMSS Project Manager 

4 BS, Physics, Bob Jones University, Greenville, SC, 1997 

5 MS, Physics, Clemson University, Clemson, SC, 2000 

6 PhD, Physics, Clemson University, Clemson, SC, 2004 

7 Years of Relevant Experience: 6 

8 

9 Greg Chapman P.E., C.H.P; Analyst, Accidents 

10 BEE, Georgia Tech 1987 

11 ME, University of Florida, 1993 

12 Graduate Certificate, University of Tennessee, 2010 

13 Years of Relevant Experience: 18 

14 

15 Diana Diaz-Toro; Chief, Environmental Review Branch-A; General Reviewer 

16 BS, Chemical Engineering, University of Puerto Rico, 2002 

17 MBA, American University, 2008 

18 Years of Relevant Experience: 9 

19 

20 Nathan Goodman; Reviewer, Ecological Resources 

21 BS, Biology, Muhlenberg College, 1998 

22 MS, Environmental Science, Johns Hopkins University, 2000 

23 Years of Relevant Experience: 12 

24 

25 Christopher Grossman; Reviewer, Waste Management 

26 BS, Civil Engineering, Purdue University, 1998 

27 MS, Environmental Engineering & Science, Clemson University, 2001 

28 Years of Relevant Experience: 9 

29 

30 Kellee L. Jamerson; Reviewer, Environmental Measurements and Monitoring Programs 

31 BS, Environmental Science, Tuskegee University, 2006 

32 Years of Relevant Experience: 3 

33 

34 Stephen Lemont, Ph.D.; Technical Reviewer, Statutory and Regulatory Requirements, 

35 Alternatives, Reasonably Foreseeable Actions, Land Use, Historic and Cultural Resources, 

36 Water Resources, Waste Management, and Geology, Minerals, and Soil 

37 BS, Chemistry, Brooklyn College of the City University of New York, 1971 

38 PhD, Physical Chemistry, Columbia University, 1976 

39 Years of Relevant Experience: 30 

40 

41 Asimios Malliakos, Ph.D.; EIS Project Manager; General EIS Reviewer 

42 BS, Physics, University of Thessaloniki, Greece, 1975 

43 MS, Nuclear Engineering, Polytechnic Institute of New York, 1977 

44 PhD, Nuclear Engineering with a Minor Degree in Probability and Statistics, University of 

45 Missouri-Columbia, 1980 

46 Years of Relevant Experience: 30 

47 
 9-2 

1 Christepher A. McKenney; Contributor and Technical Reviewer, Waste Management 

2 BS, Nuclear Engineering, Oregon State University, 1991 

3 Years of Relevant Experience: 20 

4 

5 Johari Moore; Reviewer, Public and Occupational Health, Traffic and Transportation 

6 BS, Physics, Florida A & M University, 2003 

7 MSE, Nuclear Engineering and Radiological Sciences, University of Michigan, 2005 

8 Years of Relevant Experience: 3 

9 

10 Ashley Riffle; Reviewer, Ecological Resources, Air Quality and Environmental Monitoring 

11 BS, Biology, Frostburg State University, 2009 

12 Years of Relevant Experience: 3 

13 

14 Jean Trefethen; Reviewer, Traffic and Transportation, Noise, and Public and 

15 Occupational Health 

16 BA, Biology, Carroll College, 1987 

17 Years of Relevant Experience: 2 

18 

19 9.2 Straughan Environmental and Tetra Tech Contributors 

20 Lawson Bailey; Contributing Author, Affected Environment 

21 BS, Biology, Virginia Polytechnic Institute & State University, 1979 

22 Years of Relevant Experience: 32 

23 

24 Greg M. Beachley, Ph.D.; Contributor, Air Quality 

25 BS, Chemistry and BS, Biology, James Madison University, 2001 

26 PhD, Analytical & Environmental Chemistry, University of Maryland, 2009 

27 Years of Relevant Experience: 6 

28 

29 Jacqueline K. Boltz; Technical Editor, Public Outreach Manager 

30 BA, French Language and Literature, Boston University, 1991 

31 MBA, General Business, Boston University, 1991 

32 Years of Relevant Experience: 19 

33 

34 Steven J. Connor; Analyst, Proposed Action and Alternatives and Cost-Benefit Analysis 

35 Summary; Technical Reviewer 

36 BS, Physics, Georgia Institute of Technology, 1973 

37 MS, Physics, Georgia Institute of Technology, 1974 

38 Years of Relevant Experience: 34 

39 

40 Charles Conrad; Analyst, Air Quality and Traffic 

41 BS, Chemical Engineering, University of Wisconsin – Madison, 2002 

42 Years of Relevant Experience: 5 

43 

44 Krista Dearing; Analyst, Geology, Minerals, Soils and Groundwater 

45 BS, Geology, University of Cincinnati, 1991 

46 MS, Geology, University of Cincinnati, 1993 

47 Years of Relevant Experience: 16 

48 
 9-3 

1 Amanda J. Deering; Contributor and Technical Reviewer 

2 BS, Environmental Studies, Towson University, 2010 

3 Years of Relevant Experience: 1 

4 

5 Eric T. Duce; Contributor and Technical Reviewer, Land Use and Ecology 

6 BS, Natural Resources Management, University of Maryland, 1998 

7 MS, Environmental Science and Policy, Johns Hopkins University, 2005 

8 Years of Relevant Experience: 11 

9 

10 Alverna R. (A.J.) Durham, Jr.; Analyst and Technical Reviewer, Air Quality 

11 BS, Industrial Technology, North Carolina Agricultural and Technical State University, 1999 

12 Years of Relevant Experience: 6 

13 

14 Kristin Fusco Rowe, P.E.; Analyst, Noise Abatement Specialist 

15 BS, Engineering Science, Loyola College, 2002 

16 Years of Relevant Experience: 9 

17 

18 Kristi Hagood; Analyst, Climatology, Meteorology, and Air Quality 

19 BS, Chemistry, Converse College, 1998 

20 MS, Astrophysical, Planetary and Atmospheric Sciences, University of Colorado, 2000 

21 Years of Relevant Experience: 9 

22 

23 Tim J. Harvey, PMP; Program Manager 

24 BS, Natural Resources, Cornell University, 1983 

25 Years of Relevant Experience: 25 

26 

27 Justin M. Haynes; Technical Reviewer 

28 BS, Integrated Science & Technology, Environmental Concentration, James Madison 

29 University, 2003 

30 Years of Relevant Experience: 7 

31 

32 Richard L. Heimbach, II, AICP; Project Manager 

33 BS, Environmental Resource Management, Pennsylvania State University, 1989 

34 Years of Relevant Experience: 20 

35 

36 Chimere M. Lesane-Matthews; Analyst, Land Use, Socioeconomics, Traffic and Transportation 

37 BS, Civil Engineering, Morgan State University, 2001 

38 Years of Relevant Experience: 10 

39 

40 Anne Lovell; Contributor, Air Quality 

41 BS, Chemical and Petroleum Refining Engineering, Colorado School of Mines, 1985 

42 Years of Relevant Experience: 25 

43 

44 Lisa Matis; Analyst, Waste Management 

45 MS, Mechanical Engineering, Stevens Institute of Technology, 1989 

46 BS, Chemical Engineering, Stanford University, 1984 

47 Years of Relevant Experience: 26 

48 
 9-4 

1 Sarah M. Michailof; Analyst, Historic and Cultural Resources 

2 BA, Anthropology and Biology, University of North Carolina, Chapel Hill, 1994 

3 MA, Historic Preservation, Goucher College, 2007 

4 Years of Relevant Experience: 16 

5 

6 Phil Moore; Technical Editor

7 BA, English, University of South Carolina, 1975 

8 MS, Wildlife Biology (Fisheries Emphasis), Clemson University, 1983 

9 Post Graduate Study, Zoology, Clemson University, 1977 1979 

10 Years of Relevant Experience: 25 

11 

12 Ellen K. Mussman; Analyst, Land Use, Ecology, Mitigation and Monitoring 

13 BS, Conservation of Soil, Water, and the Environment, University of Maryland, 

14 College Park, 2002 

15 MS, Forest Resources, University of Washington, 2006 

16 Years of Relevant Experience: 6 

17 

18 Karen Patterson; Task Manager and Senior Reviewer 

19 BA, Biology, Randolph-Macon Woman’s College, 1973 

20 MA, Biology, Wake Forest University, 1977 

21 MLIS, University of South Carolina, 1999 

22 Years of Relevant Experience: 37 

23 

24 Nikki J. Radke; Contributor, Graphics 

25 BS, Biology and Wildlife Management, University of Wisconsin-Stevens Point, 1999 

26 MS, Wildlife Management, Texas Tech University, 2005 

27 Years of Relevant Experience: 7 

28 

29 Noreen Raza; Contributor, Environmental Justice 

30 BS, English, Towson University, 2003 

31 Years of Relevant Experience: 5 

32 

33 Jay Rose; Analyst, Cumulative Impact Assessment, Health and Safety, Accidents, and 

34 Executive Summary 

35 BS, Ocean Engineering, U.S. Naval Academy, 1983 

36 JD, Catholic University, Columbus School of Law, 1996 

37 Years of Relevant Experience: 27 

38 

39 Kenneth R. Scarlatelli; Technical Reviewer, Ecology 

40 BS, Wildlife Biology, University of Massachusetts at Amherst, 1983 

41 MA, Environmental Studies, Environmental Management Concentration, 1994 

42 Years of Relevant Experience: 27 

43 

44 Alan Toblin; Analyst, Accidents 

45 BE, Cooper Union, 1968 

46 MS, University of Maryland, 1970 

47 Years of Relevant Experience: 39 
 10-1 

1 10.0 GLOSSARY 

2 Abatement: Diminution in amount, degree, or intensity. 

3 Activity: A measure of the rate at which a material emits nuclear radiation, usually given in 

4 terms of the number of nuclear disintegrations occurring in a given length of time. The common 

5 unit of activity is the curie (Ci), which amounts to 37 billion disintegrations per second. The 

6 international unit of activity is the becquerel (Bq) and is equal to one disintegration per second. 

7 Air pollutant: Any substance in air which could, if present in high enough concentration, harm 

8 humans, animals, vegetation, or material. Pollutants may include almost any natural or artificial 

9 substance capable of being airborne. 

10 Air quality: A measure of the concentrations of pollutants, measured individually, in the air. 

11 These concentrations are often compared to regulatory standards. 

12 Air quality standards: The concentration of a pollutant in air prescribed by regulations that 

13 may not be exceeded during a specified time in a defined area. Air quality standards are used 

14 to provide a measure of the health-related and visual characteristics of the air. 

15 ALARA: Acronym for "as low as (is) reasonably achievable." An approach to keep radiation 

16 exposures (both to the workforce and the public) and releases of radioactive material to the 

17 environment at levels that are as low as social, technical, economic, practical, and public policy 

18 considerations allow. ALARA is not a dose limit; it is a practice in which the objective is the 

19 attainment of dose levels as far below applicable limits as possible. 

20 Alluvium: Clay, silt, sand, and/or gravel deposits found in a stream channel or in low parts of a 

21 stream valley that is subject to flooding. Ancient alluvium deposits frequently occur above the 

22 elevation of present-day streams. 

23 Alternative site: A ranked site, other than the proposed site, that was evaluated in the fine24 screening step. 

25 Ambient air: The surrounding atmosphere, usually the outside air, as it exists around people, 

26 plants, and structures. It is not the air in immediate proximity to emission sources. 

27 Ambient Air Quality Standards: Standards established on a State or Federal level, that define 

28 the limits for airborne concentrations of designated “criteria” pollutants (nitrogen dioxide, sulfur 

29 dioxide, carbon monoxide, total suspended particulates, ozone, and lead), to protect public 

30 health with an adequate margin of safety (primary standards) and to protect public welfare, 

31 including plant and animal life, visibility, and materials (secondary standards). 

32 Ambient Noise Level: A sound level that represents the background noise from community or 

33 environmental sound sources. 

34 Anhydrous: Without water (H2O). 

35 Anthropogenic: Caused or influenced by humans. 

36 Aqueous: Related to water. 
 10-2 

1 Aquifer: Geologic unit sufficiently permeable to conduct groundwater. 

2 Area of potential effect (APE): The geographic area or areas within which an undertaking 

3 may directly or indirectly cause alterations in the character or use of historic properties, if any 

4 such properties exist. The area of potential effects is influenced by the scale and nature of an 

5 undertaking and may be different for different kinds of effects caused by the undertaking. 

6 Assay: The qualitative or quantitative analysis of a substance; often used to determine the 

7 proportion of isotopes in radioactive materials. 

8 Asymptomatic: Without symptoms. 

9 Atmosphere: The layer of air surrounding the earth. 

10 Atomic Energy Act of 1954 as amended: A Federal law that created the Atomic Energy 

11 Commission, which later split into the Nuclear Regulatory Commission and the Energy and 

12 Research and Development Administration (ERDA). ERDA became part of the Department of 

13 Energy in 1977. This act encouraged development and the use of nuclear energy for the 

14 general welfare and the security of the United States. This act authorized the Nuclear 

15 Regulatory Commission to regulate and license fuel fabrication facilities that seek to receive, 

16 possess, use, or transfer special nuclear material. 

17 Attainment area: A region that meets the U.S. EPA National Ambient Air Quality Standards 

18 (NAAQS) for a criteria pollutant under the Clean Air Act. 

19 Autoclave: A strong, pressurized, steam-heated vessel, as for laboratory experiments, 

20 sterilization, or cooking. 

21 Background radiation: Radiation from: (1) naturally occurring radioactive materials, as they 

22 exist in nature prior to removal, transport, or enhancement or processing by man; (2) cosmic 

23 and natural terrestrial radiation; (3) global fallout as it exists in the environment; (4) consumer 

24 products containing nominal amounts of radioactive material or emitting nominal levels of 

25 radiation; and (5) radon and its progeny in concentrations or levels existing in buildings or the 

26 environment that have not been elevated as a result of current or past human activities. 

27 Baghouse: A large chamber or room for holding bag filters used to filter gas streams. 

28 Berms: A level space, shelf, or raised barrier separating two areas. 

29 Baseline: A quantitative expression of conditions, costs, schedule, or technical progress to 

30 serve as a base or standard for measurement during the performance of an effort; the 

31 established plan against which the status of resources and the progress of a project can be 

32 measured. 

33 Basin: A topographic or structurally low area or the area drained by a stream system. 

34 Basalt: A fine-grained dark igneous (volcanic) rock that is low in silica content and has 

35 congealed from a molten (magma) state. 
 10-3 

1 Best Management Practices (BMP): Structural, nonstructural, and managerial techniques 

2 recognized to be the most effective and practical means to reduce surface water and 

3 groundwater contamination while still allowing the productive use of resources. 

4 Beta particle: A charged particle emitted from a nucleus during radioactive decay, with a mass 

5 equal to 1/1837 that of a proton. A negatively charged beta particle is identical to an electron. 

6 A positively charged beta particle is called a positron. Large amounts of beta radiation may 

7 cause skin burns, and beta emitters are harmful if they enter the body. Beta particles may be 

8 stopped by thin sheets of metal or plastic. 

9 Bioassay analyses: A method for quantitatively determining the concentration of a substance 

10 by its effect on the growth of a suitable animal, plant, or microorganism under controlled 

11 conditions. 

12 Biomass: The dry mass of living matter, expressed in terms of a given area or volume. 

13 Bollard: A strong wooden or metal post mounted on a wharf, quay, etc. to protect the 

14 stationary structure from, and stop, a moving craft or vehicle. 

15 Boom: As used in this EIS, a temporary floating barrier launched on water to contain material 

16 such as an oil spill. 

17 Boron: Semi-metallic chemical element, with atomic number 5, which has the chemical 

18 symbol B. 

19 Bounding: That which represents the maximum reasonably foreseeable event or impact. All 

20 other reasonably foreseeable events or impacts would have fewer and/or less severe 

21 environmental consequences. 

22 Buffer area: A designated area of land that is designed to permanently remain vegetated in an 

23 undisturbed and natural condition in order to protect an adjacent aquatic or wetland site from 

24 upland impacts and to provide habitat for wildlife. 

25 Byproduct: A product from a manufacturing process that is not considered the principal 

26 material. 

27 Candidate species: A species of plants or animals considered as a candidate for possible 

28 listing as endangered or threatened by a government agency. 

29 Carbonaceous: Consisting of, containing, relating to, or yielding the element carbon (carbon is 

30 element with atomic number 6, and has the chemical symbol C). 

31 Carbon monoxide: An odorless, colorless, poisonous gas produced by incomplete burning of 

32 carbon in fuels. Exposure to carbon monoxide reduces the delivery of oxygen to the body's 

33 organs and tissues. Elevated levels can cause impairment of visual perception, manual 

34 dexterity, learning ability, and performance of complex tasks. 

35 Caliche: Calcium carbonate (chemical symbol CaCO3) deposited in the soils of arid or semiarid 

36 regions. 
 10-4 

1 Clarifier: A piece of equipment that removes suspended impurities or solid matter by settling, 

2 heating gently, or filtering. 

3 Clean Air Act: A Federal law that requires the EPA to set and enforce air pollutant emissions 

4 standards for stationary sources and motor vehicles. 

5 Climatology: The science devoted to the study, over time, of the conditions of the natural 

6 environment (rainfall, daylight, temperature, humidity, air movement) prevailing in specific 

7 regions of the earth. 

8 Code of Federal Regulations (CFR): All Federal regulations in force are published in codified 

9 form in the Code of Federal Regulations. 

10 Coke: The solid residue of impure carbon obtained from bituminous coal and other 

11 carbonaceous materials after removal of volatile material by destructive distillation. 

12 Cold traps: A device that condenses all vapors except the permanent gases into a liquid or 

13 solid. 

14 Committed dose equivalent: The predicted dose equivalent to a tissue or organ over a 50-

15 year period after an intake of a radionuclide into the body. It does not include dose 

16 contributions from radiation sources external to the body. Committed dose equivalent is 

17 expressed in units of rem (or sievert) (1 rem = 0.01 sievert). 

18 Committed effective dose equivalent: The sum of the committed dose equivalents to various 

19 organs or tissues in the body from radioactive material taken into the body, each multiplied by 

20 the tissue-specific weighting factor. Committed effective dose equivalent is expressed in units 

21 of rem (or sievert). 

22 Community: A group of people (or animals) within a defined area that could be exposed to 

23 health risks from industrial pollutants or disturbed by noise, dust, and traffic associated with 

24 development of an industrial facility but that could also benefit from improved employment 

25 opportunities, higher land values, and infrastructure improvements associated with the project. 

26 Concentration: The amount of a substance contained in a unit quantity (mass or volume) of a 

27 sample. 

28 Conservative: When used with predictions or estimates, leaning on the side of pessimism. A 

29 conservative estimate is one in which the uncertain inputs are used in the way that provides a 

30 reasonable upper limit of the estimate of an impact. 

31 Containment: Retention of a material or substance within prescribed boundaries. 

32 Contamination: The presence of an unwanted chemical or radiological constituent in or on a 

33 material, person, property, or structure. 

34 Cooling water: Water circulated through a nuclear reactor or processing plant to remove heat. 

35 Cost-benefit analysis: A formal quantitative procedure comparing costs and benefits of a 

36 proposed project or act under a set of pre-established rules. 
 10-5 

1 Council on Environmental Quality: The President’s Council on Environmental Quality (CEQ) 

2 was established by the enactment of National Environmental Policy Act (NEPA). The CEQ is 

3 responsible for developing regulations to be followed by all Federal agencies in developing and 

4 implementing their own specific NEPA implementation policies and procedures. 

5 Criteria pollutants: Six pollutants (ozone, carbon monoxide, total suspended particulates, 

6 sulfur dioxide, lead, and nitrogen oxide) known to be hazardous to human health and for which 

7 the EPA sets National Ambient Air Quality Standards under the Clean Air Act. 

8 Critical habitat: The specific areas within the geographical area occupied by a species at the 

9 time it is listed as threatened or endangered on which are found those physical or biological 

10 features that are essential to the conservation of the species and that may require special 

11 management considerations or protection. It also includes specific areas outside the 

12 geographical area occupied by the species at the time it is listed if these areas are determined 

13 to be essential for the conservation of the species. 

14 Cryogenic: Of, or relating to low temperatures; or requiring low temperatures for storage. 

15 Cultural resources: Archaeological sites, architectural features, traditional use areas, and 

16 Native American sacred sites or special use areas. 

17 Cumulative impacts: Cumulative impacts are those impacts on the environment that result 

18 from the incremental impact of the action when added to other past, present, and reasonably 

19 foreseeable future actions regardless of what agency (Federal or non-Federal) or person 

20 undertakes such other actions. Cumulative impacts can result from individually minor but 

21 collectively significant actions taking place over a period of time. 

Curie: A unit of radioactivity equal to 37 billion (3.7 x 1010 22 ) disintegrations per second. 

23 Daughter products: The remaining nuclide left over from radioactive decay. 

24 Decibel (dB): A standard unit for measuring sound-pressure levels based on a reference 

25 sound pressure of 0.0002 dyne per square centimeter. This is the smallest sound a human can 

26 hear. In general, a sound doubles in loudness with every increase of slightly more than 3 

27 decibels. 

28 Deciduous: Falling off at maturity or tending to fall off and is typically used in reference to trees 

29 or shrubs that lose their leaves seasonally. 

30 Decommissioning: The removal of a facility from active service. 

31 Decontamination: The reduction or removal of an unwanted chemical or radiological 

32 constituent from a structure, area, object, or person. Decontamination of radiological 

33 contamination may be accomplished by (1) treating the surface to remove or decrease the 

34 contamination, (2) letting the material stand so that the radioactivity is decreased as a result of 

35 natural radioactive decay, or (3) covering the contamination to shield or attenuate the radiation 

36 emitted. 

37 Deconversion: As used in this EIS, the process by which uranium hexafluoride (UF6) is 

38 chemically converted to uranium oxide (UO2) producing anhydrous hydrogen fluoride (HF) and 

39 other marketable fluoride byproducts. 
 10-6 

1 Degradation: The process by which organic substances are broken down by living organisms. 

2 Delaware Basin: An area in southeastern New Mexico and the adjacent parts of Texas where 

3 the Permian sea deposited a large thickness of evaporites some 220 to 280 million years ago. 

