International Isotopes Fluorine Products, Inc. 

(IIFP) 

A Wholly Owned Subsidiary of 

International Isotopes, Inc.

Fluorine Extraction Process & 

Depleted Uranium De-conversion 

Plant (FEP/DUP) 

Request for Additional 

Information to the 

Environmental Report 

Revision A 

February 16, 2011 
Environmental Report 

Environmental Report Request for Additional Information Page ii of 186

TABLE OF CONTENTS 

RAI Number Nature of RAI Page Number 

RAI 1 Provide description of preconstruction and construction activities and their associated impacts. 

1-a Provide definite preconstruction activities. 1 

1-b Separate preconstruction from construction activities. 7 

1-c Provide schedule for preconstruction activities. 13 

RAI 2 Provide Phase 1 and Phase 2 activities and impacts separately. 

2-a Confirm Proposed Action consists only of Phase 1. 15 

2-b Provide Phase 1, Phase 2, and cumulative impacts. 20 

2-c Describe Phase 2 construction activities. 43 

RAI 3 Provide additional information regarding taxes during construction and operation of the IIFP. 

3-a Provide descriptions of agreements, abatements, fees-in-lieu-of taxes. 45 

3-b Provide more details of incentive package. 46 

3-c Provide estimated property tax payments during construction. 47 

3-d Identify taxing entities and percentage of payments to entities. 48 

3-e Provide estimated property tax payments during operations. 50 

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

4-a Clarify whether replacement capital costs are construction or 

operations costs. 51 

4-b Provide estimate of distribution of replacement expenditures 

over/between Phase 1 and Phase 2 increment. 52 

4-c Provide the cost of raw materials. 53 

4-d Provide the utilities cost for Phase 1 and for Phase 2 increment. 54 

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

for Phase 1 and Phase 2 increment. 55 

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

and Phase 2 increment. 56 

4-g Clarify Phase 1 and Phase 2 increment costs for waste disposal. 57 

4-h Provide 2010 market value per pound of each FEP product. 58 

RAI 5 Provide clarifications and additional information regarding UO2 shipments. 

5-a Clarify packaging and number of packages per shipment for UO2

byproduct material. 59 

5-b Provide radionuclide inventory of each package and dose rate. 60 

5-c Clarify number of UO2 shipments. 61 

5-d Clarify if each of the 450 shipments contains 20-25 drums of UO2 per 

shipment. 63 

5-e Describe the shipment of “miscellaneous LLW” in terms of packages, 

numbers, and curie content. 64 

RAI 6 Provide the radionuclide inventory of an empty DUF6 cylinder 

6 Provide the activity after emptying cylinder and prior to shipment. 68 

RAI 7 Provide information regarding hydrogen generation to support the description of the proposed 

action. 

7-a Describe how hydrogen would be generated. 70 

7-b Provide the production capacity of hydrogen plant and the demand 

for hydrogen. 71 

7-c State the hydrogen storage capacity. 72 
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Environmental Report Request for Additional Information Page iii of 186

RAI Number Nature of RAI Page Number 

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

Provide the natural gas required for hydrogen generation if necessary. 73 

RAI 8 Provide additional information regarding air emissions during construction. 

8-a Provide site-specific assumptions for estimated emissions from offroad construction equipment. 74 

8-b Describe on-site fueling of gasoline and diesel vehicles. 77 

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

activities. 78 

RAI 9 Provide additional information regarding air emissions during operations. 

9-a Describe representative capacity of gas-fired boilers and source of 

data used for boiler emissions. 82 

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

estimate emissions. 84 

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

model and modeling assumptions. 87 

9-d Provide stack parameter assumptions. 102 

9-e Provide the 5-years of hourly data from Midland-Odessa station. 105 

RAI 10 Provide additional information regarding accident analyses. 

10 Describe the release rates required to exceed consequence levels. 110 

RAI 11 Provide additional information regarding groundwater. 

11-a Provide information about existing groundwater monitoring well 

network and indicate establishment of baseline quality assessment. 112 

11-b Describe proposed site groundwater monitoring well network. 116 

11-c Describe proposed groundwater production wells. 122 

RAI 12 Provide copies of IIFP Site land surveys. 

12 Information is necessary to provide a centroid for demography, 

environmental justice, air impacts, etc. 123 

RAI 13 Provide additional information regarding employment. 

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

determined. 124 

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

benefits) for Phase 1 construction. 129 

13-c Include employment curve for Phase 1 operations overlapping with 

Phase 1 construction. 130 

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

start date, duration – employment curve. 131 

13-e Provide annualize wage (no benefits) for average Phase 2 

construction employee. 132 

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

employment curve overlapping with Phase 2 construction. 133 

RAI 14 Provide reports of ecological field studies 

14 Provide reports from surveys or quarterly summaries. 134 

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

15 IIFP may submit determination. 139 

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

16 IIFP is conducting noise level reading at the corners of the site. 145 

RAI 17 Clarify status and/or schedule of various state permits. 

17 Required permits and schedule in Table 1-4 is to be updated. 146 
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Environmental Report Request for Additional Information Page iv of 186

RAI Number Nature of RAI Page Number 

RAI 18 Provide status of radiological monitoring plan. 

18 Provide updates to Section 6.1 of ER. 159 

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

19 Provide either reference or the complete citation. 161 

RAI 20 Provide additional information on construction wastes and operations wastes. 

20-a Provide estimated quantities for Phase 1 and Phase 2 construction. 164 

20-b Clarify total Phase 1 and Phase 2 RCRA operations waste. 168 

RAI 21 Provide additional information regarding past land use of project area. 

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

as cattle grazing. 169 

21-b Provide available information concerning previous oil/gas wells, right 

of way, etc. 175 

RAI 22 Provide support for ER claim of better than industry average for occupational safety statistics. 

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

comparable work. 178 

RAI 23 Provide clarifications on mitigation measures. 

23 Separate mitigation measures into construction and operations phases. 180 

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

24 Nearest residence is approximately 1 mi from NW corner. 184 
Environmental Report 

Environmental Report Request for Additional Information Page 1 of 186

RAI 1 

Provide a description of preconstruction and construction activities and their associated impacts. 

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

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

Construction” provides a list of potential preconstruction activities). 

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

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

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

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

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

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

considered part of the proposed action. 

RESPONSE: 

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

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

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

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

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

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

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

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

preconstruction activities will be added to the Environmental Report Section 2.1.2 after the 11th

paragraph. Section 2.1.2 will be revised to read as follows: 

2.1.2 Site Construction 

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

Construction of the Phase 1 facility is expected to begin in 2012 and startup of operations in 2013. IIFP is 

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

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

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

facility construction. Potential pre-licensing construction activities may include the following:

Clearing land,

Site grading and erosion control,

Installing main entrance roadbed and drainage to highway,

Installing construction trailer,

Preparing preliminary site roadways and gravel parking area,

Potential drilling of water wells,

Constructing power substation,

Stubbing in gas line to the meter,

Beginning administration building construction,

Beginning warehouse building construction,
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Environmental Report Request for Additional Information Page 2 of 186

Installing geothermal heating/cooling loops, and

Installing firewater tanks.

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

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

activities and isare determined to have a “SMALL” impact in each of the impact areas evaluated except 

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

activities. 

Construction will occur in three four phasesstages. The first stage will involve certain pre-licensing 

construction tasks allowed under 10 CFR 40.32(e). The first second phase stage will involve certain prelicensing construction tasks based on NRC approval of the exemption request. The activities will be 

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

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

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

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

Countermeasures Plan and an NPDES Construction Stormwater Permit with the General Construction 

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

The third construction stage will begin Aafter NRC approval of the license,. general construction will 

begin and This stage will complete any unfinished pre-licensing construction activities, including 

buildings, completion of roads and pads, and installation of systems and equipment, will be completed 

and will involve the remaining construction through completion for of the Phase 1 facility. The third 

fourth construction phase stage is expected to begin in 2015 and will complete the Phase 2 facility to add 

additional DUF6 de-conversion capacity. 

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

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

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

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

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

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

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

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

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

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

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

utility companies on the site that will be investigated for use in lieu of installing new wells. 

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

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

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

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

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

electrical utility company will install an independent substation to ensure service. 
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Descriptions of the preconstruction activities are provided in Sections 2.1.2.1 through 2.1.2.16.

2.1.2.1 Site Clearing 16.2 Hectares (40 Acres)

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

Clearing encompasses an area approximately 244 m x 305 m (800 ft x 1,000 ft) inside the 16.2 ha (40-ac)

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

2.1.2.2 Pre-construction Erosion and Stormwater Run-off Control

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

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

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

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

water run-off from construction areas.

2.1.2.3 Installation of Truck Washing Station

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

with NM 483 to minimize silt carryover onto the public right-of-way.

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

Structures, Storage Pads and Roads

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

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

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

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

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

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

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

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

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

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

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

parking lot. 

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

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

(20 ft wide x 2,950 ft long), will remain through construction without a wearing coat (asphalt). Before 

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

2.1.2.6 Construction/Office Trailer Installation

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

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

equipment will be in place during construction, the construction trailer will not maintain any functional 
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Environmental Report Request for Additional Information Page 4 of 186

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

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

2.1.2.7 Electrical Substation Installation

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

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

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

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

2.1.2.8 Gas Main Installation to 16.2-Ha (40-Ac) Site

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

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

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

be installed until NRC license approval is granted.

2.1.2.9 Administrative Building Shell Construction

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

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

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

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

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

employee entrance into the controlled area.