4 It is partially surrounded by the Capitan Reef. 

5 Depleted uranium: Uranium having a percentage of uranium-235 smaller than the 0.7 percent 

6 found in natural uranium. In the context of this EIS, it is the residue or tails from the uranium 

7 enrichment process. 

8 Depleted uranium hexafluoride (DUF6): A compound of uranium and fluorine from which 

9 most of the uranium-235 isotope has been removed. 

10 Diffusion: Movement of atoms, ions, or molecules of one substance into or through another as 

11 a result of thermal or concentration gradients. 

12 Dike: A barrier (typically, an embankment for controlling or holding back water; or, in geology, a 

13 type of sheet intrusion that cuts discordantly across the geologic body). 

14 Dispersion: The occurrence in which particles are dispersed in air, water, soil, or other another 

15 medium. 

16 Dose equivalent: The product of absorbed dose in rad (or gray) in tissue and a quality factor. 

17 Dose equivalent is expressed in units of rem (or sievert). 

18 Dose rate: The radiation dose delivered per unit time (e.g., rem per hour). 

19 Ecology: The science dealing with the relationship of all living things with each other and with 

20 the environment. 

21 Ecoregion: A classification of land based on similar climate, vegetation, and topography. 

22 Effective dose equivalent: The sum of the products of the dose equivalent received by 

23 specified organs or tissues of the body and a tissue-specific weighting factor. The effective 

24 dose equivalent is expressed in units of rem (or sievert). 

25 Effluent: A gas or fluid discharged into the environment, treated or untreated. Most frequently, 

26 the term applies to wastes discharged to surface waters. 

27 EIS: Environmental impact statement; a document required by the National Environmental 

28 Policy Act for proposed major Federal actions involving potentially significant environmental 

29 impacts. 

30 Emissions: Substances that are discharged into the air. 

31 Endangered species: Plants and animals that are threatened with extinction, serious 

32 depletion, or destruction of critical habitat. Requirements for declaring a species endangered 

33 are contained in the Endangered Species Act. 

34 Endangered Species Act of 1973: An act requiring Federal agencies, with the consultation 

35 and assistance of the Secretaries of the Interior and Commerce, to ensure that their actions will 
 10-7 

1 not likely jeopardize the continued existence of any endangered or threatened species or 

2 adversely affect the habitat of such species. 

Enrichment (process): Increasing the concentration of the uranium isotope U235 3 to more than 

4 that which exists in natural uranium ore, for use in atomic energy. 

5 Environment: The sum of all external conditions and influences affecting the life development 

6 and, ultimately, the survival of an organism. 

7 Environmental justice: The fair treatment of people of all races, cultures, incomes, and 

8 educational levels with respect to the development, implementation, and enforcement of 

9 environmental laws, regulations, and policies. Fair treatment implies that no population of 

10 people should be forced to shoulder a disproportionate share of the negative environmental 

11 impacts of pollution or environmental hazards due to a lack of political or economic strength. 

12 Environmental monitoring: The act of measuring, either continuously or periodically, some 

13 quantity of interest, such as radioactive material in the air. 

14 Ephemeral stream: A stream channel that carries water only during part of the year, 

15 immediately after periods of rainfall or snowmelt. 

16 Equilibrium: A state of rest in a chemical or mechanical system. 

17 ER: Environmental Report required as part of an environmental assessment, which identifies, 

18 describes and evaluates the likely significant effects on the environment of implementing a plan 

19 or program. 

20 Erosion: Removal and transport of materials by wind, ice, or water on the earth’s surface. 

21 Escarpment: A long, nearly continuous cliff or relatively steep slope facing in one general 

22 direction, breaking the continuity of the land by separating two level or gently sloping surfaces, 

23 and produced by erosion or faulting. 

24 Exposure limit: The level of exposure to a hazardous chemical (set by law or a standard) at 

25 which or below which adverse human health effects are not expected to occur. 

26 Exposure pathways: A route or sequence of processes by which a radioactive or hazardous 

27 material may move through the environment to humans or other organisms. Each exposure 

28 pathway includes a source or release from a source, an exposure point, and an exposure route. 

29 Fault: A fracture or a zone of fractures along which there has been displacement parallel to the 

30 fracture. 

31 Fauna: The animal life of any particular region or time. 

32 Floodplain: Low-lying areas adjacent to rivers and streams that are subject to natural 

33 inundations typically associated with precipitation. 

34 Flora: The plant life occurring in a particular region, generally the naturally occurring or 

35 indigenous plant life. 

36 Fluorocarbon: A halocarbon in which some hydrogen atoms have been replaced with fluorine. 
 10-8 

1 Fluorine: The chemical element with atomic number 9, represented by the chemical symbol F. 

2 Formation: A mapable geologic body of rock identified by lithic characteristics and stratigraphic 

3 position. Formations may be combined into groups or subdivided into members. 

4 Fuel cycle: The series of steps involved in supplying fuel for nuclear power reactors. It can 

5 include mining, milling, isotopic enrichment, fabrication of fuel elements, use in a reactor, 

6 chemical reprocessing to recover the fissionable material remaining in the spent fuel, 

7 re-enrichment of the fuel material, re-fabrication into new fuel elements, and waste disposal. 

8 Fugitive dust: Any solid particulate matter (PM) that becomes airborne, other than that emitted 

9 from an exhaust stack, directly or indirectly as a result of the activities of man. Fugitive dust 

10 may include emission from haul roads, wind erosion of exposed soil surfaces, and other 

11 activities in which soil is either removed or distorted. 

12 Gamma: Short-wavelength electromagnetic radiation (high-energy photons) emitted In the 

13 radioactive decay of certain nuclides. Gammas are the same as gamma rays or gamma waves. 

14 Gaussian plume: The distribution of material (a plume) in the atmosphere resulting from the 

15 release of pollutants from a stack or other source. The distribution of concentrations about the 

16 centerline of the plume, which is assumed to decrease as a function of its distance from the 

17 source and centerline (Gaussian distribution), depends on the mean wind speed and 

18 atmospheric stability. 

19 Geology: The science that deals with the earth; the materials, processes, environments, and 

20 history of the planet, especially the lithosphere, including the rocks, their formation, and 

21 structure. 

22 Geology and Soils: Those Earth resources that may be described in terms of landforms, 

23 geology, and soil conditions. 

24 Greenhouse gas: A gas in an atmosphere that absorbs and emits radiation within the thermal 

25 infrared range. 

26 Gross beta: The total rate of emission of beta particles from a sample, without regard to 

27 energy distributions or source nuclides. 

28 Groundwater: All subsurface water, especially that contained in the saturated zone below the 

29 water table. 

30 Habitat: The part of the physical environment in which a plant or animal lives. 

31 Hazardous chemical: Under 29 CFR 1910, Subpart Z, "hazardous chemicals" are defined as 

32 "any chemical, which is a physical hazard or a health hazard." Physical hazards include 

33 combustible liquids, compressed gases, explosives, flammables, organic peroxides, oxidizers, 

34 pyrophorics, and reactives. A chemical is a health hazard when there is good evidence that 

35 acute or chronic health effects occur in exposed individuals. Hazardous chemicals include 

36 carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, 

37 hepatotoxins, nephrotoxins, agents that act on the hematopoietic system, and agents that 

38 damage the lungs, skin, eyes or mucous membranes. 
 10-9 

1 Hazardous waste: According to the Resource Conservation and Recovery Act, a waste that, 

2 because of its characteristics, may (1) cause or significantly contribute to an increase in 

3 mortality or an increase in serious irreversible illness, or (2) pose a substantial hazard to human 

4 health or the environment when improperly treated, stored, transported, disposed of, or 

5 otherwise managed. Hazardous wastes possess at least one of the following characteristics: 

6 ignitability, corrosivity, reactivity, or toxicity. Hazardous waste is nonradioactive. 

7 Historic Resources: The sites, districts, structures, and objects associated with historic 

8 events, persons, or social or historic movements. 

9 Historic and Cultural Resources: Cultural resources include any prehistoric or historic district, 

10 site, building, structure, or object resulting from, or modified by, human activity. Historic 

11 properties are cultural resources listed in, or eligible for listing in, the National Register of 

12 Historic Places. 

13 Homogenous: Describing a substance or population with uniform composition. 

14 Hopper: A (usually funnel-shaped) container in which materials, such as chemicals, are stored 

15 in readiness for dispensing. 

16 Hydraulic conductivity: A quantity that describes the rate at which water flows through an 

17 aquifer. It has units of length/time and is equal to the hydraulic transmissivity divided by the 

18 thickness of the aquifer. 

19 Hydrofluorocarbons: An organic chemical containing hydrogen, fluorine, and carbon; emitted 

20 as a byproduct of industrial manufacturing. 

21 Hydroperiod: The number of days per year that an area of land is inundated with water; or the 

22 length of time that there is standing water at a location. 

23 Indirect jobs: Jobs generated or lost in related industries within a regional economic area as a 

24 result of a change in direct employment. 

25 Ingestion: To take in by mouth. Material that is ingested enters the digestive system. 

26 Inhalation: To take in by breathing. Material that is inhaled enters the lungs. 

27 Integrated Safety Analysis (ISA): A formalized and documented process that identifies 

28 potential accident sequences in a plant's operations, designates items relied on for safety to 

29 either prevent such accidents or mitigate their consequences to an acceptable level, and 

30 describes management measures to provide reasonable assurance of the availability and 

31 reliability of items relied on for safety. 

32 Intermittent: As used in this EIS, a drainage feature that contains water for only part of the 

33 year, typically during wet seasons. An intermittent stream often lacks the biological and 

34 hydrological characteristics commonly associated with the conveyance of water. 

35 Ionizing radiation: Radiation capable of displacing electrons from atoms or molecules to 

36 produce ions. 
 10-10 

1 Isotope: An atom of a chemical element with a specific atomic number and atomic weight. 

2 Isotopes of the same element have the same number of protons but different numbers of 

3 neutrons. Isotopes are identified by the name of the element and the total number of protons 

4 and neutrons in the nucleus. For example, uranium-235 is an isotope of uranium with 92 

5 protons and 143 neutrons and uranium-238 is an isotope of uranium with 92 protons and 146 

6 neutrons. 

7 Kilovolt (kV): A unit of electrical potential equal to a thousand volts. 

8 Kilovolt-ampere (kVA): A unit of electrical power equal to 1000 volt-amperes. 

9 Land use: The way land is developed and used in terms of the kinds of anthropogenic 

10 activities that occur (e.g., agriculture, residential areas, industrial areas). 

11 Latent cancer fatalities (LCFs): Deaths resulting from cancer that has become active after a 

12 latent period following radiation exposure. For radiation exposure, latent cancer fatalities can be 

calculated from collective dose using the risk conversion factor of 6x10-4 13 LCFs per person rem. 

14 Lithic: Made of stone. 

15 Load factor: The ratio of the average electric load to the peak load over a period of time. 

16 Loam: A rich, friable soil containing a relatively equal mixture of sand and silt, clay, and 

17 humus. 

18 Low-level mixed waste: Low-level radioactive waste that also contains hazardous chemical 

19 components regulated under the Resource Conservation and Recovery Act. 

20 Low-level radioactive waste: Wastes containing source, special nuclear, or by-product 

21 material are acceptable for disposal in a land disposal facility. For the purposes of this 

22 definition, low-level waste has the same meaning as in the Low-Level Radioactive Waste Policy 

23 Act, that is, radioactive waste not classified as high-level radioactive waste, transuranic waste, 

24 spent nuclear fuel, or by-product material as defined in section 11e.(2) of the Atomic Energy Act 

25 (uranium or thorium tailings and waste). 

26 Low-income population: A population where 25 percent or more of the population is identified 

27 as living in poverty. 

28 Magnitude (earthquake): A measure of the total energy released by an earthquake. It is 

29 commonly measured in numerical units on the Richter scale. Each unit is different from an 

30 adjacent unit by a factor of 30. 

31 Maim: To injure, disable or disfigure, usually by depriving of the use of a limb or other part of 

32 the body. 

33 Maximally exposed individual (MEI): A hypothetical person who—because of proximity, 

34 activities, or living habits—could receive the highest possible dose of radiation or of a hazardous 

35 chemical from a given event or process. 

36 Meteorological tower: An individual data acquisition point for weather and air related 

37 information (e.g., wind speed, wind direction, precipitation, opacity, etc.) 
 10-11 

1 Meteorology: The science dealing with the atmosphere and its phenomena, especially as 

2 relating to weather. 

3 Migration: The natural travel of a material through the air, soil, or groundwater. 

4 Millirem (mrem): One thousandth of a rem (0.001 rem). 

5 Mitigation: An action or actions implemented to lessen or alleviate impacts to a resource from 

6 a proposed action or activity. The purpose of mitigative actions is to avoid, minimize, rectify, or 

7 compensate for any adverse environmental impact. 

8 Mixed waste: Waste that contains both "hazardous waste" and "radioactive waste" as defined 

9 in this glossary. 

10 Modified Mercalli Intensity: A measurement of earthquake intensity based on the effects to 

11 people and structures. Ranges from I (low) to XII (total destruction), as opposed to the Richter 

12 scale, which measures the energy of the earthquake. Mercalli scale is often used to classify 

13 earthquakes that were not recorded on modern seismographs. 

14 National Ambient Air Quality Standards (NAAQS): Air quality standards established by the 

15 Clean Air Act, as amended. The primary NAAQS are intended to protect the public health with 

16 an adequate margin of safety, and the secondary NAAQS are intended to protect the public 

17 welfare from any known or anticipated adverse effects of a pollutant. 

18 National Emission Standards for Hazardous Air Pollutants (NESHAP): Emission standards 

19 for the control of releases of specified hazardous air pollutants, including radionuclides. These 

20 were implemented in the Clean Air Act Amendments of 1977. 

21 National Environmental Policy Act (NEPA) of 1969: A Federal law constituting the basic 

22 national charter for protection of the environment. The act calls for the preparation of an 

23 environmental impact statement (EIS) for every major Federal action that may significantly 

24 affect the quality of the human or natural environment. The main purpose is to ensure that 

25 environmental information is provided to decision makers so that their actions are based on an 

26 understanding of the potential environmental and socioeconomic consequences of a proposed 

27 action and the reasonable alternatives. 

28 National Historic Preservation Act (NHPA): A Federal law providing that property resources 

29 with significant national historic value be placed on the National Register of Historic Places. It 

30 does not require permits; rather, it mandates consultation with the proper agencies whenever it 

31 is determined that a proposed action might impact a historic property. 

32 National Pollutant Discharge Elimination System (NPDES): Federal permitting system 

33 mandated by the Clean Water Act required for any discharges to waters of the United States. 

34 National Register of Historic Places: A list maintained by the National Park Service of 

35 architectural, historic, archaeological, and cultural sites of local, state, or national importance. 

36 Native vegetation: Plants that have evolved in a particular region and environment. 

37 Nocturnal: Of, relating to, or occurring in the night. 
 10-12 

1 Nonattainment areas: An area that has been designated by the EPA, or the appropriate State 

2 air quality agency, as exceeding one or more national or State Ambient Air Quality Standards. 

3 Nonferrous: Not composed of or containing iron. 

4 NOx : Oxides of nitrogen, primarily nitrogen oxide and nitrogen dioxide. These are produced 

5 primarily by combustion of fossil fuels, and can constitute an air pollution problem. 

6 Offgas treatment: An array of technologies to discharge, collect (filter), or destroy (catalyze, 

7 react, or combust) the vapors removed from soils or other media. 

8 Order of magnitude: A multiple of ten. When a measurement is made with a result such as 

3 x 107 9 , the exponent of 10 is the order of magnitude of that measurement. To say that this 

result is known to within an order of magnitude is to say that the true value lies between 3 x 106 10 

and 3 x 108 11 . 

12 Organic compounds: Of or designating carbon compounds. (Some simple compounds of 

13 carbon, such as carbon dioxide, are frequently classified as inorganic compounds.) 

14 Oxide: A compound consisting of an element combined with oxygen. 

15 Ozone: A molecule of oxygen in which three oxygen atoms are chemically attached to each 

16 other. 

17 Package: In the regulations governing the transportation of radioactive materials, the 

18 packaging together with its radioactive contents as presented for transport. 

19 Packaging: A shipping container without its contents. 

20 Particulate matter: Materials such as dust, dirt, soot, smoke, and liquid droplets that are 

21 emitted into the air by sources such as factories, power plants, automobiles, construction 

22 activity, fires, and naturally by wind. 

23 Peak ground acceleration: The maximum acceleration experienced by the particle on the 

24 ground during the course of the earthquake motion. 

25 Permeability: The capability of a soil or rock to transmit a fluid. 

26 Perennial: A drainage feature that contains water year-round during a year of normal rainfall. 

27 A perennial stream exhibits the typical biological, hydrological, and physical characteristics 

28 commonly associated with the continuous conveyance of water. 

29 Personnel monitoring: The use of portable survey meters to determine the amount of 

30 radioactive contamination on individuals; or, the use of dosimetry to determine an individual's 

31 occupational radiation dose. 

32 Person-rem: A measure of the radiation dose to a given population; the sum of the individual 

33 radiation doses received by that population. 

34 pH: A measure of the hydrogen ion concentration in aqueous solution. Pure water has a pH of 

35 7, acidic solutions have a pH less than 7, and alkaline solutions have a pH greater than 7. 
 10-13 

1 Photosynthesis: The process in green plants and certain other organisms by which 

2 carbohydrates are synthesized from carbon dioxide and water using light as an energy source. 

3 Physiographic: Geographic regions based on geologic setting. 

4 Playa lake: A temporary lake, or its dry often salty bed, in a desert basin. 

5 Plume: The elongated pattern of contaminated air or water originating at a point source, such 

6 as a smokestack or a hazardous waste disposal site. 

7 PM10 : Particulate matter with a 10-micron (mircrometer, μm) or less aerodynamic diameter. 

8 PM10 includes PM2.5. 

9 PM2.5: Particulate matter with aerodynamic diameter of 2.5 micron or less. Since it is very 

10 small, PM2.5 is important because it can be inhaled deep into the lungs. 

11 Point source: A source of effluents that is readily identifiable and can be treated as if it were a 

12 point. This includes stacks, pipes, conduits, and tanks. A point source can be either a 

13 continuous source or a source that emits effluents only intermittently. 

14 Pollutant: Any material entering the environment that has undesired effects. 

15 Pollution: The addition of an undesirable agent to the environment in excess of the rate at 

16 which natural processes can degrade, assimilate, or disperse it. 

17 Population dose: The sum of the radiation doses received by the individual members of a 

18 population. 

19 Porosity: Percentage of void space in a material. 

20 Potable water: Water that is safe for human consumption. 

21 Potash: A potassium compound often used in agriculture and industry. 

22 Prehistoric: Predating written history, in North America, also predating contact with 

23 Europeans. 

24 Production well: A well used to retrieve water, petroleum, or gas from underground. 

25 Purge gas: Inert gases used in chemical processes to flush a system of other gases. 

26 Quaternary: Noting or pertaining to the present period of Earth’s history, forming the latter part 

27 of the Cenozoic era, originating about 2 million years ago and including the Recent and 

28 Pleistocene epochs. 

29 Radiation: Ionizing radiation; e.g., alpha particles, beta particles, gamma rays, X-rays, 

30 neutrons, protons, and other particles capable of producing ion pairs in matter. As used in this 

31 document, radiation does not include nonionizing radiation. 

32 Radiation standards: Exposure standards, permissible concentrations, rules for safe handling, 

33 regulations for transportation, regulations for industrial control of radiation, and control of 

34 radioactive material by legislative means. 
 10-14 

1 Radioactive waste: Materials from nuclear operations that are radioactive or are contaminated 

2 with radioactive materials and for which there is no practical use or for which recovery is 

3 impractical. 

4 Radioactivity: The property or characteristic of radioactive material to undergo spontaneous 

5 transformations (“disintegrations” or “decay”) with the emission of energy in the form of 

6 radiation. It means the rate of spontaneous transformations of a radionuclide. The unit of 

radioactivity is the curie (or becquerel). (1 curie = 3.7 x 1010 7 becquerel). 

8 Radionuclide: A nuclide that emits radiation by spontaneous transformation. 

9 Radon: A colorless, radioactive, inert gaseous element formed by the radioactive decay of 

10 radium. 

11 Reactant: A substance participating in a chemical reaction, especially a directly reacting 

12 substance present at the initiation of the reaction. 

13 Recharge: The downward vertical flow of groundwater to an aquifer. Recharge may be from 

14 seepage through the unsaturated zone (for unconfined aquifers) or downward flow from 

15 overlying layers (for confined aquifers). 

16 Region of influence (ROI): The physical area that bounds the environmental, sociological, 

17 economic, or cultural features of interest for the purpose of impact analysis. A site-specific 

18 geographic area that includes the counties where approximately 90 percent of the site’s current 

19 employees reside. 

20 Rem: A common (or special) unit of dose equivalent, effective dose equivalent, or committed 

21 dose equivalent. 

22 Resource Conservation and Recovery Act (RCRA): This Act was designed to provide 

23 “cradle to grave” control of hazardous chemical wastes. 

24 Restricted area: Any area to which access is controlled for the protection of individuals from 

25 exposure to radiation and radioactive materials. 

26 Riparian: Associated with stream banks or margins. 

27 Risk: The likelihood of suffering a detrimental effect as a result of exposure to a hazard. In 

28 accident analysis, the probability weighted consequence of an accident, defined as the accident 

29 frequency per year multiplied by the consequence. 

30 Risk assessment (chemical or radiological): The qualitative and quantitative evaluation 

31 performed in an effort to define the risk posed to human health and/or the environment by the 

32 presence or potential presence and/or use of specific chemical or radiological materials. 

33 Rotary calciner: An industrial processing kiln or oven and a drum using indirect heating and 

34 mixing. 