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

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

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

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

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

24.4 m x 15.3 m (80 ft long x 50 ft wide) with eave height of 4.6 m (15 ft). The preconstruction building 

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

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

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

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

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

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

2.1.2.10 Maintenance and Stores Building Shell Construction

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

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

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

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

office area is provided for maintenance supervision and stores personnel.
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Upon completion of Architectural and Engineering design drawings, and upon approval of same by all 

authorities having jurisdiction, construction of the Maintenance and Stores Building (shell only) will 

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

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

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

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

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

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

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

fasteners, etc.

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

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

system with lay-in type lighting fixtures.

2.1.2.11 Material Warehouse Building Shell Construction 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

fasteners, etc.

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

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

system with lay-in type lighting fixtures.

2.1.2.12Temporary Fencing

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

and around each building shell for protection from vandalism. 

2.1.2.13 Facility Site Roadbeds and Gravel Parking Areas for Construction

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

divides into an intersection with two access roads, one heading north and the other heading south. These 
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Environmental Report Request for Additional Information Page 6 of 186

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

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

m [700 ft long (north to south) x 400 ft wide (east to west)]. For descriptive purposes, the four sections of 

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

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

location is the employee and visitor parking lot.

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

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

construction of the IIFP Facility is essentially complete.

2.1.2.14 Water Well Drilling

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

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

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

systems after NRC License approval.

2.1.2.15 Geothermal Heat Pump Loop Installation 

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

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

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

A total capacity of 60 tons [720,000 British Thermal Units/Hour (BTUH)] is estimated for the buildings 

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

system will be performed during detailed design.

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

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

connection to heating and cooling equipment after NRC License approval. 

2.1.2.16 Firewater Tank Installation

Just east of the East Road are located two above-ground Fire Water Tanks [379 m3 (100,000 gal each)] 

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

fire water pump, jockey pump, piping and controls. The IIFP facility fire protection system is described in 

Chapter 7, “Fire Safety,” of the License Application, including the classification of individual buildings 

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

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

and footings and foundations are designed, based upon soil core sample analysis, and approvals are 

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

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

installation of fire water tanks in the State of New Mexico.
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Environmental Report Request for Additional Information Page 7 of 186

RAI 1 

Provide a description of preconstruction and construction activities and their associated impacts. 

b. Separate preconstruction from construction activities in the ER. For example, in Section 4.10.1, 

“Facility Construction,” separate the preconstruction from the construction workforce. Another 

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

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

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

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

information. 

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

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

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

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

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

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

considered part of the proposed action. 

RESPONSE: 

Impact analyses of construction activities have been conducted for both the preconstruction and the 

construction phases stages of the IIFP Facility. In addition to the examples provided above, impact 

analyses have been performed for each of the resources described in Chapter 3. These analyses and the 

predicted impacts are described for land use (Section 4.1); transportation (Section 4.2); geology and soils 

(Section 4.3); water resources (Section 4.4); ecology (Section 4.5); meteorology, climatology, and air 

quality (Section 4.6); noise (Section 4.7); historical and cultural resources (Section 4.8); visual/scenic 

resources (Section 4.9); socioeconomic (Section 4.10); public and occupational health (Section 4.12); and 

waste management (Section 4.13). Analyses and predicted impacts regarding environmental justice also 

are presented (Section 4.11). Revisions to these sections are provided in the Environmental Report 

Documentation Impact for RAI 2.b. 

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

added to show the environmental impact for preconstruction, Phase 1 facility construction, Phase 2 

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

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

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

RAI 2.b. 

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

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

Impacts and Cumulative Effects of the Proposed License Action Combined with the Phase 2 Facility.” 

Section 2.6 will be revised to add two new paragraphs before the initial (old 1st) paragraph to introduce 

the impact analysis for all the phases of the IIFP Facility to include preconstruction, Phase 1 facility and 

Phase 2 facility construction; Phase 1 facility and Phase 2 facility operation; and decommissioning as well 

as cumulative impacts. The old 3rd paragraph will be revised to show the extent of impacts considering all 

lifecycle phases from the IIFP Facility. A new paragraph after the old 3rd paragraph will be added to 

introduce a new Table 2-7 which summarizes the environmental impacts for each of various phases of the 
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IIFP Facility (preconstruction, Phase 1 and Phase 2 construction; Phase 1 and Phase 2 operation; and 

decommissioning). Section 2.6 will be revised to read as follows: 

2.6 Environmental Impacts and Cumulative Effects of the Proposed License Action Combined 

with the Phase 2 Facility

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

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

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

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

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

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

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

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

construction and operation of the IIFP Facility (preconstruction, Phase 1facility and Phase 2 facility

construction; Phase 1facility and Phase 2 facility operation; and decommissioning). Additionally, the 

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

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

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

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

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

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

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

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

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

Phase 2 facility projected for the 2015-2016 timeframe and the potential approval by NRC to exempt 

some pre-license construction activities for the Proposed License Action has already been included in this 

ER as reasonably foreseeable actions. 

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

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

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

impacts to other more environmentally sensitive sites. 

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

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

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

combined with the Phase 2 Facility is briefly summarized below by the environmental resource that could 

be impacted. Potential environmental impacts are assessed to be SMALL, except during construction 

periods (Phase 1 and Phase 2) when MODERATE impacts for transportation on local highways may 

occur and SMALL to MODERATE impacts on transportation during both operation phases and during 

decommissioning. and tTemporary disruptions may occur in some wildlife travel corridors during 

preconstruction and Phase 1 construction resulting in a MODERATE impact for ecological resources. 

Overall, Tthe cumulative potential impacts for these two resources are SMALL. 
Environmental Report 

Environmental Report Request for Additional Information Page 9 of 186

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

Action combined with the Phase 2 Facility (preconstruction, Phase 1 and Phase 2 construction; Phase 1 

and Phase 2 operation; and decommissioning) for each of the resources described in Chapter 3. Overall, 

adverse impacts from the Proposed License Action combined with the Phase 2 Facility are anticipated to 

be SMALL. Implementation of mitigation measures will further reduce the severity of these impacts.
Environmental Report 

Environmental Report Request for Additional Information Page 11 of 186

Table 2- 7 Environmental Impacts for the IIFP Facility

Resource 

Construction Impacts Operations Impacts Decommis

Impac

Preconstruction Phase 1 Phase 2 Phase 1 Phase 2 

Land Use SMALL SMALL SMALL SMALL SMALL SMALTransportation SMALL MODERATE MODERATE SMALL to MODERATE SMALL to MODERATE SMAL

MODER

Soils SMALL SMALL SMALL SMALL SMALL SMALWater SMALL SMALL SMALL SMALL SMALL SMALEcological MODERATE MODERATE SMALL SMALL SMALL SMALAir Quality SMALL SMALL SMALL SMALL SMALL SMALNoise SMALL SMALL SMALL SMALL SMALL SMALHistorical/Cultural Resources SMALL SMALL SMALL SMALL SMALL SMALVisual/Scenic Resources SMALL SMALL SMALL SMALL SMALL SMALSocioeconomic  Population SMALL SMALL SMALL SMALL SMALL SMAL Economic SMALL SMALL SMALL SMALL SMALL SMAL Community SMALL SMALL SMALL SMALL SMALL SMALEnvironmental Justice SMALL SMALL SMALL SMALL SMALL SMALPublic & Occupational Health  Nonradiological SMALL SMALL SMALL SMALL SMALL SMAL Radiological SMALL SMALL SMALL SMALL SMALL SMAL Accidents SMALL SMALL SMALL SMALL SMALL SMALWaste Management SMALL SMALL SMALL SMALL SMALL SMAL
Environmental Report 

Environmental Report Request for Additional Information Page 12 of 186

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

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

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

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

the regulatory limit of 5 rem per year. 

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

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

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

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

Environmental Report Request for Additional Information Page 13 of 186

RAI 1 

Provide a description of preconstruction and construction activities and their associated impacts. 

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

activities relative to the anticipated issuance of the license. 

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

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

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

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

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

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

considered part of the proposed action. 

RESPONSE: 

A proposed schedule for the preconstruction activities and for the construction of the Phase 1 and Phase 2 

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

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

resources. 

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

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

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

2.1.2.17 Schedule of Preconstruction and Construction Activities

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

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

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

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

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

after NRC license approval.

Table 2-1 Proposed Schedule for Construction 

Construction Activity Schedule Start Estimated Project 

Completion 

Construction/Activity Not Requiring NRC Exemption 

Wildlife Baseline Study 3rd Quarter 2010 3rd Quarter 2011 

Location and Staking of Under-ground and Aboveground Utilities 2nd Quarter 2011 3rd Quarter 2011 

Survey and Staking of 40 Acre Facility Site within 

640-acre Section 2nd Quarter 2011 2nd Quarter 2011 

Testing of Existing Well Water to Determine 

Treatment Requirements 3rd Quarter 2011 4th Quarter 2011 

Soil Borings for Foundations for Buildings, Process 

Structures, Storage Pads and Roads 3rd Quarter 2011 4th Quarter 2011
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Environmental Report Request for Additional Information Page 14 of 186

Construction Activity Schedule Start Estimated Project 

Completion 

Preconstruction Requiring NRC Exemption 

Site Clearing 40 Acres 3rd Quarter 2011 1st Quarter 2012

Pre-construction Erosion and Storm Water Run-off 

Control 3rd Quarter 2011 1st Quarter 2012

Installation of Truck Wash-off Station 4th Quarter 2011 1st Quarter 2012

Site Grading and Erosion Control/Sedimentation 

Retention for Buildings, Process Structures, Storage 

Pads and Roads 

4th Quarter 2011 1st Quarter 2012

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

Construction/Office Trailer Installation 4th Quarter 2011 1st Quarter 2012

Electrical Substation Installation 4th Quarter 2011 1st Quarter 2012

Gas Main Installation to 40-acre Site 4th Quarter 2011 1st Quarter 2012

Administrative Building Shell Construction 4th Quarter 2011 1st Quarter 2012

Maintenance/Stores Building Shell Construction 4th Quarter 2011 1st Quarter 2012

Warehouse Building Shell Construction 4th Quarter 2011 1st Quarter 2012

Temporary Fencing 4th Quarter 2011 1st Quarter 2012

Facility Site Roadbeds and Gravel Parking Areas for 

Construction 1st Quarter 2012 1st Quarter 2012

Water Well Drilling 4th Quarter 2011 1st Quarter 2012

Geothermal Heat Pump Loop Installation 4th Quarter 2011 1st Quarter 2012

Firewater Tank Installation 4th Quarter 2011 1st Quarter 2012

Construction after NRC License 

Phase 1 Construction 2nd Quarter 2012 2nd Quarter 2013

Phase 2 Construction 2nd Quarter 2015 2nd Quarter 2016 
Environmental Report 

Environmental Report Request for Additional Information Page 15 of 186

RAI 2 

Provide Phase 1 and Phase 2 activities and impacts separately. 

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

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

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

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

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

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

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

from activities that are part of the proposed action. 

RESPONSE: 

The ER will be revised to be clear that the “Proposed License Action” is for Phase 1 facility construction 

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

has been renamed “Proposed License Action.” The ER does however include the Environmental Impacts 

and Cumulative Effects for both the Proposed License Action (which is the Phase 1 facility) combined 

with the Phase 2 Facility in order for NRC to prepare an Environmental Impact Statement (EIS) for the 

integrated Phase 1 and Phase 2 IIFP Facility. 

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

License Action,” reads as follows: 

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

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

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

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

Phase 1 and Phase 2 integrated facility and IIPF is requesting an EIS for the integrated facility. 

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

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

A, will be revised and will read as follows: 

1.1 General Description of the IIFP Facility and Proposed License Action 

PrecConstruction of the Phase 1 plantfacility is expected to begin in late the 3rd quarter of 2011with Phase 

1 construction beginning the 2nd quarter of 2012. and sStart up of operations is expected to begin in the 

late mid-20132. The expansion construction for athe Phase 2 plant facility is expected to begin in 2015 

and operations start up in late 2016. The “Proposed Action” term that was used in the Revision A of the 

Environmental Report” has been renamed “Proposed License Action.” The ER does however include the 

Environmental Impacts and Cumulative Effects for both the Proposed License Action (which is the Phase 

1 facility) combined with the Phase 2 Facility in order for NRC to prepare an Environmental Impact 

Statement (EIS) for the integrated Phase 1 and Phase 2 IIFP Facility. Prior to the Phase 2 expansion, IIFP 

will prepare and submit an amended license application for the Phase 2 Facility. At the end of its useful 

life, the plant IIFP Facility would will be decommissioned consistent with the decommissioning plan that 

is developed and submitted in the IIFP License Application, Chapter 10, “Decommissioning”. 
Environmental Report 

Environmental Report Request for Additional Information Page 16 of 186

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

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

and will read as follows: 

2.1 Proposed License Action (renamed)

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

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

• The Fluorine Extraction Process for producing SiF4 and BF3 by reacting the DUF4 produced 

in the de-conversion step with the oxides of silicon (SiO2) and boron (B2O3), respectively. 

The Pphase 2 plant facility, scheduled for startup in midlate-2016 will have an additional process for 

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

construction and operation of the Phase 1 IIFP Facility. Prior to the Phase 2 expansion, IIFP will prepare 

and submit an amended license application for the Phase 2 Facility. This Environmental Report addresses 

both the Phase 1 and Phase 2 IIFP Facilities. 

Environmental Report Documentation Impact: Each environmental resource addressed in Chapter 2 

will be revised to clarify that the assessed impact includes both Phase 1 and Phase 2 Facilities even 

though the Proposed License Action is the Phase 1 facility. The various sections of Chapter 4 of the 

Environmental Report, Revision A, will be revised and will read as follows: 

4.1.1 Proposed License Action (Renamed and revised section.) 

The Proposed License Action, as described in Section 2.1.2, “Proposed Action,” is that International 

Isotopes Fluorine Products, Inc. (IIFP) will construct and operate a facility that will use depleted uranium 

hexafluoride (DUF6) to produce inorganic fluorides, uranium oxide, and anhydrous hydrofluoric acid 

(AHF). The Proposed License Action addresses only the construction and operation of the Phase 1 IIFP 

Facility. Prior to the Phase 2 expansion, IIFP will prepare and submit an amended license application for 

the Phase 2 facility. However, the land use impacts were assessed for the construction and operation of 

both Phase 1 and Phase 2 facilities. Figure 4-1 presents a schematic of the integrated facility showing the 

location of process buildings, roads, grounds, and other non-production facilities. 

4.2.4 Proposed License Action (Renamed and revised section.)

The Proposed License Action, as described in Section 2.1, “Proposed Action,” is that IIFP will construct 

and operate a facility that will use DUF6 to produce inorganic fluorides, uranium oxide, and anhydrous 

hydrofluoric acid. The Proposed License Action addresses only the construction and operation of the 

Phase 1 IIFP Facility. Prior to the Phase 2 expansion, IIFP will prepare and submit an amended license 

application for the Phase 2 facility. However, the transportation impacts were assessed for the 

construction and operation of both Phase 1 and Phase 2 facilities. Figure 4-1 presents a schematic of the 

integrated facility showing the location of process buildings, roads, grounds, and other non-production 

facilities. 

4.3 Geology and Soil Impacts (Revised section.)

Site geology and soils are fully described in the ER Section 3.3. The sections below address the impacts 

of the Proposed License Action on site geology and soils. The Proposed License Action addresses only 

the construction and operation of the Phase 1 IIFP Facility. Prior to the Phase 2 expansion, IIFP will 
Environmental Report 

Environmental Report Request for Additional Information Page 17 of 186

prepare and submit an amended license application for the Phase 2 facility. However, the impacts to 

geology and soil resources were assessed for the construction and operation of both Phase 1 and Phase 2 

facilities.

4.4 Water Resources Impacts (Inserted as the 1st paragraph of section.) 

The Proposed License Action addresses only the construction and operation of the Phase 1 IIFP Facility. 

Prior to the Phase 2 expansion, IIFP will prepare and submit an amended license application for the Phase 

2 facility. However, the impacts to water resources were assessed for the construction and operation of 

both Phase 1 and Phase 2 facilities.

4.5 Ecological Resources Impacts (Added as an introduction for the subsequent sections.)

The Proposed License Action addresses only the construction and operation of the Phase 1 IIFP Facility. 

Prior to the Phase 2 expansion, IIFP will prepare and submit an amended license application for the Phase 

2 facility. However, the ecological impacts were assessed for the construction and operation of both Phase 

1 and Phase 2 facilities.

4.6 Air Quality Impacts (Revised section.)

This section describes the air quality impacts of the Proposed ActionIIFP Facility. Under the Proposed 

License Action, a fluorine extraction and depleted uranium de-conversion facility will be built at Hobbs, 

New Mexico. The Proposed License Action addresses only the construction and operation of the Phase 1 

IIFP Facility. Prior to the Phase 2 expansion, IIFP will prepare and submit an amended license application 

for the Phase 2 facility. However, the air quality impacts were assessed for the construction and operation 

of both Phase 1 and Phase 2 facilities. New on-site air emission sources will be created at the proposed 

IIFP Ssite during the preconstruction-licensing and general construction, operation, and decommissioning 

of the Proposed IIFP Facility. The source types and the constituents and levels of the emissions to the 

atmosphere from the sources will vary over the life of the project. The use of air emissions control 

systems and the implementation of other planned mitigation measures for these on-site sources will 

reduce the levels of air emissions actually released to the atmosphere. Automobile and truck traffic 

traveling to and from the Proposed IIFP Facility will incrementally add small quantities of air emissions 

to the total motor vehicle air emissions to Lea County. 

4.7 Noise Impacts (Revised section.)

Noise is defined as unwanted sound. High levels of noise can damage hearing, cause sleep deprivation, 

interfere with communication, and disrupt concentration. Even at low levels, noise can be a source of 

irritation, annoyance, and disturbance to people and communities when it significantly exceeds normal 

background sound levels. In the context of protecting the public health and welfare, noise implies adverse 

effects on people and the environment. The Proposed License Action addresses only the construction and 

operation of the Phase 1 IIFP Facility. Prior to the Phase 2 expansion, IIFP will prepare and submit an 

amended license application for the Phase 2 facility. However, the noise impacts are assessed for the 

construction and operation of both Phase 1 and Phase 2 facilities.

4.8.1 Proposed License Action (Renamed section and revised section.)

The Proposed License Action, as described in Section 2.1, “Proposed Action,” is that IIFP will construct 

and operate a facility that will use depleted UF6 to produce inorganic fluorides, uranium oxide, and AHF. 

The Proposed License Action addresses only the construction and operation of the Phase 1 IIFP Facility. 
Environmental Report 

Environmental Report Request for Additional Information Page 18 of 186

Prior to the Phase 2 expansion, IIFP will prepare and submit an amended license application for the Phase 

2 facility. However, the historical and cultural resources impacts were assessed for the construction and 

operation of both Phase 1 and Phase 2 facilities.

4.9.2 Proposed License Action (Renamed section and revised section.)

The Proposed License Action, as described in Section 1.2, “Proposed Action,” is that IIFP will construct 

and operate a facility that will use depleted UF6 to produce inorganic fluorides, uranium oxide, and 

anhydrous hydrofluoric acid. The Proposed License Action addresses only the construction and operation 

of the Phase 1 IIFP Facility. Prior to the Phase 2 expansion, IIFP will prepare and submit an amended 

license application for the Phase 2 facility. However, the visual and scenic resources impacts were

assessed for the construction and operation of both Phase 1 and Phase 2 Facilities. Figure 4-1 presents a 

schematic of the integrated plant facility showing the location of process buildings, roads, grounds, and 

other non-production facilities. The proposed IIFP Ssite is remote from any population centers or 

neighbors and is set over 914 m (3,000 feet) from the nearest highway (NM 483). 