35 Runoff: The portion of rainfall that is not absorbed by soil, evaporated, or transpired by plants, 

36 but finds its way into streams directly or as overland surface flows. 
 10-15 

1 Sanitary/industrial waste: Nonhazardous, nonradioactive liquid and solid waste generated by 

2 normal housekeeping activities. 

3 Scrubber: An apparatus for purifying a gas. 

4 Sediment: Eroded soil particles that are deposited downhill or downstream by surface runoff. 

5 Seismic: Pertaining to any earth vibration, especially an earthquake. 

6 Seismicity: All of the earthquakes that may occur in a region, regardless of magnitude. 

7 Semi-conductor: Any of various solid crystalline substances having electrical conductivity 

8 greater than insulators but less than good conductors. 

9 Shielding: Any material or obstruction that absorbs radiation and thus tends to protect 

10 personnel or materials from the effects of ionizing radiation. 

11 Sievert (Sv): A unit of radiation dose used to express a quantity called equivalent dose. This 

12 relates the absorbed dose in human tissue to the effective biological damage of the radiation by 

13 taking into account the kind of radiation received, the total amount absorbed by the body, and 

14 the tissues involved. Not all radiation has the same biological effect, even for the same amount 

15 of absorbed dose. One sievert is equivalent to 100 rem. 

16 Silicon: A nonmetallic element occurring extensively in the earth’s crust in silica and silicates. 

17 Silt: A sedimentary material consisting of fine mineral particles intermediate in size between 

18 sand and clay. 

19 Sink: A natural or artificial means of absorbing or removing a substance or a form of energy 

20 from a system. 

21 Slurry pump: A machine composed of an impeller, casing, shaft/bearing assembly, shaft seal 

22 and sleeve, and drive; to increase the pressure of a liquid and solids mixture (slurry) through 

23 rotational/centrifugal force and convert electrical energy into kinetic energy; which drives the 

24 mixture from one location to another. 

25 Soil association unit: A landscape or soil grouping that has a distinctive proportional pattern 

26 of soils; it normally consists of one or more major soils and at least one minor soil, and is named 

27 for the major soil(s). 

28 Solidification: To make solid, compact, or hard. 

29 Source material: Uranium or thorium ores containing 0.05 percent uranium or thorium 

30 regulated under the Atomic Energy Act. In general, this includes all materials containing 

31 radioactive isotopes in concentrations greater than natural and the by-product (tailings) from the 

32 formation of these concentrated materials 

33 Source term: The kinds and amounts of radionuclides in an assumed release of radioactive 

34 material. 
 10-16 

1 State Historic Preservation Officer (SHPO): The State officer charged with the identification 

2 and protection of prehistoric and historic resources in accordance with the National Historic 

3 Preservation Act. 

4 Stormwater: The flow of water that results from precipitation and that occurs immediately 

5 following rainfall or as a result of snowmelt. 

6 Subcritical: Incapable of sustaining a nuclear fission chain reaction. 

7 Succulents: Having thick, fleshy, water-absorbing leaves or stems. 

8 Sumps: A hole at the lowest point of a building or facility into which water is drained in order to 

9 be pumped out.

10 Surface water: A creek, stream, river, pond, lake, bay, sea, or other waterway that is directly 

11 exposed to the atmosphere. 

12 Surge tank: A tank used to absorb surges in flow. 

13 Tails: In the uranium enrichment process, tails refers to uranium hexafluoride with a reduced 

14 concentration of the uranium-235 isotope. 

15 Tectonic activity: Movement of the earth’s crust, produced by internal forces, such as uplift, 

16 subsidence, folding, faulting, and seismic activity. 

Teragram: 1012 grams or a million metric tons ("tera" represents a factor of 1012 17 ). 

18 Terrestrial: Living or growing on land; not aquatic. 

19 Tertiary: The first period of the Cenozoic era (after the Cretaceous period of the Mesozoic era 

20 and before the Quaternary period), thought to have covered the span of time between 65 million 

21 years and 3 to 2 million years ago. The Tertiary period is divided into five epochs: the 

22 Paleocene, Eocene, Oligocene, Miocene, and Pliocene. 

23 Threatened Species: Any species likely to become an endangered species within the 

24 foreseeable future throughout all or a significant portion of its range. Requirements for declaring 

25 a species threatened are contained in the Endangered Species Act. 

26 Title V: Title V of the 1990 Clean Air Act Amendments requires all major sources and some 

27 minor sources of air pollution to obtain an operating permit. A title V permit grants a source 

28 permission to operate. The permit includes all air pollution requirements that apply to the 

29 source, including emission limits and monitoring, record keeping, and reporting requirements. It 

30 also requires that the source report its compliance status with respect to permit conditions to the 

31 permitting authority. 

32 Topography: The shape of Earth’s surface or the geometry of landforms in a geographic area. 

33 Top soil: The fertile, surface portion of a soil; usually dark colored and rich in organic material. 

34 Total effective dose equivalent (TEDE): The sum of the effective dose equivalent from 

35 radiation sources external to the body during the year plus the committed effective dose 
 10-17 

1 equivalent from radionuclides taken into the body. A 50-year time interval is assumed for 

2 determining committed dose. 

3 Toxic Substances Control Act (TSCA): A Federal law authorizing the U.S. Environmental 

4 Protection Agency to secure information on all new and existing chemical substances and to 

5 control any of these substances determined to cause unreasonable risk to public health or the 

6 environment. This law requires that the health and environmental effects of all new chemicals 

7 be reviewed by the EPA before such chemicals are manufactured for commercial purposes. 

8 Transient species: Traveling nonresident, individuals of distinct animal species; migrating 

9 between seasonal breeding habitat, and overwintering or feeding habitat. 

10 Transuranic waste: Waste containing more than 100 nanocuries of alpha-emitting transuranic 

11 (atomic number greater than 92) isotopes per gram of waste with half-lives greater than 

12 20 years. 

13 Unconfined aquifer: An aquifer that is not confined by a less-permeable confining unit. An 

14 aquifer where the water table elevation represents the hydraulic potential. 

15 Unincorporated area: An area that is not located within the jurisdiction of any local 

16 government. Such unincorporated areas are governed and taxed by county-level government. 

17 Uranium: A radioactive element with the atomic number 92 and, as found in natural ores, an 

18 atomic weight of approximately 238. The two principal natural isotopes are uranium-235 

19 (0.7 percent of natural uranium), and uranium-238 (99.3 percent of natural uranium). Natural 

20 uranium also includes a minute amount of uranium-234. 

21 Viewscape: Those features which provide a range of sight that can be identified as providing a 

22 community asset such as, but not limited to, pleasing vistas, scenes and views that provide a 

23 sense of place and character. 

24 Viewshed: The area on the ground that is visible from a specific location. 

25 Venturi scrubber: A “wet” scrubber, using gas atomizing spray ejection technology to control 

26 fine (under 10 micrometers diameter) particulate matter. 

27 Volatile organic compound: Any compound containing carbon and hydrogen in combination 

28 with any other element that has a vapor pressure of 77.6 millimeters of mercury (1.5 pounds 

29 per square inch) absolute or greater under actual storage conditions. 

30 Waste management: The planning, coordination, and direction of functions related to 

31 generation, handling, treatment, storage, transportation, and disposal of waste. It also includes 

32 associated pollution prevention and surveillance and maintenance activities. 

33 Water deluge system: A sprinkler system employing open sprinklers that are attached to a 

34 piping system that is connected to a water supply through a valve that is opened by the 

35 operation of a detection system installed in the same areas as the sprinklers; when this valve 

36 opens, water flows into the piping system and discharges from all sprinklers attached thereto; 

37 deluge systems are used where large quantities of water are needed quickly to control a fast38 developing fire; deluge valves can be electrically, pneumatically or hydraulically operated. 
 10-18 

1 Water resources: This term includes both freshwater and marine systems, wetlands, 

2 floodplains, and ground water. 

3 Wetlands: Land or areas exhibiting the following characteristics: hydric soil conditions; 

4 saturated or inundated soil during some part of the year and plant species tolerant of such 

5 conditions; also, areas that are inundated or saturated by surface or groundwater at a frequency 

6 and duration sufficient to support, under normal circumstances, a prevalence of vegetation 

7 typically adapted for life in saturated soil conditions. Wetlands generally include swamps, 

8 marshes, bogs, and similar areas. 

9 Wildlife corridor: An area of habitat connecting wildlife populations otherwise separated by 

10 human activities. 

11 Wind rose: A plot of wind direction and speed showing the distribution of directions that the 

12 wind blows from at a measurement site. The proportion of the time that a wind blows from any 

13 given direction is indicated by the length of the “petal” on the wind rose. 

14 Wind speed: The speed of air movement measured for a set height above ground level (agl) at 

15 a meteorological observing site. This height may vary depending on the location. Typically, 

16 anemometers at National Weather Service stations are placed at 32 ft 10 inches (10 m) agl; 

17 however, some are still found at 20 ft (6 m) agl. 
A-1 

1 APPENDIX A 

2 

3 SCOPING SUMMARY 

A-3 

1 

2 

3 

4 ENVIRONMENTAL IMPACT STATEMENT SCOPING 

5 PROCESS 

6 

7 

8 

9 

10 SCOPING SUMMARY REPORT 

11 

12 

13 

14 

15 

16 

17 PROPOSED INTERNATIONAL ISOTOPES FLUORINE 

18 PRODUCTS, INC. (IIFP) FLUORINE EXTRACTION PROCESS 

19 AND DEPLETED URANIUM DE-CONVERSION PLANT 

20 TO BE LOCATED IN LEA COUNTY, NEW MEXICO

 A-5 

1 A.1 INTRODUCTION 

2 On December 30, 2009, International Isotopes Fluorine Products, Inc. (IIFP) submitted an 

3 application to the U.S. Nuclear Regulatory Commission (NRC) for a license to construct and 

4 operate a proposed Fluorine Extraction Process (FEP) and Depleted Uranium De-conversion 

5 Plant (FEP/DUP) to be located at a site 22.5 kilometers (km) (14 miles [mi]) west of the City of 

6 Hobbs in Lea County, New Mexico. An Environmental Report was also submitted by IIFP at 

7 that time. If licensed, the FEP/DUP facility would be used for the deconversion of commercially8 generated depleted uranium hexafluoride (DUF6) inventories into depleted uranium oxide and 

9 other deconversion products. 

10 In accordance with NRC regulations in Title 10 of the Code of Federal Regulations (10 CFR) 

11 Part 51 (10 CFR 51), which implement the National Environmental Policy Act of 1969, as 

12 amended (NEPA), the NRC staff is preparing an Environmental Impact Statement (EIS) for the 

13 proposed FEP/DUP facility as part of its decision-making process. The EIS will examine the 

14 potential environmental impacts associated with the proposed facility. The NRC staff has not 

15 identified any cooperating agencies for the preparation of this EIS. In addition to the EIS, the 

16 NRC staff will prepare a Safety Evaluation Report (SER) which will document the staff’s review 

17 of safety and security issues associated with the proposed facility. 

18 On July 15, 2010, NRC published in the Federal Register (FR) a Notice of Intent to prepare an 

19 EIS and to conduct the public scoping process (75 FR 41242). The public scoping comment 

20 period ended on August 30, 2010. Scoping is an early part of the NEPA process designed to 

21 help determine the range of actions, alternatives, and potential impacts to be considered in the 

22 EIS, and to identify significant issues related to the proposed action. In addition to the public 

23 scoping process, the NRC staff solicits input from State, local and other Federal agencies, and 

24 potentially affected Native American Tribes in order to focus on issues of genuine concern. 

25 On July 29, 2010, the NRC staff held a public scoping meeting in Hobbs, New Mexico, to 

26 receive oral and written comments from interested parties. The public scoping meeting began 

27 with NRC staff providing a description of the NRC’s roles, responsibilities, and mission. A brief 

28 overview of the licensing process was followed by a description of the environmental review 

29 process and a discussion of how the public can participate. The majority of the meeting was 

30 reserved for the public to ask questions and make comments on the scope of the environmental 

31 review. 

32 As part of the environmental review process, the NRC staff has requested information regarding 

33 the scope of its environmental review from several sources. The NRC staff initiated consultation 

34 with the New Mexico State Historic Preservation Officer (SHPO), in accordance with the 

35 procedures in 36 CFR 800 to meet the requirements of Section 106 of the National Historic 

36 Preservation Act. In accordance with 36 CFR 800.3(f), the NRC staff has requested information 

37 from Native American Tribal members identified by the SHPO and the NRC staff. The NRC 

38 staff has also consulted with representatives of the U.S. Fish and Wildlife Service (USFWS) as 

39 required by Section 7 of the Endangered Species Act. The National Park Service was 

40 contacted and indicated that no parks would be affected by the project. 

41 This scoping summary report addresses only comments received through the public scoping 

42 process and will be included as an Appendix of the EIS. Input from consulting agencies and 

43 potentially affected Native American Tribes will also be used as a basis for the impact 

44 assessments performed for each resource area. Correspondence with the SHPO and 

45 potentially-affected Native American Tribes are included in Appendix B of this draft EIS. 
 A-6 

1 Correspondence with the USFWS, the National Park Service, and New Mexico Environment 

2 Department (NMED) are also included in Appendix B of this draft EIS. 

3 This report has been prepared to summarize the comments received during the scoping 

4 process as required in 10 CFR 51.29(b). After publication of the draft EIS, the public will be 

5 invited to submit comments on the draft EIS. Availability of the draft EIS, the dates of the public 

6 comment period, and information about a public meeting to discuss the draft EIS will be 

7 announced in the Federal Register, on the NRC’s website (http://www.nrc.gov/public8 involve.html), and in the local news media. After evaluating comments on the draft EIS, the 

9 NRC staff will issue a final EIS that will serve as the basis for the NRC’s consideration of 

10 potential environmental impacts in its decision on whether to license the proposed facility. 

11 This report is organized into four main sections. Section 1 provides an introduction and 

12 background information on the environmental review process. Section 2 summarizes the 

13 comments and concerns expressed by government officials, agencies, and the public. Section 

14 3 identifies the issues that the draft EIS will address and Section 4 describes those issues that 

15 are not within the scope of the draft EIS. Where appropriate, Section 4 also identifies other 

16 places in the decision-making process where issues that are outside the scope of the draft EIS 

17 may be considered. 

18 A.2 ISSUES RAISED DURING THE SCOPING PROCESS 

19 A.2.1 Overview 

20 The public scoping process is an important component in determining the major issues that the 

21 NRC staff should address in the draft EIS. The comments provided by the public addressed 

22 several subject areas related to the IIFP proposed facility and the development of the draft EIS. 

23 Members of the public were able to submit comments on the scope of the IIFP proposed facility 

24 draft EIS by e-mail, postal mail, and by speaking and/or submitting written comments at the 

25 public scoping meeting held in Hobbs, New Mexico, on July 29, 2010. The scoping period 

26 ended on August 30, 2010. 

27 Approximately 60 individuals not affiliated with the NRC staff attended the July 29, 2010, public 

28 scoping meeting in Hobbs, New Mexico. During the meeting, one individual asked a specific 

29 question about the licensing process. Ten individuals offered specific oral comments related to 

30 the proposed FEP/DUP facility. Including the comments received in the scoping meeting, a total 

31 of 28 oral and written comments were received from various individuals during the public 

32 scoping period, which ended on August 30, 2010. The scoping meeting transcript and the 

33 scoping comment letters received by the NRC are available on the NRC website, electronic 

34 reading room, at http://www.nrc.gov/reading-rm/adams/web-based.html. The ADAMS 

35 accession number for the scoping meeting transcript is ML102210424. 

36 In addition to private citizens, the commenters included: 

37 • A representative of Senator Tom Udall 

38 • A Lea County Commissioner 

39 • A Hobbs City Commissioner 

40 • The Mayors of the Cities of Hobbs and Eunice 

41 • The City Manager of Eunice 

42 • State Senator Carroll Leavell (Letter read on his behalf) 
 A-7 

1 Individuals providing oral and written comments addressed several subject areas related to the 

2 environmental review process of the proposed FEP/DUP facility. The following general topics 

3 categorize the comments received during the public scoping period: 

4 • General support or opposition 

5 • Socioeconomics 

6 • Waste Management 

7 • Water Resources 

8 • Geology and Seismicity 

9 • Transportation 

10 • Public and Occupational Health 

11 • Out of Scope 

12 In addition to raising issues about the potential environmental impacts of the proposed facility, 

13 some commenters offered opinions and concerns that typically would not be included in an EIS. 

14 Although noted by the NRC in this summary document, comments of this type are not within the 

15 scope of environmental issues to be analyzed. 

16 Other statements may be relevant to the proposed action, but have no direct bearing on the 

17 evaluation of alternatives or on the decision-making process regarding the proposed action. For 

18 instance, general statements of support for or opposition to the proposed action fall into this 

19 category. Comments of this type have been noted but are not used in defining the scope and 

20 content of the EIS. 

21 A.2.2 Summary of Issues Raised 

22 Several individuals provided comments regarding the beneficial potential socioeconomic 

23 impacts of the proposed facility on the local community. Other comments addressed potential 

24 impacts or risks posed by the facility due to seismic concerns, availability of water sources, 

25 transportation and disposal of waste, and possible health impacts associated with nuclear 

26 facilities. The following summary groups the comments received during the scoping period by 

27 technical area and issue. 

28 A.2.2.1 General Support or Opposition 

29 Several commenters expressed general support for the FEP/DUP facility. One commenter 

30 expressed opposition to locating the FEP/DUP facility, or any facility that deals with nuclear 

31 byproducts, in an area with a history of earthquakes and over an aquifer. 

32 A.2.2.2 Socioeconomics 

33 Three commenters expressed support for the project, specifically for the jobs that will be created 

34 by construction and operation of the facility and the positive economic impact it will have on the 

35 region. 

36 A.2.2.3 Waste Management 

37 Two commenters supported the project as a way to use uranium ‘tails’ that will be generated at 

38 the nearby URENCO USA uranium enrichment plant. One commenter stated that a disposal 
 A-8 

1 path for waste from the FEP/DUP facility to the Andrews County, Texas, nuclear waste disposal 

2 facility is an unsafe disposal path. This commenter also requested that the EIS include disposal 

3 site suitability requirements, as described in 10 CFR 61.50. 

4 A.2.2.4 Water Resources 

5 One commenter stated that the EIS should include the aquifer map that has been prepared by 

6 Mesa Water Company. The same commenter also stated that Lea County lacks an adequate 

7 water supply for a nuclear project. This commenter expressed concern about a site that may 

8 potentially be used for disposal of waste from the FEP/DUP facility being located over the 

9 Ogallala Aquifer. The commenter also stated that the water supply of Hobbs, Eunice, and Jal 

10 risks being polluted by allowing a nuclear project in the area. 

11 A.2.2.5 Geology and Seismicity 

12 One commenter stated that the EIS should include the seismic hazards that have been 

13 indicated for Lea County by the U.S. Geological Survey. This commenter also stated that the 

14 Lea County site should not have been selected due to its seismic history. The commenter also 

15 expressed concerns about possible contamination of the Ogallala Aquifer by nuclear waste 

16 released during an earthquake. 

17 A.2.2.6 Transportation 

18 One commenter expressed concerns about the transportation of waste from the facility in Lea 

19 County (New Mexico) to the Andrews County, Texas, nuclear waste disposal facility just across 

20 the state line. 

21 A.2.2.7 Public and Occupational Health 

22 One commenter submitted a New Mexico Department of Health report showing elevated cancer 

23 rates in Lea County compared to other parts of the state and stated concern that allowing 

24 nuclear industry in the area will raise cancer rates. 

25 A.2.2.8 Out of Scope 

26 One commenter stated that the New Mexico Environment Department’s denial of his request to 

27 set up offsite radiation monitors should be included in the EIS. One commenter stated that 

28 employees of various federal agencies should waive their liability immunity through the Federal 

29 Tort Claims Act and be fully liable for any damages, pollution to the water table, and loss of 

30 livelihood and health of Lea County citizens caused by any future earthquakes. 

31 A.3 SCOPE OF THE ENVIRONMENTAL IMPACT STATEMENT 

32 The NEPA (42 U.S.C. 4321, et seq., as amended), and the NRC’s implementing regulations for 

33 NEPA (10 CFR 51), specify in general terms what should be included in an EIS prepared by the 

34 NRC staff. Regulations established by the Council on Environmental Quality (40 CFR 1500-

35 1508), while not binding on the NRC, provide useful guidance. Additional guidance for meeting 

36 NEPA requirements associated with licensing actions can be found in NUREG-1748, 

37 “Environmental Review Guidance for Licensing Actions Associated with NMSS Programs.” 
 A-9 

1 Pursuant to 10 CFR 51.71(a), in addition to public comments received during the scoping 

2 process, the EIS will also consider matters discussed in the IIFP Environmental Report. In 

3 accordance with 10 CFR 51.71(b), the EIS will consider major points of view and objections 

4 concerning the environmental impacts of the proposed action raised by other Federal, State, 

5 and local agencies, by any affected Indian Tribes/Pueblos, and by other interested persons. 

6 Pursuant to 10 CFR 51.71(c), the EIS will list all Federal permits, licenses, approvals, and other 

7 entitlements that must be obtained in implementing the proposed action, and will describe the 

8 status of compliance with these requirements. Any uncertainty as to the applicability of these 

9 requirements will be addressed in the EIS. 

10 In accordance with 10 CFR 51.71(d), the draft EIS will include a preliminary analysis that 

11 considers and weighs the environmental effects of the proposed action, the environmental 

12 impacts of the alternatives to the proposed action, and alternatives available for reducing or 

13 avoiding adverse environmental effects. In the analysis, due consideration will be given to 

14 compliance with environmental quality standards and regulations that have been imposed by 

15 Federal, State, regional, and local agencies having responsibilities for environmental 

16 protections. The environmental impact of the proposed action will be evaluated in the EIS with 

17 respect to matters covered by such standards and requirements, regardless of whether a 

18 certification or license from the appropriate authority has been obtained. Compliance with 

19 applicable environmental quality standards and requirements does not negate the requirement 

20 for the NRC to weigh all environmental effects of the proposed action, including the degradation, 

21 if any, of water quality, and to consider alternatives to the proposed action that are available for 

22 reducing adverse effects. 