4.10 Socioeconomic Impacts (Revised section.)

The Proposed License Action addresses only the construction and operation of the Phase 1 IIFP Facility. 

Prior to the Phase 2 expansion, IIFP will prepare and submit an amended license application for the Phase 

2 facility. However, the socioeconomic impacts were assessed for the construction and operation of both 

Phase 1 and Phase 2 fFacilities. This section describes the socioeconomic impacts to the community 

surrounding the IIFP plantFacility, including the impacts from the-influx of the construction and 

operation work force to schools and housing as well as on social services. Transportation impacts are 

described in ER Section 4.2, “Transportation Impacts.” 

4.11.4 Proposed License Action (Renamed section and revised section.)

The Proposed License Action addresses only the construction and operation of the Phase 1 IIFP Facility. 

Prior to the Phase 2 expansion, IIFP will prepare and submit an amended license application for the Phase 

2 facility. However, the environmental justice impacts were assessed for the construction and operation of 

both Phase 1 and Phase 2 facilities. If the Proposed Action is undertaken, pre-licensing construction of the 

Proposed IIFP Facility will begin in early 2011. In late 2012, Phase 1 operation of the facility will begin. 

By 2016, Phase 2 operation of the Proposed IIFP Facility is expected to be fully operational.

4.12 Public and Occupational Health Impacts (Added as an introduction to the following sections.) 

The Proposed License Action addresses only the construction and operation of the Phase 1 IIFP Facility. 

Prior to the Phase 2 expansion, IIFP will prepare and submit an amended license application for the Phase 

2 facility. However, the public and occupational health impacts were assessed for the construction and 

operation of both Phase 1 and Phase 2 Facilities. Potential impacts to air quality and surface and 

groundwater quality were assessed to evaluate exposure pathways to the public and workers at the IIFP 

Facility. Potential human health impacts due to exposures from permitted emissions and accidental 

releases from the IIFP Facility were estimated for chemical and radiological gaseous emissions and liquid 

effluents.

4.13 Waste Management Impacts (Revised the 1st paragraph of the section.)

The Proposed License Action addresses only the construction and operation of the Phase 1 IIFP Facility. 

Prior to the Phase 2 expansion, IIFP will prepare and submit an amended license application for the Phase 
Environmental Report 

Environmental Report Request for Additional Information Page 19 of 186

2 facility. However, the waste management impacts are assessed for the construction and operation of 

both Phase 1 and Phase 2 fFacilities. Solid waste generated at the IIFP plant Facility will be disposed of at 

licensed facilities designed to accept the various waste types. Radioactive waste will be collected in 

labeled containers in each Restricted Area and transferred to a solid waste collection area for inspection. 

Suitable waste will be volume reduced, where applicable, and all radioactive waste disposed of at a 

licensed LLW disposal facility. Hazardous and some mixed wastes will be collected at the point of 

generation, transferred to the solid waste collection area, inspected, and classified. There will be no onsite disposal of solid waste at the IIFP Ffacility. Waste Management Impacts for on-site disposal, 

therefore, need not be evaluated. 
Environmental Report 

Environmental Report Request for Additional Information Page 20 of 186

RAI 2 

Provide Phase 1 and Phase 2 activities and impacts separately. 

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

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

2009a): 

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

including emissions and waste streams; 

• workforce; and 

• impacts. 

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

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

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

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

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

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

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

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

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

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

from activities that are part of the proposed action. 

RESPONSE: 

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

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

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

each stage of the Facility. 

Environmental Report Documentation Impact: Each environmental resource will be revised, if 

necessary, to address the Phase 1 preconstruction, construction and operation, the Phase 2 construction 

and operation, and the cumulative impact of both phases of construction and operations. The various 

sections of the Environmental Report, Revision A, will be revised as follows:

4.1.1.1 Construction Impacts (Revised 4th paragraph.) 

During the construction phases stages of the IIFP Site, conventional earthmoving and grading equipment 

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

ripping tools. Soil removal work for foundations will be controlled to minimize excavation. In addition, 

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

designed structures. Approximately 6.3% of the total site area will be disturbed, affording wildlife of the 

site an opportunity to move to undisturbed on-site areas or to additional areas of suitable habitat bordering 

the IIFP Site. No mitigation is necessary to offset this SMALL impact on land use from preconstruction, 

Phase 1 construction, or Phase 2 construction. 
Environmental Report 

Environmental Report Request for Additional Information Page 21 of 186

4.1.1.2 Utilities (Revised 2nd, 3rd, and 4th paragraphs.)

Two wells will be drilled on site to supply potable water, process makeup water, and fire water. The Site 

is over the Ogallala Aquifer. These wells will have a SMALL impact on land use during preconstruction 

and do not require mitigation measures. 

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

of short-term disturbances related to the placement of the tie-in line. The gas line will have a SMALL 

impact on land use during preconstruction and does not require mitigation measures. 

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

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

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

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

transmission lines and the new substation have a SMALL impact on land use during preconstruction and 

do not require mitigation measures. 

4.1.1.3 Operations (Revised section.)

The operation of the plant IIFP Facility is not anticipated to significantly affect land use. Land use 

impacts to the site and vicinity will be minimal considering that the majority of the site will remain 

undeveloped, the current industrial activity on neighboring properties, the nearby expansive oil and gas 

well fields, and the placement of most utility installations along highway easements. Operation of the 

IIFP Ffacility has a SMALL impact on land use during Phase 1 or Phase 2 operations and does not require 

mitigation measures. 

4.2.4.1 Construction of Access Road (Revised section.)

Access to the site will be directly off of NM 483. The access roadway will eventually be converted to a 

permanent access road upon completion of construction. Therefore, preconstruction impacts from this 

access road construction will be SMALL. 

4.2.4.2 Construction (Revised 1st and 3rd paragraphs.)

The impact on Ttransportation of IIFP employees is minimal (5-10) during the construction periods. The 

number of construction workers during the pre-licensing preconstruction period is estimated at between 

30 and 60 per day. During Phase 1 construction activities, the number of workers is estimated at between 

12090 and 14050 per day. The maximum number of construction workers during the peak of the facility 

construction including Phase 2 is estimated at 200150 to 180. Thus, the maximum potential increase from 

construction worker traffic during the construction phases is 20180 round trips per day. 

If all the construction traffic used the access road off NM 483, this will result in a 19% 42% increase in 

traffic on that 2-lane highway during preconstruction, a 36% increase during Phase 1 construction, and a 

44% increase during Phase 2 construction. The vast majority of this increase is expected to be on the 1.5 

mile section between the access road and U.S. 62/180. Compared with the traffic count for the various 

highways from 2006 through 2008 and the transportation commuting statistics in Lea County from the 

2000 census data, the impact of this temporary increase in traffic during preconstruction is considered 

SMALL. For Phase 1 construction or Phase 2 construction, the impact of this temporary increase in traffic 

on NM 483 is considered to MODERATE for these peak construction periods. 
Environmental Report 

Environmental Report Request for Additional Information Page 22 of 186

4.2.4.3 Operations (Revised 1st, 2nd, and 3rd paragraphs.) 

As stated in ER Section 4.10.2.1, the operational workforce at the IIFP Facilityplant during Phase 1 is 

estimated at will be up to 138 employees. Thus the maximum potential increase to traffic due to 

operational workers is 138 round trips per day. This is an upper bound estimate since all workers do not 

work on any given day and some may carpool. It is anticipated that operations will be conducted using 

three 8-hour shifts per day with 17 to 25 per shift. It is also estimated that there are 38 to 52 day workers. 

With Operational shift and day changes for site personnel, it areis estimated to average 40103 to 60113

vehicles per shift change round trips per day. Considering both the leaving shift and the incoming shift, 

the operational shift change will double to 80 to 120 vehicles. This will amount to increased traffic of 

240206 to 360226 vehicles per day for operational personnel or a maximum of 276 vehicles per day. This 

will increase the traffic on NM 483 at Arkansas Junction 29% per day. If all the traffic went east/west on 

U.S. 62/180, this will be less than an 8% increase at Arkansas Junction in traffic per day. The IIFP 

Facility will have a SMALL to MODERATE impact on the transportation pattern from IIFP Phase 1 

operations personnel.

After Phase 2 is operational, total plant facility employee population is estimated up to 160. Thus, there 

will be a maximum of 160 round trips if there were no shift operations resulting in an additional 320 

vehicles on the area highways per day. The This will increase in the traffic on NM 483 at Arkansas 

Junction will be 12% during each shift change or a 347% increase in traffic per day. If all the traffic went 

east/west on U.S. 62/180, this will be less than a 49% increase in traffic at Arkansas Junction at each shift 

change or an 11% increase in traffic per day. The Proposed ActionIIFP Facility will have a SMALL to 

MODERATE impact on the transportation pattern from IIFP Phase 2 operations personnel. 

The maximum potential increase to traffic due to operational deliveries and waste removal shipments 

during Phase 1 is estimated at about 2,650 round trips per year. This value is based on estimated 55700 

radiological shipments per year plus 2,1,9500 non-radiological shipments per year. Thus, an average of 

approximately 10 round trips for operational deliveries and waste management will occur daily during a 

normal 5-day work week. During Phase 2 operations, the number of radiological shipments per year 

would increase to 2,150 or a total of 4,100 shipments annually. Operational delivery and waste removal 

shipments would increase to 16 round trips per year. Compared with the transportation commuting 

statistics in Lea County from the 2000 census data and the traffic count on the specific highways, this 

increase in traffic from operational deliveries and waste removal will be SMALL either for Phase 1 or 

Phase 2 operations. One mitigation measure to be considered by IIFP is to schedule operations worker 

shift changes and truck shipments for off-peak traffic periods, when practical. 