23 While satisfaction of the NRC standards and criteria pertaining to radiological effects is 

24 necessary to meet the licensing requirements of the Atomic Energy Act, the EIS will also, for the 

25 purposes of NEPA, consider the radiological and nonradiological effects of the proposed action 

26 and alternatives. The development of the EIS is closely coordinated with the SER prepared by 

27 the NRC staff to evaluate the potential health and safety impacts of the proposed action. The 

28 EIS will also contain a discussion of the potential cumulative impacts of the proposed action. 

29 Pursuant to 10 CFR 51.71(f), the draft EIS will include a preliminary recommendation by the 

30 NRC staff with respect to the proposed action. Any such recommendation will be reached after 

31 considering the environmental effects of the proposed action and reasonable alternatives, and 

32 after weighing the costs and benefits of the proposed action. 

33 One goal in writing the EIS is to present the impact analyses in a manner that makes it easy for 

34 the public to understand. This EIS will provide the basis for the NRC decision with regard to 

35 potential environmental impacts. Those resources with potential significant impacts will be 

36 discussed in greater detail in the EIS than resources with potential minor or no impacts. This 

37 should allow readers of the EIS to focus on issues that were determined to be important in 

38 reaching the conclusions supported by the EIS. The following topical areas and issues will be 

39 addressed in the EIS. 

40 Alternatives. The EIS will describe and assess the no-action alternative and other reasonable 

41 alternatives to the proposed action. Other alternatives may include alternative sites or 

42 alternative processes to the proposed chemical process. 

43 Need for the Facility. The EIS will provide a discussion of the need for the proposed FEP/DUP 

44 facility. 
 A-10 

1 Compliance with Applicable Regulations. The EIS will list relevant permits and regulations that 

2 apply to the proposed FEP/DUP facility. These include air, water, and solid waste disposal 

3 permits. 

4 Land Use. The EIS will discuss the potential land use impacts associated with the proposed 

5 site preparation, construction, and operating activities. As appropriate, the assessment will 

6 include an analysis of mitigation measures to address potential adverse impacts. 

7 Transportation. The EIS will discuss the potential impacts associated with the transportation of 

8 the construction materials, feed material, product, and waste during both normal transportation 

9 and under credible accident scenarios. The potential impacts on local transportation routes due 

10 to workers, delivery vehicles, and waste removal vehicles will be evaluated. As appropriate, the 

11 assessment will include an analysis of mitigation measures to address potential adverse 

12 impacts. 

13 Geology and Soils. The EIS will assess the potential impacts to the geology and soils of the 

14 proposed FEP/DUP facility. The potential for earthquakes or any other major ground motion 

15 considerations will be addressed in the SER and potential environmental impacts of those 

16 phenomena will be evaluated in the EIS. As appropriate, the assessment will include an 

17 analysis of mitigation measures to address potential adverse impacts. 

18 Water Resources. The EIS will assess the potential impacts on surface water and groundwater 

19 quality and water use due to the proposed action. As appropriate, the assessment will include 

20 an analysis of mitigation measures to address potential adverse impacts. 

21 Ecological Resources. The EIS will assess the potential environmental impacts on ecological 

22 resources, including plant and animal species. Threatened and endangered species and critical 

23 habitats that may occur in the area will be discussed. The outcomes of consultations with 

24 resource protection agencies, as required by Section 7 of the Endangered Species Act of 1973 

25 (16 U.S.C. Section 1536(a)(2)), will be discussed. As appropriate, the assessment will include 

26 an analysis of mitigation measures to address potential adverse impacts. 

27 Air Quality. The EIS will make determinations concerning the meteorological conditions of the 

28 site location, the ambient air quality, the contributions of other sources to air quality, and the 

29 potential impacts of site preparation, construction, and operation of the proposed FEP/DUP 

30 facility on local air quality. In addition, the EIS will consider the impact of the proposed facility 

31 on climate change. As appropriate, the assessment will include an analysis of mitigation 

32 measures to address potential adverse impacts. 

33 Noise. The EIS will discuss the potential impacts associated with noise from site preparation, 

34 construction, operation, and decommissioning of the proposed FEP/DUP facility. As 

35 appropriate, the assessment will include an analysis of mitigation measures to address potential 

36 adverse impacts. 

37 Historic and Cultural Resources. The EIS will address the potential impacts of the proposed 

38 FEP/DUP facility on the historic and archaeological resources of the area. The outcomes of 

39 consultations with historic and cultural resource protection agencies, consistent with Section 

40 106 of the National Historic Preservation Act of 1966 (36 CFR 800) will be discussed. As 

41 appropriate, the assessment will include an analysis of mitigation measures to address potential 

42 adverse impacts. 
 A-11 

1 Visual and Scenic Resources. Potential impacts to the overall visual and scenic character of 

2 the area will be addressed. As appropriate, the assessment will include an analysis of 

3 mitigation measures to address potential adverse impacts. 

4 Socioeconomics. The EIS will address demography, economic base, labor pool, housing, 

5 utilities, public services, education, and recreation potentially affected by the proposed action 

6 and alternatives. The hiring of new workers from outside the area could lead to potential 

7 impacts on regional housing, public infrastructure, and economic resources. Potential 

8 population changes leading to changes in the housing market and demands on the public 

9 infrastructure will be assessed. As appropriate, the assessment will include an analysis of 

10 mitigation measures to address potential adverse impacts. 

11 Costs and Benefits. The EIS will compile in one place the costs and benefits of the proposed 

12 project so that a determination can be made of any net positive benefit to Lea County, the 

13 region, and the Nation. The EIS will compare the potential environmental and monetary costs 

14 and benefits of constructing and operating the proposed FEP/DUP facility. 

15 Resource Commitments. The EIS will identify the potential for any unavoidable adverse 

16 impacts and irreversible and irretrievable commitments of resources. It will also address the 

17 relationship between local, short-term uses of the environment and the maintenance and 

18 enhancement of long-term productivity. Associated mitigative measures and environmental 

19 monitoring requirements will be presented, as applicable. 

20 Public and Occupational Health. The EIS will include a determination of potentially adverse 

21 effects on human health that result from chronic and acute exposures to ionizing radiation and 

22 hazardous chemicals, and from physical safety hazards. Potentially adverse effects on human 

23 health might occur during site preparation, construction, operation, or decommissioning. 

24 Potential impacts associated with the implementation of the proposed action will be assessed 

25 under normal operation and credible accident scenarios. As appropriate, the assessment will 

26 include an analysis of mitigation measures to address potential adverse impacts. 

27 Waste Management. The EIS will discuss the management of wastes, including by-product 

28 materials, generated from the site preparation, construction, and operation of the proposed 

29 FEP/DUP facility to assess the potential impacts of generation, storage, and disposal. 

30 Decommissioning. The EIS will provide a discussion of facility decommissioning and associated 

31 potential impacts. 

32 Cumulative Impacts. The EIS will address the potential cumulative impacts from past, present, 

33 and reasonably foreseeable future activities at and near the site, including preconstruction 

34 activities and a proposed facility expansion. 

35 Environmental Justice. The EIS will address any potential disproportionately high and adverse 

36 environmental impacts of the proposed FEP/DUP facility on low-income and minority 

37 populations. 

38 A.4 ISSUES CONSIDERED TO BE OUTSIDE THE SCOPE OF THE ENVIRONMENTAL 

39 IMPACT STATEMENT 

40 The purpose of an EIS is to assess the potential environmental impacts of a proposed action in 

41 order to assist in an agency’s decision-making process – in this case, NRC’s licensing process. 
 A-12 

1 As noted in Section 2.1, some issues and concerns raised during the scoping process are not 

2 relevant to the EIS because they are not directly related to the assessment of potential 

3 environmental impacts or the decision-making process. The lack of in-depth discussion in the 

4 EIS, however, does not mean that an issue or concern lacks value. Issues beyond the scope of 

5 the EIS either may not yet be at the point where they can be resolved or are more appropriately 

6 discussed and decided in other venues. 

7 Some of the issues raised during the public scoping process for the proposed facility are outside 

8 the scope of the EIS, but are analyzed in the SER. For example, health and safety issues are 

9 considered in detail in the SER prepared by the NRC staff for the proposed action and are 

10 summarized in the EIS. The EIS and the SER are related in that they may cover some of the 

11 same topics and may contain similar information, but the analysis in the EIS is focused on the 

12 assessment of potential environmental impacts. In contrast, the SER deals primarily with safety 

13 evaluations and procedural requirements or license conditions to ensure the health and safety 

14 of workers and the general public. The SER also covers other aspects of the proposed action 

15 such as demonstrating that the applicant will provide adequate funding for the proposed facility 

16 in compliance with the NRC’s financial assurance regulations. 

17 Some of the issues raised during the public scoping process are not addressed in the EIS as 

18 they are not appropriate for resolution in the EIS. Other issues, including support of or 

19 opposition to nuclear facilities and the liability of federal workers under the Federal Tort Claims 

20 Act, are also beyond the scope of the EIS. The mission of the NRC is to license and regulate 

21 the Nation’s civilian use of byproduct, source, and special nuclear materials in order to protect 

22 public health and safety, promote the common defense and security, and protect the 

23 environment. The NRC’s regulations are designed to protect both the public and workers 

24 against radiation hazards from industries that use radioactive materials. The NRC’s scope of 

25 responsibility includes regulation of commercial nuclear power plants; research, test, and 

26 training reactors; nuclear fuel cycle facilities; medical, academic, and industrial uses of 

27 radioactive materials; and the transport, storage, and disposal of radioactive materials and 

28 wastes. Activities not within the jurisdiction of the NRC are not subject to NRC regulations nor 

29 appropriate for consideration in the NRC’s decision making process. 

30 

31 
B-1 

1 APPENDIX B 

2 

3 CONSULTATION/CORRESPONDENCE 

 

 B-3 

1 
 

 B-4 

1 
 

 B-5 

1 
 

 B-6 

1 

2 
 

 B-7 

1 
 

 B-8 

1 
 

 B-9 

1 
 

 B-10 

1 
 

 B-11 

1 
 

 B-12 

1 
 

 B-13 

1 
 

 B-14 

1 
 

 B-15 

1 
 

 B-16 

1 
 

 B-17 

1 
 

 B-18 

1 
 

 B-19 

1 
 

 B-20 

1 
 

 B-21 

1 
 

 B-22 

1 
 

 B-23 

1 

2 

3 

4 
 

 B-24 

1 
 

 B-25 

1 
 

 B-26 

1 
 

 B-27 

1 
 

 B-28 

1 
 

 B-29 

1 
 

 B-30 

1 
 

 B-31 

1 
 

 B-32 

1 
 

 B-33 

1 
 

 B-34 

1 
C-1 

1 APPENDIX C 

2 

3 AIR EMISSIONS 

 

 C-3 

1 AIR EMISSIONS

2 C.1 Introduction 

3 The construction and operation of the proposed IIFP facility would result in an increase in air 

4 emissions due to construction, operations, and decommissioning workforce commuter vehicles 

5 and delivery vehicles, and, during construction, construction equipment. This Appendix 

6 presents the inputs and methodology used to estimate emission rates from vehicles in order to 

7 compare the estimated pollutant concentrations with National Ambient Air Quality criteria 

8 (NAAQS). The impacts of emissions on air quality also considered the downwind dispersion 

9 rates, and the input and methodology for those calculations are included in this Appendix. 

10 C.2 Air Pollutant Emissions from On-Road Vehicles 

11 This section discusses on-road vehicle air pollutant emissions, during construction, operation, 

12 and decommissioning of the proposed IIFP facility. 

13 C.2.1 Model Input 

14 The basic calculation to determine a pollutant emission rate is to multiply the number of vehicle 

15 miles by the pollutant’s emission factor (explained below for pollutants listed in Table C-2). The 

16 number of commuter vehicles was conservatively estimated based on the size of the 

17 construction and operations workforces presented applicant’s Environmental Report (IIFP, 

18 2009). The daily mileage was estimated based on the likely residences of the workforces (see 

19 this draft EIS Sections 4.1.1.8 for construction and 4.1.2.8 for the methodology to estimate 

20 commuter mileage). The estimated numbers of daily deliveries and mileage was also estimated 

21 from information found in the Environmental Report. This information is summarized in Table 

22 C-1. 

23 Emission factors were determined using the computer code MOVES (EPA, 2010a), an EPA 

24 emission inventory model. It provides an accurate estimate of emissions from mobile sources 

25 under a wide range of user-defined conditions. MOVES was used to calculate emission factors 

26 for volatile organic compounds (VOCs), carbon monoxide (CO), nitrogen oxides (NOx), carbon 

27 dioxide equivalents (CO2), sulfur dioxide (SO2), particulate matter less than 2.5 microns in 

28 diameter (PM2.5), particulate matter less than 10 microns in diameter (PM10), benzene, methyl 

29 tertiary butyl ether (MBTE), 1,3 butadiene, formaldehyde, acetaldehyde, and acrolein for the 

30 years of interest. Phase 1 construction is expected to start in 2012 and be completed in 2013. 

31 Phase 2 construction is expected to begin in year 2015 and be completed in 2016 Facility 

32 operations would begin in 2013, and extend for the 40-year license term. The year 2011 was 

33 chosen as the model year. 

34 Different emissions emanate from a vehicle depending on type of activity and time of the day. 

35 The model accounts for all emissions during normal daily activity. The types of emission 

36 processes are: 

37 • Running exhaust – tailpipe emissions during highway travel. 

38 • Starting exhaust – tailpipe emissions that occur as a result of starting a vehicle. These 

39 emissions are independent of running exhaust emissions. The magnitude of these 

40 emissions is dependent on how long the vehicle has been sitting prior to starting. 
 

 C-4 

1 Table C-1. Worker and Delivery Vehicle Rates Due to Construction, Operation, and 

2 Decommissioning Activities of the IIFP Facility 

 (vehicles) (miles/day) (days/phase)* (vehicle miles/phase) 

Preconstruction (3 months) 

workers 70 40 62.5 175,000 

deliveries 10 40 62.5 25,000 

equipment 2 40 62.5 5,000 

Phase 1 Construction (1 year**) 

workers 140 40 250 1,400,000 

deliveries 20 40 250 200,000 

equipment 4.25 40 250 42,500 

Phase 1 Operations (1 year) 

workers 140 40 250 1,400,000 

deliveries 10.6 1512 250 4,006,800 

Phase 2 Construction (1 year) 

workers 180 40 250 1,800,000 

deliveries 20 40 250 200,000 

equipment 2 40 250 20,000 

Phase 2 Operations* (per year) 

workers 40 40 250 400,000 

deliveries 17.2 1512 250 6,501,600 

Decommissioning (3 years) 

workers 40 40 750 1,200,000 

deliveries 0 - 750 0 

* After 2016, both phases of the facility will be operational. The “Phase 1 operations” entries apply only to the 

years 2013 to 2016, when only Phase 1 is operation. “Phase 2 operations” entries include both Phase 1 and 

Phase 2 operations, beginning in year 2016. 

** The work year was taken to be 250 days long. 

Source: IIFP, 2011 

3 

4 • Tirewear – particulate emissions as friction between tires and the highway wear away 

5 the tire. 

6 • Brakewear – particulate emissions from brake use. 

7 • Evaporation loss – fuel loss through rubber and plastic components while the vehicle is 

8 sitting . 

9 • Crankcase exhaust – the exhaust gases that escape around the piston rings and enter 

10 the crankcase during normal operation. 

11 Table C-2 presents the results of all the sources of emissions as grams per mile driven, as 

12 calculated by the MOVES model using the input parameters from Table C-1. 

13 
 

 C-5 

1 Table C-2. MOVES Emission Factor Outputs for 2011 

Pollutant Emission Factor (gram/mile) 

workers deliveries equipment 

VOCs 7.37x10-1 8.72x10-1 1.02 

CO 7.82 1.02 x10 1.20 x10 

NOx 1.04 4.63 1.71 

SO2 8.28 x10-3 1.12 x10-2 9.96 x10-3

PM10* 3.53 x10-2 2.38x10-1 5.30 x10-2

PM2.5* 1.90 x10-2 1.97x10-1 3.23 x10-2

CO2 - equivalent 4.28 x102 9.57 x102 5.30 x102

benzene 1.67 x10-2 1.92 x10-2 2.57 x10-2

MBTE 0.00 0.00 0.00 

1,3 butadiene 2.86 x10-3 4.34 x10-3 4.56 x10-3

formaldehyde 6.41 x10-3 2.46 x10-2 1.15 x10-2

acetaldehyde 5.93 x10-3 1.27 x10-2 9.72 x10-3

acrolein 2.97 x10-4 1.20 x10-3 5.31 x10-4

2 *PM totals are the sum of organic carbon, elemental carbon, and sulfate particulate emissions. 

3 

4 C.2.2 Analysis Methods 

5 Emission rates of the six criteria pollutants (i.e., CO, NOX, SO2, PM10, PM2.5 and VOCs, an 

6 ozone precursor), CO2 equivalent, and six hazardous air pollutants (HAPs) (i.e., benzene, 

7 MBTE, 1,3 butadiene, formaldehyde, acetaldehyde, and acrolein) as calculated by MOVES for 

8 Lea County in 2011 (Table C-2) were multiplied by the worker and delivery vehicles mileage 

9 estimates (Table C-1) to arrive at total emissions. 

10 

11 C.2.3 Results 

12 Pollutant emission amounts for the span of construction and operation phase are reported in 

13 draft EIS Sections 4.1.1.4 for construction (Tables 4-4 and 4-5), 4.1.2.4 for operations (Tables 

14 4-15 and 4-16), and 4.2.2.4 for the Phase 2 increment. 

15 C.3 Air Pollutant Emissions from Construction Activities 

16 This section discusses air pollutant emissions as a result of construction activities. This 

17 includes emissions from construction equipment, fugitive dust emissions from land disturbance 

18 from construction activities, and fugitive emissions from the onsite diesel refueling activities. 
 

 C-6 

1 C.3.1 Analysis Methods 

2 All emissions were calculated using the general equation for emissions estimation (EPA, 

3 1995a): 

4 E = A x EF x (1-ER/100) 

5 where: 

6 E = emissions 

7 A = activity rate 

8 EF = emission factor 

9 ER = overall emission reduction efficiency, as % 

10 

11 For construction equipment the activity rate is measured as horsepower-hours. The following 

12 equation (EPA, 2005a) was used to determine the horsepower-hours: 

13 HP-hr = (Max HP) x (LF) x (#) x (hrs) 

14 where: 

15 HP-hr = horsepower-hours 

16 Max HP = maximum horsepower 

17 LF = load factor 

18 # = number of units used 

19 hrs = hours that equipment operates 

20 

21 For fugitive dust emissions in the first equation, the activity rate is the number of acres that 

22 would be disturbed by construction activities. Because the applicant indicated that watering 

23 would be used to control fugitive dust emissions, an emission reduction efficiency of 50% was 

24 assumed. 

25 For fugitive emissions from the onsite diesel refueling activities in the first equation, the activity 

26 rate is the number of gallons of diesel fuel used. The amount of diesel fuel used was calculated 

27 using the following equation (EPA, 2010b): 

28 DB = BSFC x TAF x A 

29 where: 

30 DB = diesel burned 

31 BSFC = brake specific fuel consumption 

32 TAF = transient adjustment factor 

33 A = activity rate (HP-hr) 

34 Carbon dioxide equivalents were calculated using the equation (EPA, 2005b): 

35 CO2e = CO2 + (21 x CH4) + (310 x N2O) 

36 where: 

37 CO2e = carbon dioxide equivalents 

38 CO2 = carbon dioxide 

39 CH4 = methane 

40 N2O = nitrous oxide 

41 

42 The applicant provided equipment lists and schedules showing the hours of equipment 

43 operation per month for each construction phase (preconstruction, Phase 1 and Phase 2), and 

44 the amount of disturbed acreage (IIFP, 2011). 
 

 C-7 

1 C.3.2 Emission Factors 

2 Emission factors for CO2, VOCs, CO, NO2, SO2, PM2.5, and PM10 were determined using the 

3 computer code NONROAD (EPA, 2005b), an EPA emission inventory model. Default values 

4 for Lea County, New Mexico (i.e., climate/meteorology, equipment age, deterioration factors, 

5 fuel properties, and growth factors) were used as inputs for the model. The year 2011 was 

6 chosen at the modeling year. 

7 Emission factors for the greenhouse gases methane (CH4) and nitrous oxide (N2O) were 

8 obtained from the EPA guidance document “Climate Leaders Greenhouse Gas Inventory 

9 Protocol Core Module Guidance Direct Emissions from Mobile Combustion Sources” (EPA, 

10 2008). 

11 Emission Factors for fugitive dust emissions were obtained from Section 13.2.3 of EPA AP-42 

12 “Compilation of Air Emission Factors” (EPA, 1995a). Emission factors for refueling activities 

13 were provided by the applicant (IIFP, 2011). 

14 C.3.3 Results 

15 The input used in the calculations described in Section C.3.1, and the calculated monthly and 

16 annual emissions, and maximum emissions rates for each pollutant for each construction phase 

17 (Table C-2) are reported in Draft EIS Sections 4.1.1.4 for Phase 1, and 4.2.2.4 for 

18 preconstruction and Phase 2 construction. 

19 C.4 Incremental Downwind Air Pollutant Concentration Increases 

20 C.4.1 Model Input 

21 Emissions from construction equipment would be dispersed downwind. Dispersion coefficients 

22 were determined using the computer code SCREEN3 (EPA, 1995b), an EPA single source 

23 Gaussian plume model. Dispersion coefficients were determined for the maximum 

24 concentration (at the construction site), the property border (at 900 meters from the construction 

25 site), and 1 mile (1,600 meters) from the construction site for Phase 1 preconstruction and 

26 construction, Phase 2 construction, and Phase 1 operations (Table C-3). 

27 C.4.2 Analysis Methods 

28 There is a direct correlation between the source emission rate and the dispersion coefficients 

29 (disp coeff) calculated by SCREEN3. For example, a 5-fold increase in the emission rate input 

30 to SCREEN3 results in a 5-fold increase in the resulting dispersion concentrations. Therefore, 

31 setting the source emission rate to 1.0 gram/second/square meter allows scaling of the 

32 emission rates by multiplying them by SCREEN3’s dispersion coefficients. This was done using 

33 Eq. C.3-1 for the preconstruction, Phase 1 construction, and Phase 2 construction to determine 

34 the peak 1-hour concentrations at the site border (900 meters) and at one mile (1,600 meters). 

35 The peak 3-hour, 8-hour, 24-hour, and annual concentrations were derived by multiplying the 

36 peak 1-hour concentration by the conversion factors given in Table C-4 (EPA, 1992). The 

37 resulting concentrations are provided in Section C.4.3. 

38 

39 [ (A + B) x C ] + [ D x E ] = F Eq. C.3-1 

40 
 

 C-8 

1 Table C-3. SCREEN3 Outputs: Dispersion Coefficients 

Preconstruction / 

Phase 1 Construction 

Volume

(μg/m3)/ 

(g/s) 

max (157 m ) 935.9 

900 m 246.4 

1600 m 144.5 

Area

(μg/m3)/ 

(g/s/m2) 

max (223 m) 1.648x108

900 m 2.492x107

1600 m 1.565 x107

Phase 2 Construction 

Volume

(μg/m3)/ 

(g/s) 

max (30 m) 7352 

900 m 593.4 

1600 m 274.7 

Area

(μg/m3)/ 

(g/s/m2) 

max (35 m) 9.386x107

900 m 1.753x106

1600 m 7.636x105

Phase 1 Operations - Utilities 

Point

(μg/m3)/ 

(g/s) 

max (107 m) 608.0 

900 m 145.5 

1600 m 132.9 

Phase 1 Operations - H2 Generation 

Point

(μg/m3)/ 

(g/s) 

max (140 m) 666.5 

900 m 210.0 

1600 m 166.5 

2 

3 where A = Construction Equipment 1-hour Peak Emission Rate 

4 B = Construction Vehicles 1=hour Peak Emission Rate 

5 C = SCREEN3 Volume Dispersion Coefficient 

6 D = Fugitive Dust 1-hour Peak Emission Rate 

7 E = SCREEN3 Area Dispersion Coefficient 

8 F = One-hour Peak Concentration at Site Boundary or 1.6 km (1 mi) 

9 Table C-4. EPA Peak Hour Conversion Factors 

3-Hour Conversion Factor 0.90 

8-Hour Conversion Factor 0.70 

24-Hour Conversion Factor 0.40 

Annual Average Conversion Factor 0.10 

Source: (EPA, 1992) 

10 
 

 C-9 

1 The 1-hour peak concentrations at site border for each construction phase and operations were 

2 determined according to Eq. C.3-2. All emission-generating units were conservatively assumed 

3 to operate continuously. The conversion factors given in Table C-4 were used to determine 

4 peak 3-hour, 8-hour, 24-hour, and annual concentrations. The resulting concentrations are 

5 provided in Section C.4.3. 

6 

7 [ ( G + H + J ) x K ] + [ L x M ] = N Eq. C.3-2

8 where G = Boilers 1-hour Peak Emission Rate 

9 H = Generators 1-hour Peak Emission Rate 

10 J = Firewater Pump 1-hour Peak Emission Rate 

11 K = SCREEN3 Utilities Point Dispersion Coefficient 

12 L = H2 Generator 1-hour Peak Emission Rate 

13 M = SCREEN3 H2 Generation Point Dispersion Coefficient 

14 N = One-hour Peak Concentration at Site Boundary or 1.6 km (1 mi) 

15 C.4.3. Results 

16 Peak 1-hour, 3-hour, 8-hour, 24-hour, and annual concentrations at the site boundary for each 

17 construction phase and operations and their percent of the NAAQS that were calculated are 

18 reported in draft EIS Sections 4.1.1.4 for construction (Table 4-6), 4.1.2.4 for operations (Table 

19 4-17), and 4.2.2.4 for cumulative impacts. 

20 C.5 References 

21 (EPA, 1992) U.S. Environmental Protection Agency. 1992. Screening Procedures for Estimating 

22 the Air Quality Impact of Stationary Sources, Revised, EPA-454/R-92-019, October, 1992. 

23 Available at http://www.epa.gov/oppt/exposure/presentations/efast/usepa_1992b_sp_ 

24 for_estim_aqi_of_ss.pdf. Accessed August 9, 2011. 

25 (EPA, 1995a) U.S. Environmental Protection Agency. 1995. Compilation of Air Pollutant 

26 Emissions Factors, Fifth Edition and Supplements, AP-42. Office of Air Quality Planning and 

27 Standards, Research Triangle Park, North Carolina. January 1995. . Available at 

28 http://www.epa.gov/ttn/chief/ap42/index.html. Accessed May 18, 2011. Relevant sections are 

29 posted in ADAMS with ADAMS Accession Nos. ML 11194A234, ML11194A236, and ML 

30 11182C051. 

31 (EPA, 1995b) U.S. Environmental Protection Agency. 1995. “SCREEN3 Model User’s Guide,” 

32 EPA-454/B-95-004, Office of Air Quality Planning and Standards, Research Triangle Park, 

33 North Carolina. September 1995. Available at http://www.epa.gov/ttn/scram/userg/ 

34 screen/screen3d.pdf. Accessed May 18, 2011. ADAMS Accession No. ML071930125. 

35 (EPA, 2005a) U.S. Environmental Protection Agency. 2005. “User’s Guide for the Final 

36 NONROAD2005 Model,” EPA420-R-05-013, Office of Transportation and Air Quality. December 

37 2005. Available at http://www.epa.gov/otaq/models/nonrdmdl/nonrdmdl2005/420r05013.pdf. 
 

 C-10 

1 (EPA, 2005b) U.S. Environmental Protection Agency. 2005. Metrics for Expressing 

2 Greenhouse Gas Emissions: Carbon Equivalents and Carbon Dioxide Equivalents. EPA420-F3 05-002, February 2005. . Available at http://www.epa.gov/oms/climate/420f05002.pdf. 

4 Accessed October 14, 2011. 

5 (EPA, 2008) U.S. Environmental Protection Agency. 2008. Climate Leaders Greenhouse Gas 

6 Inventory Protocol Core Module Guidance Direct Emissions from Mobile Combustion Sources. 

7 EPA430-K-08-004, May 2008. Available at http://www.epa.gov/climateleaders/documents/ 

8 resources/mobilesource_guidance.pdf. Last Accessed on June 2, 2011. 

9 (EPA, 2010a) U.S. Environmental Protection Agency. 2010. MOVES – Motor Vehicle Emission 

10 Simulator, August 26, 2010. Available at http://www.epa.gov/otaq/models/moves/index.htm, last 

11 accessed June 2, 2011. 

12 (EPA, 2010b) U.S. Environmental Protection Agency. 2010. Exhaust and Crankcase emission 

13 Factors for Nonroad Engine Modeling -- Compression-Ignition, NR-009d. EPA-420-R-10-018, 

14 July 2010. Available at http://www.epa.gov/oms/models/nonrdmdl/nonrdmdl2010/ 

15 420r10018.pdf. Accessed October 14, 2011. 

16 (IIFP, 2009) International Isotopes Fluorine Products. 2009. Fluorine Extraction Process and 

17 Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A. ER-IFP18 001, Revision A. December 27, 2009. ADAMS Accession No. ML 100120758. 

19 (IIFP, 2011) International Isotopes Fluorine Products, 2011. Fluorine Extraction Process and 

20 Depleted Uranium De-conversion Plant (FEP/DUP) Official Responses to Environmental Report 

21 RAIs, Revision A ,Talking Points Regarding the Environmental Report. May 24, 2011. ADAMS 

22 Accession No. ML111530402. 
D-1 

1 APPENDIX D 

2 

3 SOCIOECONOMIC INFORMATION 

4 

 

 D-3 

1 SOCIOECONOMIC INFORMATION

2 

3 D.1 Introduction 

4 This Appendix presents the bases to establish the region of influence (ROI) for socioeconomic 

5 conditions, and calculations to assess impacts in the ROI. In addition, this Appendix contains 

6 the input used for the Environmental Justice analysis.

7 

8 D.2 Socioeconomic Region of Influence (ROI) 

9 The identification of a socioeconomic region of influence for a site is dependent on many 

10 factors, which can include, but are not necessarily limited to: 

11 

12 • Population and population densities of the counties within 50 miles of the proposed site 

13 • Population of those counties’ largest population centers 

14 • Geographic locations of the population centers in relation to the proposed site 

15 • Estimated travel distance or travel time from the population centers to the proposed site 

16 • Mean travel time to work for each county 

17 • Employment data for each county 

18 • Worker commuting patterns from the surrounding counties to the county containing the 

19 proposed site (“host county”) 

20 

21 In identifying the socioeconomic ROI, the initial step was to identify counties that lie primarily 

22 within the 50-mile radius or counties with only a small portion of their area within the 50-mile 

23 radius but with a large population center within the 50-mile radius . Two counties in New 

24 Mexico and three counties in Texas have these characteristics: Lea County and Eddy County, 

25 New Mexico, and Andrews, Gaines, and Yoakum Counties, Texas. A review of the key 

26 factors for each county, determined that the proposed action has the potential to impact 

27 socioeconomic variables (employment, population, income, housing, infrastructure, and 

28 community services) in the two New Mexico counties only (Lea and Eddy). Therefore, these 

29 counties were identified as the socioeconomic ROI. For the reasons discussed below, the 

30 proposed action is unlikely to impact socioeconomic variables in the Texas counties (Andrews, 

31 Gaines, and Yoakumand these counties were not included in the socioeconomic ROI. Each 

32 county’s demographics are summarized in Tables D-1 through D-5 and briefly analyzed below. 

33 

34 Table D-1 provides information on population, income, distances and commuting time for 

35 counties and population centers. Table D-2 provides employment characteristics by county. 

36 Table D-3 provides county-to-county worker flows. Table D-4 provides information on housing 

37 units and staffed hospital beds. Table D-5 provides hospital beds details per hospital/medical 

38 center. 

39 
D-4 

1 

Table D-1. Population, Income, Distances and Commuting Time for Counties and Population Centers.

County Population 

(2000)a

Population 

Density per 

Square 

mile of 

Land Area 

(2000)a

Population 

Estimate 

(2009)a

Mean 

Travel 

Time to 

Work, 

2000 

(Minutes)a

Median 

Household 

Income 

(2008 

dollars)a

County's 

Largest 

Population 

Center b

Population 

Center 

Population 

(2000)b

Population 

Center 

Population 

(2009)b

Driving 

Miles from 

Population 

Center to 

proposed 

site 

New Mexico  Lea 55,508 12.6 60,232 18.7 $45,813 Hobbs 28,657 30,838 10-15  Eddy 51,658 12.4 52,706 18.3 $43,784 Carlsbad 25,625 26,259 60-65 Texas  Andrews 13,004 8.7 14,057 20.6 $49,043 Andrews 9,652 10,448 70-75  Gaines 14,467 9.6 15,382 17.4 $40,489 Seminole 5,910 6,251 40-45  Yoakum 7,322 9.2 7,698 15.9 $50,317 Denver 

City 

3,985 4,140 45-50 

Sources and Notes: a USCB, 2010a b USCB, 2010b 

2 3 
D-5 

1 

Table D-2. Employment Characteristics by County.

County Number of 

Jobs 

(2008)a

Construction 

Jobs (2008)a

Construction 

Jobs as 

Percent of 

All Jobs 

(2008) a

Professional, 

Scientific, 

and 

Technical 

Services 

Jobs (2008)a

Professional, 

Scientific, 

and 

Technical 

Services 

Jobs as 

Percent of 

All Jobs 

(2008) a

Civilian 

Labor 

Force 

(2009)b

Annual 

Average 

Unemployment 

Rate (2009)b,c 

(%) 

Unemployment 

Rate (June 

2010)b,c (%) 

New Mexico  Lea 37,622 3,460 9.2% 1,019 2.7% 28,890 7.6 8.0  Eddy 30,692 2,597 8.5% 1,315 4.3% 28,700 5.5 6.1 Texas Andrews 7,337 860 11.7% (D) NA 7,008 7.1 6.6  Gaines 8,043 992 12.3% 150 1.9% 7,016 6.4 6.4 Yoakum 4,980 419 8.4% 67 1.3% 4,134 7.7 6.8 Sources: a BEA, 2010a b BLS, 2010a c BLS, 2010b 

(D) - Not shown (by the BLS) to avoid disclosure of confidential information, but the amount is included in the BEA's totals. NA = Not available

2 3 
D-6 

1 

Table D-3: County-to-County Worker Flows, 2000. 

Res State 

Res 

County 

Res 

(C)MSA

Res 

PMSA

Residence 

State- County 

Name 

Work 

State 

Work 

County 

Workplace 

State-County 

Name Count 

Percent from Resident County 

35 025 9999 9999 Lea Co. NM 035 015 Eddy Co. NM 303 1.5% 35 025 9999 9999 Lea Co. NM 035 025 Lea Co. NM 18,566 93.6% 35 015 9999 9999 Eddy Co. NM 035 015 Eddy Co. NM 19,236 95.3% 35 015 9999 9999 Eddy Co. NM 035 025 Lea Co. NM 195 1.0% 48 003 9999 9999 Andrews Co. TX 035 025 Lea Co. NM 49 1.0% 48 003 9999 9999 Andrews Co. TX 048 003 Andrews Co. TX 3,794 77.2% 48 165 9999 9999 Gaines Co. TX 035 025 Lea Co. NM 179 3.4% 48 165 9999 9999 Gaines Co. TX 048 165 Gaines Co. TX 4,285 80.6% 48 501 9999 9999 Yoakum Co. TX 035 025 Lea Co. NM 135 4.8% 48 501 9999 9999 Yoakum Co. TX 048 501 Yoakum Co. TX 2,383 84.4% Source: USCB, 2003

2 3 
 

 D-7 

1 Table D-4. Housing Units and Staffed Hospital Beds. 

County, State Housing Units, 

2009 a

Percent of Total 

Units 

Staffed Hospital 

Beds b

Percent of 

Total Staffed 

Beds 

 Lea Co., NM 24,837 40.1% 226* 44.5% 

 Eddy Co., NM 22,645 36.5% 147* 28.9% 

 Andrews Co., TX 5,810 9.4% 88* 17.3% 

 Gaines Co., TX 5,645 9.1% 25* 4.9% 

 Yoakum Co., TX 3,062 4.9% 22* 4.3% 

Total 61,999 508 

Sources: 

a

 USCB, 2010a 

b

 AHA, 2007 

2 * See Hospital Beds details per Hospital/Medical Center, in Table D.5 below. 

3 

Table D-5. Hospital Beds Details per Hospital/Medical Center.

New Mexico Hospital Beds Hospital Beds 

County 

Total 

Eddy County 147 

Carlsbad Medical Center 127 

Artesia General Hospital 20 

Lea County 226 

Lea Regional Medical Center 214 

NOR-Lea General Hospital 12 

Texas Hospital Beds 

Andrews County 88 

Permian Regional Medical Center 88 

Yoakum County 22 

Yoakum County Hospital 22 

Gaines County 25 

Memorial Hospital 25 

Source: AHA, 2007 
 

 D-8 

1 D.2.1 Lea County, New Mexico 

2 Lea County is the host county for the proposed IIFP project. The proposed location is 

3 approximately 14 miles west of Hobbs, New Mexico. Lea County had a year 2000 population of 

4 55,508 and an estimated 2009 population of 60,232, with 12.6 people per square land mile in 

5 2000 (Table D-1). The county’s largest population center is Hobbs, with a 2000 population of 

6 28,657, and an estimated 2009 population of 30,838. Hobbs is the largest city within a 50-mile 

7 radius (Carlsbad, in Eddy County New Mexico, has about 26,300 residents and lies on the 50-

8 mile perimeter). Lea County’s mean commute time is 18.7 minutes. 

9 

10 In 2009, Lea County’s civilian labor force was 28,890 persons (Table D-2). In 2008, 

11 employment in the construction industry accounted for 9.2 percent of total employment and 

12 employment in the professional, scientific, and technical services industry (the industry 

13 classification of the proposed project) accounted for approximately 2.7 percent of the jobs. In 

14 2009, the annual average unemployment rate was 7.6 percent. The unemployment rate in June 

15 2010 was 8.0 percent. 

16 

17 In 2000, Lea County’s 19,828 commuting residents traveled to a worksite (USCB, 2003). Of 

18 those, 18,566 (93.6 percent) traveled to a worksite in Lea County. An additional 303 workers 

19 (1.5 percent) commuted to a worksite in Eddy County. The remaining 4.8 percent traveled to a 

20 worksite elsewhere. Of the 19,790 jobs in Lea County in 2000, 18,566 (93.8 percent) were held 

21 by residents of Lea County. Residents of Eddy County held 195 (1.0 percent) of those jobs. No 

22 other county had residents that filled at least 1 percent of the Lea County jobs (Table D-3). 

23 

24 Lea County, in the vicinity of the proposed site, in particular, is well served by state and county 

25 highways and roads. Sufficient community amenities and infrastructure to support additional 

26 population are in Lea County. In 2009, Lea County had 40.1 percent of the housing inventory in 

27 the five subject counties (Table D-4). Lea County had 44.5 percent of all the staffed hospital 

28 beds in the five-county area (Tables D-4 and D-5). 

29 

30 Based on the proximity to the proposed project site, availability of amenities including housing, 

31 and the historical county-to-county worker travel patterns, Lea County is the most likely county 

32 for project workers to reside. Also, Lea County would be the major recipient of facility33 generated property taxes. Therefore, Lea County , was included in the socioeconomic ROI of 

34 the proposed project. 

35 

36 D.2.2 Eddy County, New Mexico 

37 A substantial portion of Eddy County, New Mexico is within the 50-mile radius of the proposed 

38 site. Eddy County had a year 2000 population of 51,658 and an estimated 2009 population of 

39 52,706 with 12.4 people per square land mile in 2000 (Table D-1). The county’s largest 

40 population center is Carlsbad, with a 2000 population of 25,625 and an estimated 2009 

41 population of 26,259. Carlsbad is on the perimeter of the 50-mile radius of the proposed site. 

42 Eddy County’s mean commute time is 18.3 minutes. Carlsbad is approximately 60-65 driving 

43 miles from the proposed site. 

44 

45 In 2009, Eddy County’s civilian labor force was 28,700 persons (Table D-2). In 2008, 

46 employment in the construction industry accounted for 8.5 percent of total employment and 
 

 D-9 

1 employment in the professional, scientific, and technical services industry (the industry 

2 classification of the proposed project) accounted for approximately 4.3 percent of the jobs in the 

3 county. In 2009, the annual average unemployment rate was 5.5 percent. The unemployment 

4 rate in June 2010 was 6.1 percent. 

5 

6 In 2000, of Eddy County’s total commuting population, 19,236 (95.3 percent) traveled to a 

7 worksite in Eddy County and 195 (1.0 percent) commuted to a worksite in Lea County (Table D8 3). 

9 

10 Eddy county is served by several state and county highways and roads. U.S. Highway 62 

11 travels NNE from Carlsbad to the proposed site. Eddy County has sufficient community 

12 amenities and infrastructure to support its population. In 2000, Eddy County had 36.5 percent 

13 of all housing inventory in the five subject counties and 28.9 percent of all the staffed hospital 

14 beds in (Tables D-4 and D-5). 

15 

16 Eddy County, New Mexico, borders the host county of the proposed project. A substantial 

17 portion of the county and a portion of its largest population center is within the 50-mile radius. 

18 The county population center is accessible to the proposed site via a major U. S. Highway. 

19 Although historically few Eddy County residents have traveled to Lea County for work, 

20 commuting patterns may change with newly available employment opportunities, particularly in 

21 the professional, scientific, and technical services industry. Based on the proximity to the 

22 proposed site, easy vehicle access, and availability of amenities including housing, this analysis 

23 concludes that some project workers would likely live in Eddy County. Therefore, Eddy County, 

24 New Mexico, was included in the socioeconomic ROI of the proposed project. 

25 

26 D.2.3 Andrews County, Texas 

27 A substantial portion of Andrews County, Texas, is within the 50-mile radius of the proposed 

28 site. In 2000, Andrews County had a population of 13,004 and an estimated 2009 population of 

29 14,057with 8.7 persons per square land mile in 2000 (Table D-1). The county’s largest 

30 population center is Andrews, with a 2000 population of 9,652 and an estimated 2009 

31 population of 10,448. Andrews is outside the 50-mile radius of the proposed site. Andrews 

32 County’s mean commute time is 20.6 minutes. The proposed site is approximately 70-75 

33 driving miles from the city of Andrews. 

34 

35 In 2009, Andrews County’s civilian labor force was 7,008 persons. In 2008, employment in the 

36 construction industry accounted for 11.7 percent of total employment (Employment in the 

37 professional, scientific, and technical services industry was confidential and not disclosed by the 

38 Bureau of Labor Statistics). In 2009, the annual average unemployment rate was 7.1 percent. 

39 The unemployment rate in June 2010 was 6.6 percent (Table D-2). 

40 

41 In 2000, 3,794 (77.2 percent)of Andrews County commuting residents traveled to a workplace in 

42 Andrews County and 49 residents (1.0 percent) commuted to a worksite in neighboring Lea 

43 County (Table D-3). 

44 

45 The rural county is served by state and county highways and roads. In 2000, Andrews County 

46 had less than 10 percent of all housing inventory in the five subject counties and 17.3 percent of 

47 all the staffed hospital beds (Tables D-4 and D-5). 
 

 D-10 

1 

2 Andrews County, Texas, borders the host county of the proposed project. A substantial portion 

3 of the county is within the 50-mile radius. However, the county population center is not readily 

4 accessible to the proposed site via a major transportation artery. Historically, few Andrews 

5 County workers commute to Lea County., Therefore, few project workers would be expected to 

6 live in Andrews County and it was not included in the socioeconomic ROI. 