4.2.5 Other Construction Transportation Impacts (Revised 3rd, 5th, and 6th paragraphs.) 

Air quality impacts from general construction site preparation for the IIFP plant Facility have been 

evaluated using emission factors. Emission rates for fugitive dust were estimated using emission factors 

provided in AP-42, the U.S. Environmental Protection Agency's Compilation of Air Pollutant Emission 

Factors (EPA, 2009a). A more detailed discussion of air emissions can be found in ER Section 4.6.1, “Air 

Quality Impacts from Construction.” The air quality impacts due to preconstruction, Phase 1, or Phase 2

activities are SMALL. 
Environmental Report 

Environmental Report Request for Additional Information Page 23 of 186

Although plant facility construction will significantly alter its the natural state of the site, there are no 

high quality viewing areas nearby and there is existing industrial development on surrounding properties. 

Therefore, impacts to the scenic quality of the site are considered to be SMALL during preconstruction, 

Phase 1, or Phase 2 construction. Also, construction vehicles are comparable to trucks servicing 

neighboring facilities. 

As detailed in ER Section 4.7, “Noise Impacts,” the temporary increase in noise levels along U.S. 62/180 

and NM 483 due to construction vehicles is not expected to impact nearby receptors significantly, due to 

substantial truck traffic currently using these roadways and the distance to the receptors. Noise impacts 

due to construction traffic are SMALL during preconstruction, Phase 1, or Phase 2 construction. 

4.2.7 Cumulative Impacts (Revised 3rd paragraph.) 

The impact of the cumulative daily vehicle trips that will be generated by the Proposed IIFP Facility on 

traffic flow on the segment of U.S. 62/180 in the immediate vicinity of the Arkansas Junction is 

anticipated to be SMALL. However, the impact of cumulative daily vehicle trips on NM 483 is 

anticipated to be MODERATE. On a regional basis, the cumulative transportation impacts for the 

Proposed IIFP Facility are expected to be SMALL. 

4.3.3 Site Preparation and Construction (Revised 2nd paragraph.) 

The engineering design will specify the volume of soils that will be impacted during the construction 

phases. At this time, it is assumed that any shallow soils disturbed or moved during facility construction 

will be reused within the 16.2-ha (40-ac) Site. No off-site disposal of soil is expected. Site preparation 

work during preconstruction and for any Phase 1 or Phase 2 construction activities will have a SMALL 

impact on the site soils.

4.3.4 Road Construction at the Proposed Site (Revised section.) 

The access road from NM 483 (Arkansas Junction Road) to the Proposed IIFP Facility will cross several 

different soil types, as outlined on the soil type map shown in Figure 3-24, “Custom Soil Resource Report 

Soil Map of the IIFP Site.” The topsoil will likely need to be stripped before road construction can begin, 

and the remaining shallow soils that are considered suitable for a roadbed will need to be compacted. The 

resulting increase in impervious area will impact the volume of runoff from the land surface, but the 

amount of topsoil or sediment available for transport as erosion will be decreased. Roadbed preparations

during preconstruction will have a SMALL impact on the site soils. 

4.3.5 Grading within the IIFP Site (Revised section.) 

The grading within the IIFP facility site will begin with the removal of topsoil from areas designated for 

the new construction. The topsoil thickness to be removed will be determined by the soil test borings 

performed as part of the preliminary subsurface investigation. Following removal of topsoil, those areas at 

grade or designated to receive fill will likely be proof-rolled to identify those areas needing additional soil 

repair. Any area that ruts or bumps appear excessively in the opinion of the geotechnical engineer will be 

undercut to firm bearing or be repaired, as directed by the engineer. Grading within the IIFP Site during 

preconstruction will have a SMALL impact on the site soils.
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4.3.6 Operations (Revised section.) 

Impacts to shallow soils after construction is complete and during Proposed IIFP Facility operation are 

SMALL for either Phase 1 or Phase 2 operations. The stormwater retention basins within the 16.2-ha (40-

ac) IIFP Facility Site will manage stormwater runoff up to a 100-year return period event. Operation of 

the Proposed IIFP Facility will not involve additional soil disturbances; therefore, additional areas 

susceptible to soil erosion and dust generation will not be created. 

4.4.1 Receiving Waters (Revised 4th paragraph.) 

The stormwater retention basins for the site are designed to provide a means of controlling discharges of 

rainwater for about 8.1 to 16.2 ha (20 to 40 ac) of the IIFP Ssite. Impacts to receiving waters from 

preconstruction-licensing, and general construction, or and Phase 1 or Phase 2 operations of the IIFP 

Ffacility are expected to be SMALL. 

4.4.2 Impacts on Surface Water and Groundwater Quality (Revised 2nd paragraph.) 

Control of surface water runoff will be required for IIFP Ffacility pre-licensingconstruction and general 

construction activities, covered by the NPDES Construction General SWPPP Permit. As a result, no 

significant impacts are expected for either surface water bodies or groundwater. During IIFP operation, 

stormwater from the site will be collected in a collection system that includes two runoff 

retention/evaporation basins, as described in ER Section 4.4.1, “Receiving Waters.” No wastes from 

facility operational systems will be discharged to stormwater. In addition, stormwater discharges during 

plant facility operation will be controlled by a Stormwater Pollution Prevention Plan (SWPPP). Impacts 

of preconstruction, Phase 1, or Phase 2 construction activities to the surface and groundwater are expected 

to be SMALL. 

4.4.4 Hydrological System Impacts (Revised 1st paragraph.)

Due to limited effluent discharge from the facility operations, the lack of groundwater in the sand and 

gravel layer above the Chinle Formation, and the considerable depth to groundwater at the IIFP Ssite, the 

impacts from Phase 1 or Phase 2 operations are expected to be SMALL for the site's hydrologic systems. 

4.4.7 Control of Impacts to Water Quality (Revised 5th, 6th, and 7th paragraphs.) 

The Stormwater Retention Basins are designed with an outlet structure for drainage if the basins were to 

exceed its design capacity. Local terrain serves as the receiving area for these basins. During a rainfall 

event larger than the design basis, the potential exists to overflow the basins. If at all possible, IIFP will 

sample and approve discharge from the retention (evaporation) basins. However, overflow of the basins is 

an unlikely event. The additional impact to the surrounding land over that which will occur during such a 

precipitation event alone will be small. Therefore during Phase 1 and Phase 2 operations, potential 

overflow of the Stormwater Retention Basin and the Cylinder Pad Stormwater Retention Basin during an 

event beyond its design basis is expected to have a SMALL impact on water quality or the surrounding 

land. 

The existing groundwater monitoring program at the site will be supplemented with a focus on detecting 

any unforeseen impacts to groundwater quality associated with the Proposed ActionIIFP Facility (see 

Chapter 6 of this Report, “Environmental Measurement and Monitoring Programs”). Although there will 

be only a small potential for indirect impacts to groundwater quality, stormwater and effluent sampling 

will be conducted as necessary in accordance with the NPDES permit to protect surface water quality. In 
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addition, site-wide groundwater levels will be monitored routinely, and the groundwater monitoring-well 

and pumping-well networks will be analyzed to confirm that the changes in groundwater levels associated 

with the Proposed ActionIIFP Facility are minimal. Thus, the impact of the Proposed ActionIIFP Facility

during Phase 1 or Phase 2 operations on off-site groundwater quality and the effectiveness of the existing 

on-site pumping well system are SMALL. 

Water discharged from the IIFP Ssite sanitary waste treatment system will meet required levels for all 

contaminants stipulated in any permit or license required for that activity, including 10 CFR 20 (CFR, 

2009a) and a Ground Wwater Discharge Permit/Plan. The State of New Mexico has adopted the U.S. 

EPA hazardous water regulations (40 CFR Parts 260 through 266, 268 and 270) (CFR, 2009v; CFR, 

2009w; CFR, 2009x; CFR, 2009y; CFR, 2009z; CFR, 2009aa; CFR,2009bb; CFR, 2009cc; CFR, 2009dd) 

governing the generation, handling, storage, transportation, and disposal of hazardous materials. These 

regulations are found in 20.4.1 NMAC, “Hazardous Waste Management” (NMAC, 2009). Therefore, the 

impact of the site sanitary waste treatment system on water quality is SMALL during Phase 1 or Phase 2 

operations. 

4.5.4 Construction Practices (Revised section.) 

Standard land clearing methods, primarily the use of heavy equipment, will be used during the 

preconstruction-licensing and general Phase 1 construction phases of the IIFP Ssite. Both temporary and 

permanent erosion, runoff and situation control methods will follow the BMPs referenced in ER Section 

4.1, “Land Use Impacts.” Additionally, Stormwater Retention Basins will be constructed prior to land 

clearing and used as sedimentation collection basins during construction then converted to a retention 

basin once the site is revegetated and stabilized. When required, applications of water will be used to 

control dust in construction areas. Water conservation will be considered when deciding how often dust 

suppression sprays will be applied. After construction is complete, the site will be stabilized with native 

grass species, pavement, and crushed stone to control erosion. Ditches, unless excavated in rock, will be 

lined with riprap, vegetation, or other suitable material as dictated by water velocity to control erosion. 

Furthermore, any eroded areas that may develop will be repaired and stabilized. See ER Section 4.1 for 

additional information on BMPs that IIFP will use for the construction activities. 

Mobile animals will be able to avoid direct impacts during preparation of the IIFP facility site and 

construction of the facility by moving to unaffected areas on the site or to neighboring properties; 

however, there will be adverse impacts to these populations from increased competition for existing 

resources between and within wildlife species. Indirect impacts to wildlife during construction may 

include increased noise (see Section 4.7, “Noise Impacts”), disruption of travel corridors, and behavioral

modifications. Wildlife on the site are adapted to current conditions, which include roads that fragment 

communities, loud noises from pumping at the oil/gas rigs, and irregular travel of vehicles on existing 

roads. Overall, wWildlife populations on the Proposed Site will be altered during preconstruction and 

Phase 1 construction but will not be destabilized; therefore, direct and indirect impacts to wildlife will be 

MODERATE. A security fence will be installed around the 40-acre site during Phase 1 construction, so 

wildlife will not be impacted by Phase 2 construction. Thus, Phase 2 construction will have a SMALL 

impact on wildlife.

4.5.5 Operation (Revised section.) 

The operation of the Proposed IIFP Facility will not directly impact additional biotic communities beyond 

those impacted during the site preparation and construction phase. Fencing around the Proposed IIFP 

Facility could cause additional disruption of wildlife travel corridors. However, wildlife would will

develop new travel corridors and utilize the fence line and the new road as corridors. Human encounters 
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with some wildlife could increase due to disruption of travel corridors and loss of habitat. Phase 1 or 

Phase 2 Ooperations of the IIFP facility will not noticeably alter the impact to biotic communities or 

wildlife. Impacts to travel corridors and habitat quality are SMALL. 

Non-radiological air emissions from the IIFP facility will be lower than the National Ambient Air Quality 

Standards (NAAQS) for humans (see Section 4.6, “Air Quality Impacts”); however, emissions from 

vehicles and very small emissions from the operation of the facility will occur and could have small 

impacts to wildlife. No rare or unique habitats will be directly affected by the operational phases of the 

Proposed ActionIIFP Facility; therefore, overall indirect impacts from non-radiological air emissions will 

be SMALL during Phase 1 or Phase 2 operations. 

4.5.6 Area of Disturbance by Habitat Type (Revised 3rd paragraph.) 

The total area of disturbance proposed for the IIFP Ssite is approximately 16.2 ha (40 ac) of the 259-ha 

(640-ac) Section. The disturbance during preconstruction, Phase 1 construction, or Phase 2 construction 

will have a SMALL effect on the Basin and Range vegetation community. 

4.5.10 Impacts of Elevated Construction Equipment or Structures (Revised 2nd paragraph.) 

Emission stacks will be designed are proposed to be less than 30.5 m (100 ft) tall. All stacksBoth are well 

under the 61 m (200 ft) threshold that requires lights for aviation safety. This avoidance of lights, which 

attract species, and the low above ground level structure height, also reduces the relative potential for 

impacts. Additionally, security lighting for all ground level facilities and equipment will be directed 

downward to help to reduce the potential for impacts (USFWS, 1998). The impacts of elevated 

construction equipment or structures on the ecological species are expected to be SMALL during all 

construction and operational phases. 

4.5.16 Cumulative Impacts (Revised section.) 

During construction the Proposed IIFP Site could have an effect on terrestrial wildlife by causing loss of 

habitat, food sources, and travel corridors. The effect will be the loss of approximately 40 acres (16.2 ha) 

of habitat from the Proposed ActionIIFP Facility. Impacts during preconstruction and Phase 1

construction to ecological resources are MODERATE, while impacts to wildlife during Phase 2 

construction are SMALL. 

Cumulatively, Tthe Proposed ActionIIFP Facility will only have SMALL impacts to these rare and 

unique communities and to migratory bird habitat during Phase 1 and Phase 2 operations and 

decommissioning.; tTherefore, cumulative impacts to ecological resources from the Proposed License 

Action combined with the Phase 2 Facility isare SMALL. 

4.6.1 Air Quality Impacts from Construction (Revised 2nd and 10th paragraph.) 

Construction of large projects the scale of the IIFP facility commonly produce fugitive dust emissions. 

These PM emissions typically are produced by the operation of heavy-duty, off-road construction 

equipment at the construction site for land-clearing, ground excavation, grading, and foundation work. 

The level of fugitive dust emissions at a typical construction site will vary from day to day, depending on 

the specific construction activities conducted, soil types exposed to the air, and meteorological conditions 

(e.g., amount of recent precipitation, wind speed). Wind blowing over disturbed areas of a construction 

site and on-site building material storage piles is also a potential source of fugitive dust emissions. Best 

management practices during the construction of the facility are described in Section 4.1.3, “Control of
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Impacts.” With the implementation of these BMPs, the air quality impacts on during preconstruction, 

Phase 1, or Phase 2 construction are anticipated to be SMALL. 

Construction emissions generated in the site preparation phase could cause a local exceedance of the onehour NAAQS for NO2. However, NO2 concentrations would fall below the NAAQS at the site boundary 

and beyond. All other criteria pollutant concentrations attributable to construction activities would be well 

below the NAAQS. Peak year VOC and HAP emissions attributable to construction are 1.8 ton and 1.0 

ton, respectively. These emissions are negligible compared to annual VOC and HAP emissions in Lea 

County. The results of air modeling show that annual average and short-term ambient air concentrations 

from fugitive dust and on-site motor vehicle emissions produced by construction activities for the 

Proposed IIFP Facility will be orders of magnitude below the level of the applicable ambient air quality 

standards. These incremental air quality impacts from the air emissions from preparation of the IIFP 

facility site and construction of the facility will not measurably change the existing ambient air quality in 

the vicinity of the Proposed IIFP Facility; therefore, the air quality impacts resulting from the 

preconstruction and general construction stages of the Proposed IIFP Facility are anticipated to be 

SMALL. 

4.6.2.1 Description of Gaseous Effluents (Revised 4th paragraph.) 

The incremental air quality impacts from the air emissions from the Proposed IIFP Facility will not 

significantly change the existing ambient air quality in the vicinity of the Proposed IIFP Facility; 

therefore, the air quality impacts that will result from the Proposed IIFP Facility Phase 1 or Phase 2 

operations are SMALL. 

4.6.44.6.3 Visibility Impacts (Revised 2nd paragraph.)

Air emissions of the pollutants that contribute to haze formation are predicted to be low from the on-site 

air emission sources associated with the Proposed IIFP Facility preconstruction-licensing and general 

construction, operation, and decommissioning. phases. Consequently, the air emissions from the Proposed

IIFP Facility are expected to have no significant impact on regional visibility; therefore, the visibility 

impacts resulting from the preconstruction-licensing and general construction, Phase 1 and Phase 2 

operations, and decommissioning of the Proposed IIFP Facility are SMALL. 

4.7.1.1 Construction Impacts (Revised 3rd, 4th, and 5th paragraphs.) 

The finishing work within the building structures will create noise levels slightly above normal 

background. Sound levels will be expected to dissipate to near background levels by the time they reach 

the property boundaries. No sensitive noise resources are located in the immediate vicinity of the site. As 

shown in Table 3-330, “Site Acceptability Noise Standards as Established by U.S. Department of 

Housing and Urban Development (HUD),” these predicted noise level ranges fall within acceptable sound 

pressure levels. ER Section 4.2.3, “Traffic Pattern,” states that U.S. 62/180 is a main trucking 

thoroughfare for local industry and that there are no sensitive receptors (hospitals, schools, or churches) at 

the IIFP south boundary. In addition, noise levels in the predicted ranges at the south and west boundary 

lines will only be for a short duration and only during construction of the facilities. ExXcel Energy’s 

Cunningham Station is located on NM 483 on the western boundary of the IIFP Ssite., Xcel Energy’s 

Maddox Station is located east of the site. while aAnother utility and gas processing facility are located 

northeast and southeast of the site respectively. The south fence line is near to U.S. 62/180 and the west 

boundary line adjacent to NM 483. The north and east boundary lines are adjacent to vacant land. 
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Since there is already substantial truck traffic using U.S. 62/180 and NM 483, the temporarily increased 

noise levels due to construction activities are not expected to exceed 56 dBA and not adversely affect 

nearby employees of the Excel Energy Cunningham Station. ER Section 4.2, “Transportation Impacts,” 

includes further discussion of vehicle traffic. 

Due to the temporary and episodic nature of construction and because of the significant distance to the 

nearest residence approximately 2.68.5 km (1.65.3 mi) to the west northwestnortheast of the site, and 

since construction activities largely will be during weekday daylight hours, actual construction noise at 

the site is not expected have a significant effect on the closest resident. The noise level is not expected to 

exceed 50 dBA at the nearest residence. Vehicle traffic will be the most noticeable cause of construction 

noise. There are no sensitive receptors (hospitals, schools, residences) is a café located close to the 

intersection of U.S. 62/180 and NM 483 at Arkansas conjJunction. Personnel at the café who will have

been the most aware of the increase in noise from the traffic or from the construction not expected to 

exceed 48 dBAdue to proximity to the source. Noise impacts from preconstruction or general construction 

are anticipated to be SMALL.

4.7.1.2 Operational Impacts (Revised 3rd paragraph.) 

Since the nearest residence is located west northeast northwest of the IIFP Ssite at a distance of 

approximately 2.68.5 km (1.65.3 mi), the resultant sound level exposure will be below the perception of 

the human ear. This is because a noise source over such a great distance will be dispersed in air and 

absorbed by natural landscape, vegetation, and buildings to the point of being masked by background 

ambient noise at the receptor. Noise impacts from the Phase 1 or Phase 2 operation of the IIFP Ffacility 

are anticipated to be SMALL. 