7 

8 D.2.4 Gaines County, Texas 

9 A substantial portion of Gaines County, Texas, is within the 50-mile radius of the proposed site. 

10 In 2000, Gaines County had a population of 14,467 and an estimated 2009 population of 

11 15,382with 9.6 persons per square land mile in 2000 (Table D-1). The county’s largest 

12 population center is Seminole, with a 2000 population of 5,910 and an estimated 2009 

13 population of 6,251. Gaines County’s mean commute time is 17.4 minutes. The proposed site 

14 is approximately 40-45 driving miles from Seminole. 

15 

16 In 2009, Gaines County’s civilian labor force was 7,016 persons. In 2008, employment in the 

17 construction industry accounted for 12.3 percent of total employment and employment in the 

18 professional, scientific, and technical services industry accounted for 1.9 percent of total 

19 employment. In 2009, the annual average unemployment rate was 6.4 percent. The 

20 unemployment rate in June 2010 was also 6.4 percent (Table D-2). 

21 

22 In 2000, 4,285 (80.6 percent) of Gaines County commuting residents traveled to a worksite in 

23 Gaines County and 179 (3.4 percent) commuted to a worksite in neighboring Lea County. 

24 

25 The rural county is served by state and county highways and roads. In 2000, Gaines County 

26 had less than 10 percent of all housing inventory in the five subject counties, and 25 staffed 

27 hospital beds, less than 5 percent of all the staffed hospital beds (Tables D-4 and D-5). 

28 

29 Gaines County, Texas, borders the host county of the proposed project. A substantial portion of 

30 the county and its largest population center are within the 50-mile radius. The county population 

31 center is accessible to the proposed site via a major transportation artery. However, because 

32 historically few Gaines County workers commute to work in Lea County and the professional, 

33 scientific, and technical industry accounts for only 1.9 percent of the relatively small county 

34 workforce. Therefore, few project workers would be expected to live in Gaines County and it 

35 was not included in the socioeconomic ROI. 

36 

37 D.2.5 Yoakum County, Texas 

38 A substantial portion of Yoakum County Texas is within the 50-mile radius of the proposed site. 

39 In 2000, Yoakum County had a population of 7,322 and an estimated 2009 population of 

40 7,698with 9.2 persons per square land mile in 2000 (Table D-1). The county’s largest 

41 population center is Denver City, with a 2000 population of 3,985 and an estimated 2009 

42 population of 4,140. Yoakum County’s mean commute time is 15.9 minutes. The proposed site 

43 is approximately 45-50 driving miles from Denver City. 

44 

45 In 2009, Yoakum County’s civilian labor force was 4,134 persons. In 2008, employment in the 

46 construction industry accounted for 8.4 percent of total employment and employment in the 
 

 D-11 

1 professional, scientific, and technical services industry accounted for 1.3 percent of total 

2 employment. In 2009, the annual average unemployment rate was 7.7 percent. The 

3 unemployment rate in June 2010 was 6.8 percent (Table D-2). 

4 

5 In 2000, 2,383 (84.4 percent) ofYoakum County commuting residents traveled to a workplace in 

6 Yoakum County and 135 (4.8 percent) commuted to a worksite in neighboring Lea County 

7 (Table D-3). 

8 

9 The rural county is served by state and county highways and roads. In 2000, Yoakum County 

10 had approximately 4.9 percent of all housing inventory in the five subject counties and less than 

11 5 percent of all the staffed hospital beds (Tables D-4 and D-5). 

12 

13 Yoakum County, Texas, borders the host county of the proposed project. A substantial portion 

14 of the county and its largest population center are within the 50-mile radius. The county 

15 population center is accessible to the proposed site via a major road. However, because 

16 historically few Yoakum County workers commute to work in Lea County and the professional, 

17 scientific, and technical industry accounts for only 1.3 percent of the relatively small county 

18 workforce, few project workers would be expected to live in Yoakum County. Therefore, 

19 Yoakum County, Texas, was not included in the socioeconomic ROI. 

20 

21 D.2.6 Workflow Patterns Summary 

22 Historical patterns of commuting are the strongest proxy available to predict residential 

23 settlement patterns for workers migrating to an area for new employment opportunities. County24 to-county worker flow patterns are established by commuters based on their demonstrated 

25 preferences for residential areas. These demonstrated preferences are thought to include 

26 commuting times, housing, amenities, and other opportunities for employment. In this analysis, 

27 workers in Lea County demonstrated a preference for working in Lea County and residents of 

28 the surrounding counties demonstrated a reluctance to drive to a worksite in Lea County. 

29 Despite the limited employment opportunities in Andrews, Gaines, and Yoakum County, few 

30 residents of those counties have elected to drive to Lea County, with its larger employment 

31 base. Eddy’s County’s relatively large employment in the professional, scientific, and technical 

32 service sector reflects the presence of WIPP (Waste Isolation Pilot Plant) and related industries. 

33 These variables, coupled with the availability of highway access between Carlsbad and Hobbs, 

34 indicate a strong worker exchange between Lea and Eddy Counties. 

35 

36 D.3 Environmental Justice 

37 This discussion supports the identification of minority and low-income populations within 

38 50 miles of the proposed project location, as shown in draft EIS Chapter 3, Figures 3-20 through 

39 3-25. 

40 Procedures for the determination of minority and low-income populations are discussed in this 

41 section. Appendix C of the Environmental Review Guidance for Licensing Actions Associated 

42 with NMSS Programs (NRC, 2003), provides the current NRC guidance for identifying minority 

43 and low-income populations. The guidance was used in identifying minority and low-income 

44 populations in this draft EIS.
 

 D-12 

1 The area potentially impacted by environmental issues was determined to be within a 50-mile 

2 radius of the site, which is the area that was evaluated for impacts of potential facility accidents. 

3 Therefore, the minority populations and low-income populations were determined for all census 

4 block groups that fell entirely or partially within 50 miles of the project location. Block groups 

5 were used because census blocks (smaller than block groups) do not report income data and 

6 census tracts (larger than block groups) might not delineate minority or low-income populations 

7 within the larger general population (NRC, 2003). U.S. Census Bureau (USCB) Summary File 1 

8 containing race data (USCB 2000a; USCB 2000b) and Summary File 3 containing household 

9 poverty data (USCB 2000c; USCB 2000d) were obtained for all block groups in New Mexico 

10 and Texas since the 50-mile radius encompasses parts of both states. 

11 

12 For each race/ethnicity minority category (Black or African American, American Indian and 

13 Alaska Native, Asian, Native Hawaiian and Other Pacific Islander, Other Race, Two or More 

14 Races [Multi-Racial], and Hispanic Ethnicity), and for each block group the percentage of the 

15 total population made up of the minority/ethnicity was calculated. The Aggregate category was 

16 also determined. The Aggregate is the sum of all the minorities within a block group. The 

17 percentage of low-income households was also calculated for each block group. 

18 

19 The Hispanic Ethnicity category is NOT included in the aggregate of minorities because the 

20 USCB considers race and Hispanic origin (ethnicity) as two separate and distinct concepts. 

21 People who are Hispanic may be of any race. People in any race group may be either Hispanic 

22 or Not Hispanic. Each person has two attributes, their race (or races) and whether or not they 

23 consider themselves Hispanic. Because each person is counted in a race category and in 

24 either the Hispanic or not Hispanic category, including the Hispanic ethnicity in the “aggregate 

25 race” category would double count a number of individuals. As such, the race categories and 

26 the Hispanic Ethnicity categories are considered separately. 

27 

28 The minority demographic data and low-income data were then attributed to block group spatial 

data in ArcGIS® 29 9.3 to develop a comprehensive shapefile dataset containing demographic and 

low-income data for every block group in the state. ArcGIS® 30 is a geographic information system 

31 (GIS) modeling software which is used to access and query mapped demographic and low32 income data (ESRI, 2008). 

33 In order to identify whether a minority or low-income population exists, an area larger than the 

34 proposed site and immediately surrounding environs, and that encompasses the entire area of 

35 potential impact must be identified for comparative analysis (NRC, 2003). This area is called a 

36 geographic area. Because the 50-mile radius used in this analysis includes parts of New 

37 Mexico and Texas, the geographic area used as the basis for identifying individual block groups 

38 with minority or low-income populations was the states of New Mexico and Texas. Block group 

39 low-income and minority populations in New Mexico were compared to the total low-income and 

40 minority populations in New Mexico, and block groups low-income and minority populations in 

41 Texas were compared to the total Texas low-income and minority populations. 

42 A significant minority population is considered to be present if: (1) the minority population in the 

43 census block group exceeds 50 percent or (2) the minority population percentage of the block 

44 group is significantly greater (typically at least 20 percentage points) than the minority 

45 population percentage in the geographic area (NRC, 2003). A significant low-income population 

46 is considered to be present if: (1) the low-income household population in the census block 
 

 D-13 

1 group exceeds 50 percent or (2) the percentage of households below the poverty level in an 

2 environmental impact area is significantly greater (typically at least 20 percentage points) than 

3 the low-income household percentage in the geographic area (NRC, 2003). 

4 State and county percentages for minority and low-income populations were obtained using 

summary statistics in ArcGIS® 5 9.3 and then compared to the USCB information (USCB, 2000e 

6 USCB, 2000f). The low-income and minority populations of all block groups wholly or partially 

7 within the 50-mile radius were identified if that block group contained a significant “minority 

8 population” or a “low-income population” as defined by NRC (2003). The results of the GIS 

9 modeling are shown on Table D.7, which indicates state and county percentages of racial 

10 composition and low income status for comparison. 

11 Table D6 provides the number of block groups entirely or partially in the 50 mile radius with 

12 minority or low-income populations. 

13 

14 Table D-7 contains the state and county percentages of low-income and minority populations. 

15 These data were compared to the percentages of low income households and minority 

16 populations in each block group in the 50-mile radius to arrive at the information in Table D-6. 

17 

18 Ninety-six block groups are within 50 miles of the project. Block groups within 50 miles of the 

19 proposed project location have Black, Some Other Race, Aggregate, Hispanic and low-income 

20 populations (Table D-6). . 

21 

22 D.4 Construction and Operation Workforce Characteristics Calculations 

23 The tables below present the assumptions used for construction and operation workforce 

24 assessments presented in Chapter 4 of the draft EIS. Table D-8 presents the construction 

25 workforce characteristics during construction of the proposed facility (IIFP, 2011) and 

26 assumptions based on NRC studies of workforces in substantially similar situations (BMI, 1981).

27 

28 Table D-9 presents the operations workforce estimated number of on-site employees during the 

29 Phase I operation of the proposed IIFP facility (IIFP, 2011), and assumptions based on NRC 

30 studies of workforces in substantially similar situations (BMI, 1981).

31 

32 D.5 Socioeconomic Calculations Used in Chapter 4 – Environmental Consequences 

33 Table D-10 presents the calculations used to support the conclusions presented in Chapter 4 of 

34 the Draft EIS related to population, employment, income, housing, public utilities, and education. 
D-14 

1 2 

Table D-6. Race and Low-income Population Block Groups within 50 miles of the Proposed Project. State County County 

FIPS Number 

Number of Block Groups 

Black American 

Indian or Alaskan Native 

Asian Native 

Hawaiian or Other Pacific Islander 

Some Other Race 

Two or More Races 

Aggregate Hispanic LowIncome 

Households 

New Mexico 

Chaves 5 2 0 0 0 0 0 0 0 1 0 

New Mexico 

Eddy 15 3 0 0 0 0 0 0 0 1 0 

New Mexico 

Lea 25 64 1 0 0 0 14 0 10 24 10 

Texas Andrews 3 3 0 0 0 0 0 0 0 0 0 Texas Cochran 79 1 0 0 0 0 0 0 0 0 0 Texas Gaines 165 13 0 0 0 0 0 0 1 3 0 Texas Loving 301 1 0 0 0 0 0 0 0 0 0 Texas Terry 445 1 0 0 0 0 0 0 0 0 0 Texas Winkler 495 1 0 0 0 0 0 0 0 0 0 Texas Yoakum 501 7 0 0 0 0 1 0 0 3 0 

Totals: 96 1 0 0 0 15 0 11 32 10 

Source: ESRI, 2008; USCB, 2000a; USCB, 2000b; USCB, 2000c; USCB, 2000d; USCB, 2000e; USCB, 2000f; USCB, 2000g; USCB, 2000h 3 
D-15 

 1  2 

Table D-7. State and County Percentages of Race and Low-Income Populations 

State County Black(%) American 

Indian or 

Alaskan 

Native 

(%) 

Asian 

(%) 

Native 

Hawaiian 

or Other 

Pacific 

Islander 

(%) 

Some 

Other 

Race 

(%) 

MultiRacial 

(%) 

Aggregate 

(%) 

Hispanic 

(%) 

LowIncome 

Households 

(%) 

New Mexico (state only) 

NA 1.89 9.54 1.06 0.08 17.04 3.65 33.25 42.08 16.78 

New Mexico Chaves 1.97 1.13 0.53 0.06 21.25 3.12 28.05 43.83 19.12 New Mexico Eddy 1.56 1.25 0.45 0.09 17.67 2.64 23.66 38.76 16.72 New Mexico Lea 4.37 0.99 0.39 0.04 23.81 3.27 32.87 39.65 19.90 Texas (state only) NA 11.53 0.57 2.70 0.07 11.69 2.47 29.03 31.99 13.98 Texas Andrews 1.65 0.88 0.71 0.02 16.79 2.87 22.92 40.00 16.74 Texas Cochran 4.53 0.83 0.21 0.05 27.35 2.55 35.52 44.13 21.67 Texas Gaines 2.28 0.76 0.15 0.01 14.17 2.35 19.72 35.77 19.08 Texas Loving 0.00 0.00 0.00 0.00 8.96 1.49 10.45 10.45 0.00 Texas Terry 5.00 0.53 0.22 0.02 14.28 3.40 23.45 44.09 20.53 Texas Winkler 1.85 0.45 0.20 0.00 20.35 2.34 25.19 44.00 18.58 Texas Yoakum 1.39 0.71 0.12 0.01 25.48 1.65 29.38 45.93 18.20 Source: USCB, 2000a; USCB, 2000b; USCB, 2000c; USCB, 2000d; USBC, 2000g; USCB, 2000h 
 

 D-16 

Table D 8. Workforce Characterization During IIFP Phase 1 Construction. 

WORKFORCE CHARACTERIZATION 

Peak number of workers on-site during construction (IIFP, 2011) 140 

WORKFORCE MIGRATION 

Percent of construction workforce migrating into ROI 20% 

Total of construction workers migrating into ROI during construction peak 28 

FAMILIES 

Percent of construction workers who bring families (BMI, 1981) 70% 

Percent of construction workers who do not bring families 30% 

Average construction worker family size (worker, spouse, children) (BMI, 1981) 3.25 

Number of construction workers who would move into ROI and bring families 20 

Number of construction workers who would move into ROI and not bring families 8 

TOTAL IN-MIGRATION - FAMILIES AND UNACCOMPANIED WORKERS 

Number of construction workers who would bring families into ROI (total new families in 

ROI) 20 

Number of in-migrating workers' family members 44 

Number of in-migrating workers accompanied by family, plus family members 64 

Number of in-migrating workers who would not bring families into ROI 8 

Number of in-migrating workers and family members (= new population in ROI) 72 

SCHOOL-AGE CHILDREN 

Number of school-age children per construction family (BMI, 1981) 0.8 

Number of in-migrating school-age children 16 

POST-CONSTRUCTION WORKFORCE RETENTION 

Percent of in-migrating construction workers that would leave, post-construction (BMI, 

1981) 50% 

Number of in-migrating construction workers that would leave ROI, post-construction 14 

Number of in-migrating construction workers and their families plus in-migrating workers 

without families that would leave ROI, post-construction 36 

Number of school-age children of in-migrating construction workers that would migrate to 

ROI 16 

Number of in-migrating school-age children that would leave ROI, post-construction 8 

EMPLOYMENT 

Construction workforce peak 140 

Number of construction workers who migrate into ROI (20% of construction workforce 

peak) 28 

Employment multiplier for construction workers in ROI (indirect portion only) (BEA, 

2010b) 0.4324 

Indirect jobs resulting from in-migrating construction workers 12 

Sources: BEA .2010b; BMI. 1981; IIFP. 2011 

 1 

2 
 

 D-17 

 1 

Table D-9. Workforce Characterization During IIFP Phase 1 Operation. 

WORKFORCE CHARACTERIZATION 

Peak number of workers on-site during operation (IIFP, 2011) 140 

WORKFORCE MIGRATION 

Percent of operation workforce migrating into ROI 20% 

Number of operation workers migrating into ROI during operation peak 28 

FAMILIES 

Percent of operation workers who bring families (BMI, 1981) 100% 

Percent of workers who do not bring families 0% 

Average New Mexico family size, 2009 (USCB, 2010c) 3.23 

Number of operation workers who would move into ROI and bring families 28 

Number of operation workers who would move into ROI and not bring families 0 

TOTAL IN-MIGRATION - FAMILIES AND UNACCOMPANIED WORKERS 

Number of operation workers who would bring families into ROI (= total new families in ROI) 28 

Number of in-migrating operation worker family members 62 

Number of in-migrating operation workers accompanied by family, plus family members 90 

Number of operation workers who would not bring families into ROI 0 

Number of operation workers and family members migrating into ROI (= new population in 

ROI) 

90 

SCHOOL-AGE CHILDREN 

Number of school-age children per family (BMI, 1981) 0.8 

Number of in-migrating school-age children 22 

EMPLOYMENT

Operation workforce peak 140 

Number of operation workers who migrate into ROI (20% of workforce peak) 28 

Employment multiplier for operation workers in ROI (indirect portion only) (BEA, 2010b) 1.8173 

Indirect jobs resulting from in-migrating operation workers 51 

Number of persons unemployed in ROI, June 2010 (BLS, 2010a) 3,993 

2 Sources: BEA, 2010b; BLS, 2010a; BMI., 1981; IIFP, 2011; USCB, 2010c. 

3 

4 
 

 D-18 

1 

2 

Table D.10: Socioeconomic Calculations 

 Phase 1 

Construction 

Phase 1 

Operation 

POPULATION 

2009 ROI Population (USCB, 2010e) 112,938 112,938 

Total In-migration Associated with Phase 1 of the IIFP 

Project 72 90 

Percent ROI Population Increase related to IIFP Project 

Phase 1 0.06% 0.08% 

EMPLOYMENT AND INCOME 

June 2010 ROI Labor Force (BLS, 2010a) 56,945 56,945 

Estimated Number of people, who would become IIFP 

Phase 1 Employees, Currently Living within the ROI (80% 

of workforce) 

112 112 

Number of In-migrating IIFP Phase 1 Workers 28 28 

June 2010 ROI Labor Force Plus In-migrating IIFP Phase 

1 Workers 56,973 56,973 

Percent Jobs Filled by In-migrants Represent of June 

2010 ROI Labor Force 0.05% 0.05% 

June 2010 ROI, Unemployment Rate (BLS, 2010a) 7.0% 7.0% 

June 2010 ROI, Number of People Employed (BLS, 

2010a) 52,952 52,959 

June 2010 ROI, Number of People Unemployed (BLS, 

2010a) 3,993 3,993 

Number of Indirect Jobs Created (BEA, 2010b) 12 51 

Percent Indirect Jobs Represent of the June 2010 ROI 

Labor Force 0.02% 0.09% 

HOUSING 

Vacant Housing Units in the ROI (USCB, 2010d) 5,823 5,823 

Housing Units Needed for In-migrating IIFP Workers 28 28 

Percent of Needed Housing Units Represent of Vacant 

Housing Units 0.48% 0.48% 

3 
 

 D-19 

 1 

Table D.10: Socioeconomic Calculations (Continued)

 Phase 1 

Construction 

Phase 1 

Operation 

PUBLIC UTILITIES

People Served by Major Public Water Suppliers in 2007-

2009 (NMED, 2010a) 88,643 88,643 

Number of IIFP Phase 1 Workers and their Family 

Members Who Would Migrate into the ROI 72 90 

Percent Increase of People to be Served by Major Public 

Water Suppliers 0.08% 0.10% 

Number of People Served by Major Public Wastewater 

Systems, 2009 (NMED, 2010b; Artesia, 2010; Carlsbad, 

2010; Appendix A; Lovington, 2010) 

78,917 78,917 

Percent Increase of People to be Served by Major 

Wastewater Systems 0.09% 0.11% 

EDUCATION 

2008 Public School Enrollment (NCES, 2010) 22,847 22,847 

Number of School-Aged children of IIFP In-migrants 

Eligible for Public School Enrollment 16 22 

Percent Increase School-aged Children In-migrants 

Represent of 2008 ROI Public School Enrollment 0.07% 0.10% 

2 Source: Artesia, 2010; BEA, 2010b; BLS, 2010a; Carlsbad, 2010; Appendix A, Lovington, 2010; NCES, 2010; 

3 NMED, 2010a; NMED, 2010b; USCB, 2010d; USCB, 2010e

4 

5 D.6 References 

6 (Artesia, 2010) City of Artesia Water and Wastewater Department. 2010. Personal 

7 Communication between M. Stroud, (City of Artesia Water and Wastewater Department) and P. 

8 Baxter (TtNUS). September 28, 2010. ADAMS Accession No. ML112840402.

9 (BEA, 2010a) U.S. Department of Commerce, Bureau of Economic Analysis. 2010. Table 

10 CA25N-Total full-time and part-time employment in NAICS industry, Eddy County New Mexico, 

11 Lea County New Mexico, Andrews County Texas, Gaines County Texas, and Yoakum County 

12 Texas. Update April. Available at http://bea.gov/, accessed August 20, 2010.ADAMS Accession 

13 No. ML112920317.
 

 D-20 

1 (BEA, 2010b) U.S. Department of Commerce, Bureau of Economic Analysis. 2010. RIMS II 

2 Multipliers for Eddy, NM and Lea, NM. Economic and Statistics Administration, Washington, 

3 D.C. September, 2010. ADAMS Accession No. ML112720418. 

4 (BLS, 2010a) U S Department of Labor, Bureau Labor Statistics. 2010.. Local Area 

5 Unemployment Statistics (LAUS), 2010 to 2011, New Mexico, Lea County and Eddy County 

6 New Mexico” Available at http://data.bls.gov/. Accessed August 23 and 31, 2010. ADAMS 

7 Accession No. ML103430031.

8 (BLS, 2010b) U.S. Department of Labor, Bureau of Labor Statistics. 2010. Local Area 

9 Unemployment StatisticsAndrews County Texas, Gaines County Texas, Yoakum County 

10 Texas. Available at hhtp://data.bls.gov/. Accessed August 23 and 31, 2010. ADAMS Accession 

11 No. 112710648.

12 (Carlsbad, 2010) City of Carlsbad Waste Water Treatment Plant. 2010. Personal 

13 Communication between A. Sena (City of Carlsbad Waste Water Treatment Superintendent) 

14 and P. Baxter (TtNUS). November 17, 2010. ADAMS Accession No. ML112840422

15 (ESRI, 2006) Environmental Systems Research, Inc. 2006. U.S. Census Block Groups. Tele 

16 Atlas North America, Inc. Redlands, CA. 

17 (IIFP, 2011) International Isotopes Fluorine Products, Inc. 2011. Fluorine Extraction Process 

18 and Depleted Uranium De-conversion Plant (FEP/DUP) Official Responses to Environmental 

19 Report RAIs, Revision A. March 31, 2011. ADAMS Accession No. ML110970481.

20 (Lovington, 2010) City of Lovington Wastewater Treatment Plant. 2010. Personal 

21 Communication between M. De La Cruz (City of Lovington Wastewater Treatment Plant) and P. 

22 Baxter (TtNUS). September 30, 2010. ADAMS Accession No. ML112840439.

23 (NCES, 2010) National Center for Education Statistics. 2010. Search for Public School 

24 Districts, Lea and Eddy Counties, New Mexico. Available at 

25 http://nces.ed.gov/ccd/districtsearch/. Accessed August 30, 2010. ADAMS Accession No. 

26 ML103430054. 

27 (NMED, 2010a) New Mexico Environment Department. 2010. “RE: FOIA Request.” Personal 

28 Communication between M. Huber (New Mexico Environment Department) and N. Hill (TtNUS). 

29 September 22, 2010. ADAMS Accession No. ML112850086.

30 (NMED, 2010b) New Mexico Environment Department, Ground Water Quality Bureau. 2010. 

31 Ground Water Regulated Facilities, List of Current Discharge Permits, updated 07/29/2010. 

32 Available at http://www.nmenv.state.nm.us/gwb/NMED-GWQB-Permits.htm. Accessed August 

33 31, 2010. ADAMS Accession No. ML112710484.

34 (NRC, 2003). U.S. Nuclear Regulatory Commission. 2003. Environmental Review Guidance 

35 for Licensing Actions Associated with NMSS Programs. Final Report. NUREG 1748. August 

36 2003. Division of Waste Management, Washington, D.C. ADAMS Accession No. ML 

37 ML032450279.
 

 D-21 

1 (USCB, 2000a) U. S. Census Bureau 2000. Summary File 1 for New Mexico: Census 2000. 

2 Available at http://www2.census.gov/census_2000/datasets/Summary_File_1/New_Mexico/. 

3 Accessed July 23, 2010. ADAMS Accession No. ML112710551.

4 (USCB, 2000b) U. S. Census Bureau 2000.Summary File 1 for Texas: Census 2000. Available 

5 at http://www2.census.gov/census_2000/datasets/Summary_File_1/Texas/. Accessed July 23, 

6 2010. ADAMS Accession No. ML112710551.

7 (USCB, 2000c) U. S. Census Bureau 2000.Summary File 3 for New Mexico: Census 2000. 

8 Available at http://www2.census.gov/census_2000/datasets/Summary_File_3/New_Mexico/. 

9 Accessed July 23, 2010. ADAMS Accession No. ML112710554.

10 (USCB, 2000d) U. S. Census Bureau 2000.Summary File 3 for Texas: Census 2000. Available 

11 at http://www2.census.gov/census_2000/datasets/Summary_File_1/Texas/. Accessed July 23, 

12 2010. ADAMS Accession No. ML112710554.

13 (USCB, 2000e) U. S. Census Bureau 2000. Texas Fact Sheet. Census 2000 Demographic 

14 Profile Highlights. American Fact Finder. Available at http://factfinder.census.gov/. Accessed 

15 july 27, 2010. 

16 

17 (USCB, 2000f). U. S. Census Bureau 2000. New Mexico Fact Sheet. Census 2000 

18 Demographic Profile Highlights. American Fact Finder. Available at 

19 http://factfinder.census.gov/. Accessed july 27, 2010.

20 

21 (USCB, 2000g) U. S. Census Bureau 2000. P92. Poverty Status in 1999 of Households by 

22 Household Type by Age of Householder. Detailed Tables. Census 2000 Summary File 3 (SF 

23 3) Sample Data. Available at http://factfinder.census.gov/. Accessed July 26, 2010.

24 

25 (USCB, 2000h) U. S. Census Bureau 2000. P3. Race and P4. Hispanic or Latino, and Not 

26 Hispanic or Latino by Race (Total Population). Detailed Tables. Census 2000 Summary File 1 

27 (SF 1) 100-Percent Data. Available at http://factfinder.census.gov/. Accessed September 7, 

28 2010.

29 

30 (USCB, 2010a) U. S. Census Bureau. 2010. State and County Quick Facts, “Lea County and 

31 Eddy County New Mexico.” Revised August 16. Available at http://quickfacts.census.gov/. 

32 Accessed September 21, 2010. ADAMS Accession No. ML103430121. 

33 (USCB, 2010b) U. S. Census Bureau 2010. Table 4. Annual Estimate of the Resident 

34 Population for Incorporated Places, April 1 2000 to July 1 2009. New Mexico and Texas. 

35 Release date June 2010. Available at http://www.census.gov/. Accessed August 23, 2010.

36 (USCB, 2010c) U S Census Bureau. 2010. American FactFinder. New Mexico Fact Sheet. 

37 2005-2009 American Community Survey 5-Year Estimates. Data Profile Highlights. Available 

38 online at http://factfinder.census.gov. Accessed April 11, 2011. ADAMS Accession No. 

39 ML112720609.

40 (USCB, 2010d) U. S. Census Bureau. 2010. American FactFinder, Fact Sheet, American 

41 Community Survey 2006 - 2008, Eddy County, New Mexico, Carlsbad City, New Mexico, Hobbs 
 

 D-22 

1 City, New Mexico, and Lea County New Mexico. Revised August 16, 2010. Available at 

2 http://quickfacts.census.gov/. Accessed September 21, 2010. ADAMS Accession No. ML 

3 112920332.

4 (USCB,2010e) U. S. Census Bureau. 2010. U. S. Census Bureau. 2010. State and County 

5 Quick Facts, New Mexico and Lea County, New Mexico, Revised August 16. Available at 

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7 ML103430126.

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10 Texas. Available at http://www.census.gov/. Accessed August 23, 2010. ADAMS Accession No. 

11 ML112920337.

12 
E-1 

1 APPENDIX E 

2 

3 TRANSPORTATION OF RADIOACTIVE MATERIALS 

4 

5 

 E-3 

1 TRANSPORTATION OF RADIOACTIVE MATERIALS 

2 E.1 Introduction 

3 This Appendix summarizes calculations that were used in making determinations within the draft 

4 EIS, related to the transportation of radioactive materials. The proposed IIFP Depleted Uranium 

5 Deconversion Plant/Fluorine Extraction Process Facility would be located in Hobbs, New 

6 Mexico. The facility would receive depleted uranium (DU) in the chemical form of DUF6 and 

7 convert it to a more stable and disposable chemical form of DUO2. The process would recover 

8 fluorine which would be available for sale on the market. The deconversion process requires 

9 transportation of the DU cylinders (full) from current storage locations at enrichment facilities, 

10 disposal of low-level radioactive waste (LLW), and possible transportation of empty DU 

11 cylinders. 

12 E.2 Radioactive Materials Transportation Analysis 

13 The DUF6 would be transported to the IIFP facility in 48Y cylinders designed for storage and 

14 transportation of DUF6. All current or proposed U.S. commercial enrichment facilities were 

15 identified as representative origins for shipments of DUF6. These are (1) Urenco USA facility 

16 just east of Eunice, New Mexico, (2) the GE-Hitachi Global Laser Enrichment (GLE) Facility 

17 north of Wilmington, North Carolina, and (3) the Areva Eagle Rock Enrichment Facility west of 

18 Idaho Falls, Idaho. The cylinders would be shipped one per 18-wheel truck. The empty DUF6

19 cylinders would be shipped back to the location of origin. In the event that cylinders are not 

20 returned, they could be disposed as LLW or filled with DUO2 and disposed as LLW. The empty 

21 cylinders are conservatively assumed to be shipped one per truck, consistent with IIFP data; 

22 however, two per truck is also a likely scenario. 

23 The DUO2 is assumed to be waste. It would be packaged into 55-gallon drums and loaded 

24 40 per truck (subject to weight limitations). Shipment destinations selected for analysis are the 

25 EnergySolutions Clive, Utah facility and the Waste Control Specialists (WCS) facility on the 

26 Texas-New Mexico border west of Andrews, Texas (immediately east of the Urenco USA 

27 facility). 

28 Process LLW (low-level waste resulting from the deconversion process) and miscellaneous 

29 LLW (low-level waste incidental to the deconversion process) volumes would be small 

30 compared to the DUO2 waste. The radioactivity in most of this waste would likely be less 

31 concentrated than the DUO2 waste. The process and miscellaneous LLW also would be 

32 packaged into 55-gallon drums, loaded 40 per truck, and shipped to the same disposal facilities 

33 as the DUO2 waste. Decommissioning waste would be similar to miscellaneous LLW and would 

34 be packaged into 55-gallon drums, loaded 40 per truck, and shipped to the same disposal 

35 facilities as the LLW and DUO2 waste. 

36 Routing characteristics, including distances travelled, population density along the route, and 

37 stop time for crew breaks and inspecting the cargo were generated by the TRAGIS Code, 

38 Version 1.5.4 (Johnson and Michelhaugh, 2003). Radiological impacts from radioactive material 

39 shipments were calculated using the RADTRAN Code, Version 5.6 (Wiener et. al, 2006). 

40 Input parameters for the transportation analysis were obtained from IIFP (IIFP, 2011), 

41 NUREG-0170 (NRC, 1977), and the Louisiana Energy Services (LES) Gas Centrifuge Facility 

42 License Application (REF) and are provided in Tables E-1 and E-3. The numbers of shipments 
 E-4 

1 and relative travel distances were provided by IIFP (IIFP, 2011a)) and accident frequency and 

2 severity were provided by NUREG-0170 (NRC, 1977). Dimensions of packages and similar 

3 information presented in Tables E-1 and E-2 were from the LES Environmental Impact 

4 Statement (NRC, 2005). State-specific accident and fatality rates are from Table 4 of the study, 

5 State-Level Accident Rates for Surface Freight Transportation: A Reexamination (Saricks and 

6 Tompkins, 1999). 

7 The RADTRAN results and the Microsoft Excel calculations are provided in E-4 through E-9. 

8 
 E-5 

Table E-1A. Input Parameters for 48Y Cylinders (Part 1 of 3) 

Parameter Description Input Parameters

Title of Project Truck transport of Empty/Full 48Y DUF6 Cylinder to Destination 

Accident Options Incident Free, Accident 

Output Level 1 

Health Effects Rem/Person-rem 

Package Parameters Source 

Package Name 48Y-Cylinder Appendix D, Table D-4, LES 

EIS

Long Dimension (m) 3.73 Appendix D, Table D-4, LES 

EIS

Dose Rate (mrem/h) 

 Full DUF6 Cylinders 2.80 x 10-1 mrem/hr @ 1 meter Appendix D, Table D-7, LES 

EIS

 Empty DUF6 Cylinders 1.00 mrem/hr @ 1 meter Appendix D, Table D-7, LES 

EIS

Gamma Fraction 1 RADTRAN Default

Neutron Fraction 0 RADTRAN Default

Radionuclide Parameters 

Package Name 48Y-Cylinder 

Radionuclide See Inventory 

Physical/Chemical Group Powder for solids and Gas for 

Radon 

Curies See Inventory 

Vehicle Parameters Source 

Vehicle Name Vehicle-1 

Number of Shipments 1 User Defined Value 

Vehicle Size (m) 3.73 same as package size 

Vehicle Dose Rate (mrem/h) same as package dose rate 

Gamma Fraction 1 RADTRAN Default 

Neutron Fraction 0 RADTRAN Default 

Crew Size 2 NUREG 0170 

Crew Distance 3.1 NUREG 0170 

Crew Shielding Factor 1 NUREG 0170 

Crew View 1.22 Appendix D, Table D-4, LES 

EIS 

Exclusive Use Yes RADTRAN Default 

Package 48Y-Cylinder User Defined Value 

Number of Packages 1 User Defined Value 

1 
 E-6 

Table E-1B. Input Parameters for 48Y Cylinders (Part 2 of 3) 

Parameter Description Input Parameters

Link Parameters Source 

Link Name

Vehicle Name Vehicle-1 Vehicle-1 Vehicle-1 

Length (km) Route specific, see TRAGIS output TRAGIS output

Speed (km/h) 88.49 40.25 24.16 NUREG 0170

Population Density 

(persons/km2

)

Route specific, see TRAGIS output TRAGIS output

Vehicle Density (Vehicles/h) 470 780 2800 NUREG 0170

Persons per Vehicle 2 2 2 NUREG 0170

Accident Rate (accidents/veh-km) State specific values Saricks and Tompkins, 1999, 

Table 4

Fatalities Per Accident State specific values Saricks and Tompkins, 1999, 

Table 4

Zone Rural Suburban Urban RADTRAN Default 

Type Primary Highway Primary Highway 

Primary Highway 

RADTRAN Default

Farm Fraction 0 0 0 RADTRAN Default

Stop Parameters Source 

Stop Name Stop-1 

Vehicle Name Vehicle-1

Minimum Distance 20 NUREG 0170

Maximum Distance 20 NUREG 0170

People or People/km2 50 NUREG 0170

Shielding Factor 1 RADTRAN Default 

Time (h) 4 TRAGIS output

Handling Parameters

Handle Name Handle-1 

Vehicle Name Vehicle-1 

Number of Handlers 4 NUREG 0170 (2 handlers at 

the shipping and 2 handlers 

receiving end of the route) 

Distance (m) 1 NUREG 0170 

Time (h) 0.25 NUREG 0170 (15 minutes) 
 E-7 

1 2 

Table E-1C. Input Parameters for 48Y Cylinders (Part 3 of 3) 

Parameter Description Input ParametersAccident Parameters 

Probability Parameters 

Probability Index 0 1 2 3 4 5 6 7 NUREG 0170 Probability Fraction 0.55 0.36 0.07 0.016 0.0028 0.0011 8.50 

x 10 -5

1.50 x 10 -5

NUREG 0170

Deposition Velocity Parameters

Physical/Chemical Group Powder Gas Deposition Velocity (m/s) 0.01 0 

Release Parameters 

Physical/Chemical Group Powder Probability Index 0 1 2 3 4 5 6 7 NUREG 0170 Release Fraction 0 0.01 0.1 1 1 1 1 1 NUREG 0170 

Gas 

Probability Index 0 1 2 3 4 5 6 7 NUREG 0170Release Fraction 0 1 1 1 1 1 1 1 User defined 

value 

Aerosol Parameters

Physical/Chemical Group Powder and Gas Probability Index 0 1 2 3 4 5 6 7 NUREG 0170Aerosol Fraction 1 1 1 1 1 1 1 1 NUREG 0170

Respirable Parameters

Physical/Chemical Group Powder and Gas Probability Index 0 1 2 3 4 5 6 7 NUREG 0170Respirable Fraction 1 1 1 1 1 1 1 1 NUREG 0170Balance of RADTRAN Inputs RADTRAN Defaults 
 E-8 

Table E-2A. Input Parameters for 55-Gallon Drums (Part 1 of 3) 

Parameter Description Input Parameters

Title of Project Truck transport of 55-Gallon-Drums of DUO2/Other Waste to 

Destination 

Accident Options Incident Free, Accident 

Output Level 1 

Health Effects Rem/Person-rem 

 

Package Parameters 

Package Name 55-Gallon-Drum 

Long Dimension (m) 0.88 

Dose Rate (mrem/h) 

 DUO2 Waste 1.93 x 10-1 mrem/hr @ 

1 meter 

Response to RAI 5, Table RAI 

5-e-1

 Other Waste 3.05 x 10-2 mrem/hr @ 

1 meter 

Response to RAI 5, Table RAI 

5-e-1 (weighted average of all 

except DUO2) 

 Other Waste 9.45 x 10 -4 mrem/hr @ 

1 meter 

Response to RAI 5, Table RAI 

5-e-1 (Minimum dose rate)

Gamma Fraction 1 RADTRAN Default

Neutron Fraction 0 RADTRAN Default

Radionuclide Parameters 

Package Name 55_Gallon_Drum 

Radionuclide See Inventory 

Physical/Chemical Group Powder for solids and Gas for 

Radon 

Curies See Inventory 

Vehicle Parameters 

Vehicle Name Vehicle_1 

Number of Shipments 1 User Defined Value 

Vehicle Size (m) 12.2 the length of 20 55-gallon 

drums (assuming the drums 

are arranged 20 x 2) 

Vehicle Dose Rate (mrem/h) 6.00 x 10-2 same as package dose rate 

Gamma Fraction 1 RADTRAN Default 

Neutron Fraction 0 RADTRAN Default 

Crew Size 2 NUREG 0170 

Crew Distance 3.1 NUREG 0170 

1 
 E-9 

1 

Table E-2A. Input Parameters for 55-Gallon Drums (con’t.) (Part 1 of 3) 

Parameter Description Input Parameters

Vehicle Parameters (con’t.)

Crew Shielding Factor 1 NUREG 0170 

Crew View 1.22 the width of 2 55-gallon drums 

Exclusive Use Yes RADTRAN Default 

Package 55_Gallon_Drum User Defined Value 

Number of Packages 40 User Defined Value 

2 

3 
 E-10 

1 

2 

Table E-2B. Input Parameters for 55-Gallon Drums (Part 2 of 3) 

Parameter Description Input Parameters

Link Parameters 

Link Name

Vehicle Name Vehicle-1 Vehicle-1 Vehicle-1

Length (km) Route specific, see TRAGIS output TRAGIS output

Speed (km/h) 88.49 40.25 24.16 NUREG 0170

Population Density 

(persons/km2

)

Route specific, see TRAGIS output TRAGIS output

Vehicle Density (Vehicles/h) 470 780 2800 NUREG 0170

Persons per Vehicle 2 2 2 NUREG 0170

Accident Rate (accidents/veh-km) State specific values Saricks and Tompkins, 1999, 

Table 4

Fatalities Per Accident State specific values Saricks and Tompkins, 1999, 

Table 4

Zone Rural Suburban Urban RADTRAN Default 

Type Primary 

Highway 

Primary 

Highway 

Primary 

Highway 

RADTRAN Default

Farm Fraction 0 0 0 RADTRAN Default

Stop Parameters 

Stop Name Stop-1 

Vehicle Name Vehicle-1

Minimum Distance 20 NUREG 0170

Maximum Distance 20 NUREG 0170

People or People/km2 50 NUREG 0170

Shielding Factor 1 RADTRAN Default 

Time (h) 4 TRAGIS output

Handling Parameters

Handle Name Handle-1 

Vehicle Name Vehicle-1 

Number of Handlers 4 NUREG 0170 (2 handlers at 

the shipping and 2 handlers 

receiving end of the route) 

Distance (m) 1 NUREG 0170 

Time (h) 0.25 NUREG 0170 (15 minutes) 

3 

4 
E-11 

Table E-2C. Input Parameters for 55-Gallon Drums (Part 3 of 3) Parameter Description Input ParametersAccident Parameters 

Probability Parameters 

Probability Index 0 1 2 3 4 5 6 7 NUREG 0170 Probability Fraction 0.55 0.36 0.07 0.016 0.0028 0.0011 8.50 

x 10 -5

1.50 x 10 -5

NUREG 0170

Deposition Velocity Parameters

Physical/Chemical Group Powder Gas Deposition Velocity (m/s) 0.01 0 

Release Parameters 

Physical/Chemical Group Powder Probability Index 0 1 2 3 4 5 6 7 NUREG 0170 Release Fraction 0 0.01 0.1 1 1 1 1 1 NUREG 0170 

Gas 

Probability Index 0 1 2 3 4 5 6 7 NUREG 0170Release Fraction 0 1 1 1 1 1 1 1 User defined 

value 

Aerosol Parameters

Physical/Chemical Group Powder and Gas Probability Index 0 1 2 3 4 5 6 7 NUREG 0170Aerosol Fraction 1 1 1 1 1 1 1 1 NUREG 0170

Respirable Parameters

Physical/Chemical Group Powder and Gas Probability Index 0 1 2 3 4 5 6 7 NUREG 0170Respirable Fraction 1 1 1 1 1 1 1 1 NUREG 0170Balance of RADTRAN Inputs RADTRAN Defaults 

1 2 
E-12 

1 

Table E-3. Number of Shipments 

Phase 1 Phase 2 Cumulative 

Full DUF6 Cylinders each from Urenco USA, GLE Facility, and Areva Eagle 

Rock 293 635 928 

Empty DUF6 Cylinders each to Urenco USA, GLE Facility, and Areva Eagle 

Rock 293 496 789 

DUO2 each to Energy Solutions and WCS 155 295 476 Miscellaneous Waste each to EnergySolutions and WCS 31 20 51 Decommissioning Waste each to EnergySolutions and WCS 64 Values from Table 3-2 of IIFP, 2011 

2 
E-13 

1 

Table E-4. Incident Free RADTRAN Output 

Incident Free Transportation Impacts (Person-Rem) 