4.7.4.1 Impacts to the Community (Revised 2nd paragraph.) 

Potential impacts to local schools, churches, hospitals, and residences are not expected to be significant, 

as supported by the information presented in ER Section 4.7.1. The nearest ranch residence is located 

west northwestnortheast of the site at a distance of approximately 2.68.5 km (1.65.3 mi) and due to its 

proximity is not expected to perceive an increase in noise levels due to construction or operations. The 

nearest school, hospital, church and other sensitive noise receptors are beyond this distance, thereby 

allowing the noise to dissipate and be absorbed, helping decrease the sound levels even further. Xcel 

Energy Cunningham Station is located on NM 483 and Colorado Energy Station is located east northeast 

of the site. Xcel Energy Maddox Station is located east of the facility. DCP Midstream gas processing 

facility is located southeast of the facility. At the Arkansas Junction intersection, Tthere are no two homes 

and a café located 2.9 km (1.8 mi) near the construction traffic off NM 483 nor at the intersection of U.S. 

62/180 and NM 483 from the site to be affected by the vehicle noise; but due to existing heavy tractor 

trailer vehicle traffic, the change will be minimal. No schools or hospitals are located at this intersection. 

4.8.1.1 Site Preparation and Construction (Revised section.) 

No archeological sites have been identified in the area proposed for IIFP facility construction, nor have 

sites been identified within the access road portion of the site, where construction of a new road will be 

built. Thus, preconstruction, Phase 1 and Phase 2 construction impacts to cultural and historical resources 

are SMALL. 
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4.8.1.2 Operation (Revised section.)

Operation of the Proposed IIFP Facility is not expected to result in impacts to any potential archaeological 

site; therefore, impacts of facility Phase 1 or Phase 2 operations on the site are expected to be SMALL for 

historical or cultural resources. 

4.8.6 Cumulative Impacts (Revised section.) 

Given the small number of potential archaeological sites, there will be no cumulatively significant 

impacts to cultural resources. Thus, the cumulative impacts from construction and operations on historical

or cultural resources are SMALL.

4.9.2.1 Site Preparation and Construction (Revised 2nd paragraph.) 

Temporary visual intrusions into the landscape may result from the use of construction cranes at the IIFP 

Site for erecting building structures and installing equipment. No other visual/scenic resource impacts are 

expected to result from the activities performed for construction of the Proposed IIFP Facility; therefore, 

the visual/scenic resource impacts resulting from preconstruction or Phase 1 or Phase 2 construction of 

the Proposed IIFP Facility will be SMALL. 

4.9.2.2 Operation (Revised section.) 

The layout of the Proposed IIFP Facility is shown is Figure 4-1. The dominant structure for Proposed

IIFP Facility that potentially could create visual intrusions into the landscape will be the main operations 

buildings. The tallest building is the DUF4 processing facility: the height of which is approximately 21.3 

m (70 ft) tall. A few gaseous emission stacks will be 30.5 m (100 ft) in height around the process 

buildings. The visual/scenic resource impacts resulting from Phase 1 or Phase 2 operation of the Proposed

IIFP Facility are SMALL. 

4.10.1.2 Impacts of Human Activities (Revised 3rd and 4th paragraphs.) 

The increase in jobs and population will lead to a need for additional housing and an increased level of 

community services, such as schools, fire and police protection, and medical services. Providers of these 

services should be able to accommodate the growth. For example, the estimated peak increase in schoolage children is 20 or 0.1% for Lea County school enrollment only (Refer to Table 3-5249, “Education 

Characteristics in the Region of Influence for Census Year 2000”). The overall change in population 

density and population characteristics in Lea County, New Mexico and the other 8 counties in the region 

of influence, due to preconstruction, Phase 1 construction, or Phase 2 construction of the IIFP facility, are 

SMALL. 

Similarly, IIFP has estimated 20 housing units will be needed to accommodate the new IIFP facility 

construction workforce. The percentage of vacant housing units in the Lea County, New Mexico and the 

region of influence in 2000 was about 16% and 14%, respectively, meaning that more than 3,700 housing 

units were available in Lea County and that over 12,600 housing units were available in the region of 

influence (Refer to Table 3-496, “Housing in the Region of Influence around the IIFP Site for Census 

Year 2000”). Accordingly, there should be no significant impact (SMALL) related to the need for 

additional housing for preconstruction, Phase 1, or Phase 2 construction. 
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4.10.2.1 Jobs, Income, and Population (Revised 4th, 5th, 6th, 7th, and 8th paragraphs.) 

An increase in the number of jobs will also lead to a population increase in the surrounding areas. Lea and 

Gaines Counties probably will experience the most noticeable population increases. The population 

increase during operations of the facility will be less than during facility construction and, accordingly,

have a lower impact. In particular, the region will avoid a boomtown effect, which generally describes the 

consequence of rapid increases in population (at least 5 to 10% per year) in small (populations of a few 

thousand to a few tens of thousands), rural 48 to 80 km (30 to 50 mi) or more from major city 

communities undergoing rapid increases in economic activity (NRC, 1994). The overall change in 

population density and population characteristics in Lea County, New Mexico and Andrews/Gaines 

Counties, Texas due to Phase 1 or Phase 2 operation of the IIFP Ffacility is SMALL. 

The impact estimates provided in ER Sections 4.10.1 and 4.10.2 are based on the assumption that impacts 

are limited to Lea, Andrews, and Gaines counties. If the projected increase in population reported in ER 

Sections 4.10.1 and 4.10.2 were spread over the 9-county region of influence, the impact will be reduced 

due to the higher population. This is the case for both the construction and operation periods. This minor 

increase in population will produce a SMALL impact on population characteristics, economic trends, 

housing, community services (health, social and educational resources), and the tax structure and 

distribution within 120 km (75 mi) of the site during both the construction and operation periods. 

As shown in Table 3-363, the population of Lea County, New Mexico was approximately 55,511 in 2000. 

The three closest population centers to the site in Lea County are Eunice at 354 km (221 mi), Hobbs at 

1923 km (124 mi), and Jal at 69 km (43 mi). The populations of these three areas in 2000 were 

approximately 2,562;, 28,657;, and 1,996;, respectively, providing a combined total population of 

approximately 33,215. If the entire construction phase population with a maximum increase of 

approximately 200 reported in ER Section 4.10.1.2 is assumed to relocate to these three areas, a total 

construction phase population increase of approximately 0.6% will result. For a highest impact scenario, 

if all the construction workers for the preconstruction-licensing and general construction,and Phase 1and 

Phase 2 construction relocated to the area, then the population will increase by 1.4%. 

As shown in Table 3-343, the population of Andrews County, Texas, was approximately 13,004 in 2000. 

The two closest population centers in Texas to the site are Andrews at 875 km (543 mi) and Seminole at 

6647 km (4129 mi) each. The populations of these two areas in 2000 were 9,652 and 5,910, respectively. 

It is reasonable to assume that the population increase due to the IIFP construction and operation will 

mostly relocate to this representative set of nearby population centers: Eunice, Hobbs and Jal, New 

Mexico, and Andrews and Seminole, Texas. All five locations are within 875 km (543 mi) of the site and 

are reasonable commuting distances for this region of the country. These five areas have a combined 

population of 48,777. If the maximum construction phase population increase of 200 is assumed to 

relocate to all five of the nearby locations (Eunice, Hobbs, Jal, Andrews, and Seminole), a total 

construction phase population increase of approximately 0.4% will result. For a highest impact scenario, 

if all the construction workers for the preconstruction,-licensing and general Phase 1 construction, and 

Phase 2 construction relocated to the area, then the population will increase by 0.9%. A significant 

number of operational jobs are likely to be filled by residents already living in the region. Therefore, the 

population increase during operation of the proposed IIFP plant Facility will be less than during facility 

construction since fewer workers are expected to relocate to the area. The small population increase of the 

maximum 200 during the construction phase is not expected to have a significant impact on the area. 

Because the population increase during operation of the Phase 2 facility is expected to be somewhat 

smaller at 145 to 160 personnel than the expected population increase during construction, a similar 

conclusion applies concerning the impact on the area during the Phase 1 and Phase 2 operational periods

of the IIFP Ffacility. 
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The minor increase in population will produce a SMALL impact on population characteristics, economic 

trends, housing, community services (health, social and educational resources), and the tax structure and 

distribution within Hobbs, Lovington, and Eunice, New Mexico, and Andrews and Seminole, Texas, 

during both all the construction and operation periods of the IIFP Facilityplant. 

4.10.2.2 Community Characteristic Impacts (Revised 2nd paragraph.) 

Similarly, a smaller increase in local elementary and secondary school enrollment will be expected during 

operations as compared to that during the construction periods. Area medical, fire, and law enforcement 

services should be minimally affected as well. Agreements exist among the cities in Lea County, New 

Mexico, for emergency services if personnel in Hobbs, New Mexico are not available. IIFP will request 

support from the local police and fire departments as well as the State police if needed. The impact to 

community characteristic is SMALL due to all the construction and operations periods. 

4.11.4.1 Residences within Four-Mile Radius of the Site (New Section added.)

When determining the area for impact assessment for a facility located outside the city limits or in a rural 

area, a 6.4-km (4-mi) radius [130 km2 (50 mi2)] can be used. Figure 4-19 shows that area of impact

around the IIFP Site. That same area of impact involves two census tracts as shown in Figure 4-20, Lea 

County Population, Census 2000 by Census Tract. One census tract (1100) has four (4) CBGs that have 

no disproportionate high minority or low-income populations within those CBGs. See Table C-1 in the 

Appendix. The other census tract (0700) has 6 CBGs. Table C-1 shows the percentage of persons in the 

following categories: Below Poverty Level, African American (Black), Indian, Asian, Other Race, Two or 

More Races, Hispanic, and Minorities. Of the various categories within those 6 block groups, only one 

category has a disproportionate high percentage [54.2% for minorities (Racial Minorities plus White 

Hispanics)].