Crew Off Link On Link Totals Handling Stops 

Full DUF6 Cylinders from Urenco USA 1.03 x 10 -4 9.95 x 10 -7 1.09 x 10 -5 1.15 x 10 -4 8.02 x 10 -4 a Full DUF6 Cylinders from GLE Facility 6.96 x 10 -3 2.88 x 10 -4 2.01 x 10 -3 9.26 x 10-3 8.02 x 10 -4 1.01 x 10 -3Full DUF6 Cylinders from Areva Eagle Rock 6.13 x 10 -3 1.66 x 10 -4 1.63 x 10 -3 7.93 x 10 -3 8.02 x 10 -4 1.01 x 10 -3Empty DUF6 Cylinders to Urenco USA 3.68 x 10 -4 3.55 x 10 -6 3.88 x 10 -5 4.10 x 10 -4 2.86 x 10 -3 a Empty DUF6 Cylinders to GLE 2.49 x 10 -2 1.03 x 10 -3 7.18 x 10 -3 3.31 x 10 -2 2.86 x 10 -3 3.59 x 10 -3Empty DUF6 Cylinders to Areva Eagle Rock 2.19 x 10 -2 5.92 x 10 -4 5.84 x 10 -3 2.83 x 1 0 -2 2.86 x 10 -3 3.59 x 10 -3DUO2 to EnergySolutions 3.95 x 10 -3 3.32 x 10 -4 3.60 x 10 -3 7.88 x 10 -3 1.11 x 10 -2 1.86 x 10 -3DUO2 to WCS 7.09 x 10 -5 2.15 x 10 -6 2.35 x 10 -5 9.66 x 10 -5 1.11 x 10 -2 a Miscellaneous Waste to EnergySolutions 1.93 x 10 -5 1.63 x 10 -6 1.76 x 10 -5 3.86 x 10 -5 5.44 x 10 -5 9.13 x 10 -6Miscellaneous Waste to WCS 3.47 x 10 -7 1.05 x 10 -8 1.15 x 10 -7 4.73 x 10 -7 5.44 x 10 -5Miscellaneous Waste to EnergySolutions 6.24 x 10 -4 5.25 x 10 -5 5.69 x 10 -4 1.25 x 10-3 1.76 x 10-3 2.95 x 10 -4Miscellaneous Waste to WCS 1.12 x 10 -5 3.40 x 10 -7 3.71 x 10 -6 1.53 x 10 -5 1.76 x 10-3 a a: A stop was not assumed since the route was short. Note: The Decommissioning Waste is the same as Miscellaneous Waste 
E-14 

Table E-5. Accident RADTRAN Output 

Accident Transportation Impacts (Person-Rem) 

Ground Inhaled Resuspended Cloudshine Total 

Full DUF6 Cylinders from Urenco USA 2.89 x 10 -8 4.25 x 10 -6 5.37 x 10 -9 3.84 x 10 -12 4.29 x 10 -6Full DUF6 Cylinders from GLE Facility 9.84 x 10 -5 1.45 x 10-2 1.83 x 10 -5 1.31 x 10 -8 1.46 x 10 -2Full DUF6 Cylinders from Areva Eagle Rock 7.30 x 10 -5 1.07 x 10-2 1.35 x 10 -5 9.67 x 10 -9 1.08 x 10 -2Empty DUF6 Cylinders to Urenco USA 2.90 x 10 -10 1.54 x 10 -8 2.31 x 10 -11 3.32 x 10 -12 1.57 x 10 -8Empty DUF6 Cylinders to GLE 9.79 x 10 -7 5.19 x 10 -5 7.80 x 10 -8 1.12 x 10 -8 5.29 x 10 -5Empty DUF6 Cylinders to Areva Eagle Rock 7.31 x 10 -7 3.87 x 10 -5 5.83 x 10 -8 8.36 x 10 -9 3.95 x 10 -5DUO2 to EnergySolutions 1.39 x 10 -4 2.17 x 10-2 2.61 x 10 -5 1.96 x 10 -8 2.19 x 10 -2DUO2 to WCS 5.18 x 10 -8 8.12 x 10 -6 9.74 x 10 -9 7.32 x 10 -12 8.18 x 10 -6Miscellaneous Waste to EnergySolutions (Low TI) 1.32 x 10 -6 1.05 x 10 -4 8.73 x 10 -7 7.44 x 10 -11 1.07 x 10 -4Miscellaneous Waste to WCS (Low TI) 4.95 x 10 -10 3.91 x 10 -8 3.27 x 10 -10 2.78 x 10 -14 3.99 x 10 -8Miscellaneous Waste to EnergySolutions 1.32 x 10 -6 1.05 x 10 -4 8.73 x 10 -7 7.44 x 10 -11 1.07 x 10 -4Miscellaneous Waste to WCS 4.95 x 10 -10 3.91 x 10 -8 3.27 x 10 -10 2.78 x 10 -14 3.99 x 10 -8Note: The Decommissioning Waste is the same as Miscellaneous Waste 
E-15 

1 

Table E-6. Phase 1 Collective Doses to Various Receptors from Radiological Transportation 

 General Public 

Drivers and 

Passengers Persons at Stops Truck Drivers Package Handlers 

PersonSv Person- rem Person- Sv Person- rem Person- Sv Person- rem Person- Sv Person- rem Person- Sv Person- rem 

Full DUF6 Cylinders from Urenco USA 2.9 x 10 -6 2.9 x 10 -4 3.2 x 10 -5 3.2 x 10 -3 a a 3.0 x 10 -4 3.0 x 10 -2 2.3 x 10 -3 2.3 x 10 -1Full DUF6 Cylinders from GLE Facility 8.4 x 10 -4 8.4 x 10 -2 5.9 x 10 -3 5.9 x 10 -1 3.0 x 10 -3 3.0 x 10 -1 2.0 x 10 -2 2.0 2.3 x 10 -3 2.3 x 10 -1Full DUF6 Cylinders from Areva Eagle Rock 4.9 x 10 -4 4.9 x 10 -2 4.8 x 10 -3 4.8 x 10 -1 3.0 x 10 -3 3.0 x 10 -1 1.8 x 10 -2 1.8 2.3 x 10 -3 2.3 x 10 -1Empty DUF6 Cylinders to Urenco USA 1.0 x 10 -5 1.0 x 10 -3 1.1 x 10 -4 1.1 x 10 -2 a a 1.1 x 10 -3 1.1 x 10 -1 8.4 x 10 -3 8.4 x 10 -1Empty DUF6 Cylinders to GLE 3.0 x 10 -3 3.0 x 10 -1 2.1 x 10- 2 2.1 1.1 x 10 -2 1.1 7.3 x 10 -2 7.3 8.4 x 10 -3 8.4 x 10 -1Empty DUF6 Cylinders to Areva Eagle Rock 1.7 x 10 -3 1.7 x 10 -1 1.7 x 10 -2 1.7 1.1 x 10 -2 1.1 6.4 x 10 -2 6.4 8.4 x 10 -3 8.4 x 10 -1DUO2 to EnergySolutions 5.1 x 10 -4 5.1 x 10 -2 5.6 x 10 -3 5.6 x 10 -1 2.9 x 10 -3 2.9 x 10 -1 6.1 x 10 -3 6.1 x 10 -1 1.7 x 10 -2 1.7 DUO2 to WCS 3.3 x 10 -6 3.3 x 10 -4 3.6 x 10 -5 3.6 x 10 -3 a a 1.1 x 10 -4 1.1 x 10 -2 1.7 x 10 -2 1.7 Miscellaneous Waste to EnergySolutions 1.6 x 10 -5 1.6 x 10 -3 1.8 x 10 -4 1.8 x 10 -2 9.1 x 10 -5 9.1 x 10-3 1.9 x 10 -4 1.9 x 10 -2 5.5 x 10 -4 5.5 x 10 -2Miscellaneous Waste to WCS 1.1 x 10 -7 1.1 x 10 -5 1.2 x 10 -6 1.2 x 10 -4 a a 3.5 x 10 -6 3.5 x 10 -4 5.5 x 10 -4 5.5 x 10 -2DUO2 and Misc to EnergySolutions 5.3 x 10 -4 5.3 x 10 -2 5.8 x 10 -3 5.8 x 10 -1 3.0 x 10-3 3.0 x 10-1 6.3 x 10-3 6.3 x 10 -1 1.8 x 10 -2 1.8 DUO2 and Misc to WCS 3.4 x 10 -6 3.4 x 10 -4 3.8 x 10 -5 3.8 x 10 -3 a a 1.1 x 10 -4 1.1 x 10 -2 1.8 x 10 -2 1.8 Greatest risk scenario 4.4 x 10-3 4.4 x 10-1 3.3 x 10-2 3.3 1.6 x 10-2 1.6 1.0 x 10-1 1.0 x 10 2.8 x 10-2 2.8 
E-16 

1 

Table E-7. Phase 2 Incremental Collective Doses to Various Receptors from Radiological Transportation 

General Public Drivers and Passengers Persons at Stops Truck Drivers Package Handlers 

Person-Sv 

Personrem Person-Sv Person-rem Person-Sv Person- rem Person-Sv Person-rem Person-Sv Person- rem 

Full DUF6 Cylinders from Urenco USA 6.3 x 10 -6 6.3 x 10 -4 6.9 x 10 -5 6.9 x 10-3 A a 6.5 x 10 -4 6.5 x 10-2 5.1 x 10 -3 5.1 x 10 -1Full DUF6 Cylinders from GLE Facility 1.8 x 10 -3 1.8 x 10-1 1.3 x 10 -2 1.3 6.4 x 10 -3 6.4 x 10-1 4.4 x 10 -2 4.4 5.1 x 10 -3 5.1 x 10 -1Full DUF6 Cylinders from Areva Eagle 

Rock 1.1 x 10 -3 1.1 x 10-1 1.0 x 10 -2 1.0 6.4 x 10 -3 6.4 x 10-1 3.9 x 10 -2 3.9 5.1 x 10 -3 5.1 x 10 -1

Empty DUF6 Cylinders to Urenco USA 1.8 x 10 -5 1.8 x 10-3 1.9 x 10 -4 1.9 x 10-2 A a 1.8 x 10 -3 1.8 x 10-1 1.4 x 10 -2 1.4 Empty DUF6 Cylinders to GLE 5.1 x 10 -3 5.1 x 10-1 3.6 x 10 -2 3.6 1.8 x 10 -2 1.8 1.2 x 10 -1 1.2 x 10 1.4 x 10 -2 1.4 Empty DUF6 Cylinders to Areva Eagle 

Rock 2.9 x 10 -3 2.9 x 10-1 2.9 x 10 -2 2.9 1.8 x 10 -2 1.8 1.1 x 10 -1 1.1 x 10 1.4 x 10 -2 1.4 

DUO2 to EnergySolutions 9.8 x 10 -4 9.8 x 10-2 1.1 x 10 -2 1.1 5.5 x 10 -3 5.5 x 10-1 1.2 x 10 -2 1.2 3.3 x 10 -2 3.3 DUO2 to WCS 6.3 x 10 -6 6.3 x 10 -4 6.9 x 10 -5 6.9 x 10-3 A a 2.1 x 10 -4 2.1 x 10-2 3.3 x 10 -2 3.3 Miscellaneous Waste to EnergySolutions 1.1 x 10 -5 1.1 x 10-3 1.1 x 10 -4 1.1 x 10-2 5.9 x 10 -5 5.9 x 10-3 1.2 x 10 -4 1.2 x 10-2 3.5 x 10 -4 3.5 x 10 -2Miscellaneous Waste to WCS 6.8 x 10 -8 6.8 x 10 -6 7.4 x 10 -7 7.4 x 10 -5 a a 2.2 x 10 -6 2.2 x 10 -4 3.5 x 10 -4 3.5 x 10 -2
E-17 

Table E-8. Cumulative Collective Doses to Various Receptors from Radiological Transportation 

General Public Drivers and Passengers Persons at Stops Truck Drivers Package Handlers 

Person-Sv 

Personrem Person-Sv Person-rem Person-Sv Person- rem Person-Sv Person- rem Person- Sv Person- rem 

Full DUF6 Cylinders from Urenco USA 9.2 x 10 -6 9.2 x 10 -4 1.0 x 10 -4 1.0 x 10-2 a a 9.6 x 10 -4 9.6 x 10-2 7.4 x 10-3 7.4 x 10-1Full DUF6 Cylinders from GLE Facility 2.7 x 10-3 2.7 x 10-1 1.9 x 10-2 1.9 9.4 x 10-3 9.4 x 10-1 6.5 x 10-2 6.5 7.4 x 10-3 7.4 x 10-1Full DUF6 Cylinders from Areva Eagle 

Rock 1.5 x 10-3 1.5 x 10-1 1.5 x 10-2 1.5 9.4 x 10-3 9.4 x 10-1 5.7 x 10-2 5.7 7.4 x 10-3 7.4 x 10-1

Empty DUF6 Cylinders to Urenco 

USA 2.8 x 10 -5 2.8 x 10-3 3.1 x 10 -4 3.1 x 10-2 a a 2.9 x 10-3 2.9 x 10-1 2.3 x 10-2 2.3 

Empty DUF6 Cylinders to GLE 8.1 x 10-3 8.1 x 10-1 5.7 x 10-2 5.7 2.8 x 10-2 2.8 2.0 x 10-1 2.0 x 10 2.3 x 10-2 2.3 Empty DUF6 Cylinders to Areva Eagle 

Rock 4.7 x 10-3 4.7 x 10-1 4.6 x 10-2 4.6 2.8 x 10-2 2.8 1.7 x 10-1 1.7 x 10 2.3 x 10-2 2.3 

DUO2 to Energy Solutions 1.6 x 10-3 1.6 x 10-1 1.7 x 10-2 1.7 8.9 x 10-3 8.9 x 10-1 1.9 x 10-2 1.9 5.3 x 10-2 5.3 DUO2 to WCS 1.0 x 10 -5 1.0 x 10-3 1.1 x 10 -4 1.1 x 10-2 a a 3.4 x 10 -4 3.4 x 10-2 5.3 x 10-2 5.3 Miscellaneous Waste to EnergySolutions 2.7 x 10 -5 2.7 x 10-3 2.9 x 10 -4 2.9 x 10-2 1.5 x 10 -4 1.5 x 10-2 3.2 x 10 -4 3.2 x 10-2 9.0 x 10 -4 9.0 x 10-2Miscellaneous Waste to WCS 1.7 x 10 -7 1.7 x 10 -5 1.9 x 10 -6 1.9 x 10 -4 a a 5.7 x 10 -6 5.7 x 10 -4 9.0 x 10 -4 9.0 x 10-2Decommissioning Waste to EnergySolutions 3.4 x 10 -5 3.4 x 10-3 3.6 x 10 -4 3.6 x 10-2 1.9 x 10 -4 1.9 x 10-2 4.0 x 10 -4 4.0 x 10-2 1.1 x 10-3 1.1 x 10-1Decommissioning Waste to WCS 2.2 x 0 -7 2.2 x 10 -5 2.4 x 10 -6 2.4 x 10 -4 a a 7.2 x 10 -6 7.2 x 10 -4 1.1 x 10-3 1.1 x 10-1DUO2 and Misc to EnergySolutions 1.6 x 10-3 1.6 x 10-1 1.7 x 10-2 1.7 9.0 x 10-3 9.0 x 10-1 1.9 x 10-2 1.9 5.4 x 10-2 5.4 DUO2 and Misc to WCS 1.0 x 10 -5 1.0 x 10-3 1.1 x 10 -4 1.1 x 10-2 a a 3.4 x 10 -4 3.4 x 10-2 5.4 x 10-2 5.4 Greatest risk scenario 1.2 x 10--2 1.2 9.3 x 10--2 9.3 4.7 x 10--2 4.7 2.8 x 10-1 2.8 x 10 8.4 x 10--2 8.4 
E-18 

Table E-9. Annual Accident Dose-Risk and LCF-Risk from Radiological Transportation 1 

 Dose-Risk LCF Risk 

Person-Sv Person-rem 

Full DUF6 Cylinders from Urenco USA 1.3 x 10 -5 1.3 x 10-3 7.5 x 10 -7Full DUF6 Cylinders from GLE Facility 4.3 x 10-2 4.3 2.6 x 10-3Full DUF6 Cylinders from Areva Eagle Rock 3.2 x 10-2 3.2 1.9 x 10-3Empty DUF6 Cylinders to Urenco USA 4.6 x 10 -8 4.6 x 10 -6 2.8 x 10 -9Empty DUF6 Cylinders to GLE 1.5 x 10 -4 1.5 x 10-2 9.3 x 10 -6Empty DUF6 Cylinders to Areva Eagle Rock 1.2 x 10 -4 1.2 x 10-2 6.9 x 10 -6DUO2 to EnergySolutions 6.4 x 10-2 6.4 3.9 x 10-3DUO2 to WCS 2.4 x 10 -5 2.4 x 10-3 1.4 x 10 -6Miscellaneous Waste to EnergySolutions 3.1 x 10 -4 3.1 x 10-2 1.9 x 10 -5Miscellaneous Waste to WCS 1.2 x 10 -7 1.2 x 10 -5 7.0 x 10 -9Decommissioning Waste to EnergySolutionsa 3.1 x 10 -4 3.1 x 10-2 1.9 x 10 -5Decommissioning Waste to WCSa 1.2 x 10 -7 1.2 x 10 -5 7.0 x 10 -9Greatest Risk Scenario 1.1 x 10-1 1.1 x 10 6.4 x 10-3Note: latent cancer fatalities per person rem (ISCORS, 2002) = 6.00 x 10 -4

a. Represents total campaign – not annual 2 

3 
 E-19 

1 E.3 References 

2 (IIFP, 2011) International Isotopes Fluorine Products. 2011. Fluorine Extraction Process and 

3 Depleted Uranium De-conversion Plant (FEP/DUP) Official Responses to Environmental Report 

4 RAIs, Revision A. March 31, 2011. ADAMS Accession No. ML110970481. 

5 (ISCORS, 2002) Interagency Steering Committee on Radiation Standards. 2002. “A Method 

6 for Estimating Radiation Risk from Total Effective Dose Equivalent (TEDE),” ISCORS Technical 

7 Report 2002-02, Final Report, Washington, D. C. ADAMS Accession No. ML112720579. 

8 (Johnson and Michelhaugh, 2003) Johnson, P. E. and R. D. Michelhaugh. 2003. 

9 Transportation Routing Analysis Geographic Information System (TRAGIS) User’s Manual. Oak 

10 Ridge National Laboratory, Oak Ridge, Tennessee. June, 2003. 

11 (NRC, 1977) U.S. Nuclear Regulatory Commission. 1977. Final Environmental Statement on 

12 the Transportation of Radioactive Material by Air and Other Modes, NUREG-0170, Office of 

13 Standards Development, December 1977. 

14 (NRC, 2005) U.S. Nuclear Regulatory Commission. 2005. Final Environmental Impact 

15 Statement for the Proposed National Enrichment Facility in Lea County, New Mexico / NUREG 

16 – 1790, June 2005. ADAMS Accession No. ML051730238. 

17 (Saricks and Tompkins, 1999) Saricks, C.L. and M.M. Tompkins. 1999 State-Level Accident 

18 Rates for Surface Freight Transportation: A Reexamination, ANL/ESD/TM-150, Argonne 

19 National Laboratory, April, 1999. ADAMS Accession No. ML112720605. 

20 (Wiener et. al, 2006) Wiener R. F., D. M. Osborn, G.S. Mills, D. Hinojosa, T. L. Heames, and 

21 D. J. Orcutt. 2006. “RadCat 2.3 User Guide.” SAND2006-6315, Sandia National Laboratories, 

22 Albuquerque, New Mexico.

BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse)

NRC FORM 335

(12-2010)

NRCMD 3.7

U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

 (Assigned by NRC, Add Vol., Supp., Rev.,

 and Addendum Numbers, if any.)

NUREG-2113

3. DATE REPORT PUBLISHED

MONTH

December

YEAR

2011

4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE

Environmental Impact Statement for the Proposed Fluorine Extraction Process and Depleted

Uranium Deconversion Plant in Lea County, New Mexico 

Draft Report for Comment

5. AUTHOR(S)

See Chapter 10

6. TYPE OF REPORT

Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor,

Division of Waste Management and Environmental Protection

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above"; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission, 

provide name and mailing address.)

and mailing address.)

10. SUPPLEMENTARY NOTES

11. ABSTRACT (200 words or less)

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

license application to the U.S. Nuclear Regulatory Commission (NRC) to construct, operate, and decommission Phase 1 of a

fluorine extraction and depleted uranium deconversion facility in Lea County, New Mexico. The proposed facility would provide

services to the uranium enrichment industry, which makes fuel for nuclear power reactors. The IIFP facility would deconvert

depleted uranium hexafluoride into fluoride products for commercial resale, and depleted uranium oxides for disposal. The

license application for Phase 1 requests NRC to license the possession of up to 750,000 kilograms (827 tons) of depleted

uranium under Title 10 "Energy" of the U.S. Code of Federal Regulations (10 CFR) Part 40, "Domestic Licensing of Source

Material" in accordance with the Atomic Energy Act of 1954.

This draft Environmental Impact Statement (EIS) was prepared in compliance with the National Environmental Policy Act (NEPA)

and the NRC regulations for implementing NEPA (10 CFR 51). This draft EIS evaluates the potential environmental impacts of

the proposed action, which is to construct, operate, and decommission Phase 1 of the fluorine extraction and depleted uranium

deconversion facility, and its reasonable alternatives, and describes IIFP's monitoring program and proposed mitigation

measures.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

EIS for the Proposed Fluorine Extraction Process and Depleted Uranium Deconversion Plant in Lea

County, New Mexico.

NUREG-2113

National Environmental Policy Act

NEPA

IIFP

International Isotopes

Depleted Uranium Hexafluoride

International Isotopes Fluorine Products, Inc.

14. SECURITY CLASSIFICATION

13. AVAILABILITY STATEMENT

unlimited

(This Page)

unclassified

(This Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (12-2010)

Office of Federal and State Materials and Environmental Management Programs

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

Same as 8 above




UNITED STATES 

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

--------------------

OFFICIAL BUSINESS
 

 

NUREG-2113

Draft

Environmental Impact Statement for the Proposed Fluorine Extraction Process 

and Depleted Uranium Deconversion Plant in Lea County, New Mexico