Figure 4-19 shows one residence 2.6 km (1.6 mi) west northwest of the IIFP Site in census tract 1100 

with no disproportionate high minority/low income populations. There are two residences at the 

intersection of U.S. 62 and NM 483 (Arkansas Junction) in census tract 0700, neither of which are 

minorities.
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Figure 4- 19 Residences Within Four-Mile Radius Around IIFP Site

4.11.4.12 Site Preparation and Construction (Revised 2nd paragraph.)

The environmental impacts associated with site preparation preconstruction, Phase 1 and Phase 2 

construction of the Proposed IIFP Facility Plant are generally estimated to be SMALL, and generally will 

be mitigated. The only MODERATE impact involves modified wildlife travel corridors during 

construction and increased traffic congestion on NM 483 for the 1.65-mile distance between Arkansas 

Junction and the site access road, especially during shift-change hours. These impacts will mainly affect 

personnel working the surrounding industries identified in Section 3.1.2, “Description of Off-site Areas,” 

and passing motorists and the three since there are no residencests within thea 4.0 mile radius of the 

Proposed IIFP Facility. The Proposed IIFP Facility is located in NM Census Tract 000700. (See Figure 4-

19, “Lea County Population, Census 2000 by Census Tract.”). Census Tract 0700 residents since there are 

no residents within that 4-mile radius of the site. Since there are no disproportionately high-minority or 

low-income populations within the 6.4-km (4-mi) radius of the IIFP SiteThus, it is not expected that 

construction of the facility will give rise to environmental justice concerns. 

4.11.4.23 Operation (Revised 2nd paragraph.) 

As was the case for construction, the environmental impacts associated with the operations phase of the 

Proposed License Action combined with the operations of the Phase 2 Facility will be most likely to 

affect employees of the nearby industries, and passing motorists since there are noand three residencets 

(non-minorities) within 6.4 km (4 mi) of the Proposed IIFP Facility. As stated in 4.11.4.1, the site is 
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located in NM Census Tract 000700 with only one of six CBGs having minority residents comprising 

54.2% of its population and low-income residents ranging from 1.7% for CBG 2 to 19% for CBG 5 of its 

population. Census Tract 1100 has no disproportionately high-minority or low-income populations. 

Environmental impacts of facility Phase 1 and Phase 2 operations are projected to be SMALL, and no 

adverse health impacts are expected since there are no disproportionately high-minority or low-income 

populations no residents within a radius of 6.4 km (4 mi) of the proposed facility. 

4.11.4.34 Decommissioning (Revised section.) 

Decommissioning of the Proposed IIFP Facility is projected to begin in 205249; decommissioning is 

projected to consist of removal of equipment from the facility, but the building, parking area, and access 

roads are projected to remain in place. Decommissioning will be expected to employ 40 FTEs and result 

in a reduction in environmental impacts relative to construction and operation of the facility, but slightly 

higher than baseline. Again, impacts are expected to be concentrated in the vicinity of the Proposed IIFP 

Facility; thus, NM Census Tract 000700, CBG 2, will experience a higher share of any environmental 

impacts than will CBGs located farther from the facility. Because there CBG in which the facility is 

located hasare no minority and low-income residents within a 4-mile radius (50 mi2) of the plantfacility, 

decommissioning of the facility is not expected to result in disproportionately high or adverse impacts on 

minority or low-income populations. Thus, decommissioning of the IIFP facility is not expected to pose 

environmental justice concerns (SMALL impact). 

4.11.4.4 5 Cumulative Impacts (Revised 1st paragraph.) 

All construction and operation phases stages of the Proposed IIFP Facility have the potential to generate 

environmental impacts on the areas surrounding the facility, including a CBG with relatively high 

proportion of minority residents. However, the results of the analysis indicate that the cumulative 

environmental impacts experienced by residents from the preconstruction, Phase 1 and Phase 2 

construction, Phase 1 and Phase 2 operation, and decommissioning phases of the Proposed ActionIIFP 

Facility will be SMALL, and any adverse health impacts will be SMALL. The only MODERATE 

impacts estimated are increased traffic congestion on NM 483 between the proposed new dedicated IIFP 

facility entrance and Arkansas Junction, especially during shift-change hours, and these impacts will 

mainly affect the neighboring industries, or passing motorists, and since nothree residentces are located 

with 6.4 km (4 mi) of the proposed IIFP Ffacility. Thus environmental impacts from the preconstructionlicensing and general construction, operation, and decommissioning of the IIFFP Ffacility are not 

expected to result in disproportionately high or adverse impacts on minority or low-income populations. 

4.12.1.1 Site Preparation and Construction (New section added.)

Construction of the IIFP Facility will result in fugitive dust emissions (from construction activities and 

vehicular traffic along unpaved roads) and vehicle emissions. Particulates with aerodynamic diameter less 

than 10 μ (PM10), CO, NOx, SO2, and VOC emissions were evaluated for potential human health impacts 

from construction activities and associated vehicle emissions (see Section 4.6.1 for details on air quality 

impacts). Fugitive dust emissions from excavation and grading during construction will be controlled 

using BMPs and dust-suppression methods (e.g., water sprays and speed limits on unpaved roadways). 

Emissions from heavy construction equipment and vehicles generally will not affect ambient air quality, 

but could result in a temporary local increase in VOC emissions. The results of air modeling (Table 4-12) 

show that annual average and short-term ambient air concentrations from fugitive dust and on-site motor 

vehicle emissions produced by construction activities for the IIFP Facility will be orders of magnitude 

below the level of the applicable ambient air quality standards. No adverse health impacts to nearby 

residents or workers are expected to result from emissions related to construction. Thus, only SMALL 
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impacts to public and occupational health from air quality during preconstruction and Phase 1 or Phase 2 

construction are expected.

4.12.1.2 3 Routine Liquid Effluent (Revised 1st paragraph.) 

The facility does not directly discharge any industrial effluents to natural surface waters or grounds on 

site, and there is no plant facility tie in to a Publicly Owned-Treatment Works (POTW). All effluents are 

contained on the IIFP Ssite via collection tanks. No public impact is expected from routine liquid effluent 

discharge. Impacts from routine liquid effluents (Phase 1 or Phase 2 operations) are SMALL. 

4.12.2.1 Site Preparation and Construction of the IIFP Facility (Added new section.) 

Radiological impacts to nearby residents or on-site workers are anticipated to be SMALL as a result of 

construction. Radiological materials will be brought on-site and handled during IIFP Facility site 

preparation. No radiological materials will be released from any process operations from the IIFP Facility 

and/or exposure during these initial construction phases. Construction of new facilities during Phase 2 is 

not anticipated to result in any releases of radiological material. Thus, the impact to public and 

occupational health during construction of the IIFP Facility is anticipated to be SMALL.

4.12.2.14.12.2.2.1 Pathway Assessment 

Routine Gaseous Effluent (Revised 3rd paragraph.) 

Under routine Phase 1 or Phase 2 operations, the potential that radioactivity from the Cylinder Storage 

Pads may impact the public is low because the cylinders are surveyed for external contamination before 

they are placed on the staging area. Therefore, rainfall runoff from the pad is not expected to be a 

significant exposure pathway. Runoff water from the Cylinder Storage Pads is directed from the Staging 

Pads to an on-site retention basin for evaporation of the collected water. Periodic sampling of the soil 

from the basins is performed to identify accumulation or buildup of any residual cylinder surface 

contamination washed off by rainwater to the basins (see ER Section 6.1, “Radiological Monitoring”). No 

liquids from the retention basins are discharged directly off site. In addition, direct radiation from the 

Cylinder Storage Pads is monitored on a quarterly basis using thermoluminescent dosimeters (TLDs).

Thus, the impacts to the public from Phase 1 or Phase 2 operations are anticipated to be SMALL.

4.12.2.24.12.2.2.2 Public and Occupational Exposure Impacts (Revised 14th paragraph.) 

The CEDE and the DDE are totaled to determine the TEDE for the MEI. The TEDE was determined to be 

0.21 mSv/yr (20.80 mrem/yr). Therefore, radiological impacts during Phase 1 or Phase 2 operations to 

off-site receptors from routine combined effluent releases and direct radiation are anticipated to be 

SMALL. Doses for public receptors at other sites of interest (e.g., schools and hospitals) would be lower 

than the MEI because the airborne concentrations of uranium are lower at these more distant locations. 

4.12.3 Environmental Effects of Accidents (Revised 1st and 2nd paragraphs.) 

Construction activities are subject to OSHA construction regulations (29 CFR 1926). During 

construction, there will be an increased potential for construction vehicle accidents, material-handling 

accidents, lacerations, trips, and falls that could result in injuries. First aid or further medical attention will

be provided promptly as warranted by the situation. As a result of construction activities, it is expected 

that there could be an increase in the incidence of OSHA-recordable injuries and illnesses. See Section 
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3.11.2.1, “Occupational Injury Rates.” However, it is anticipated that the impact to occupational health 

from the preconstruction and Phase 1 and Phase 2 construction is SMALL.

For the radiological operational aspects, Tthe IIFP facility only processes depleted uranium, thus the offsite radiological consequences associated with plant facility accidents is limited. No nuclear criticality 

potential exists at the facility and there are no materials on site that contain fission products or transuranic 

elements. There are, however, large inventories of depleted uranium material on site in the form of DUF6, 

DUF4, and a blend of depleted uranium oxides. There is also a potential to release depleted UO2F2 into the 

environment as a reaction product from a DUF6 release. In spite of these large inventories of DUF4, 

DUF6, and uranium oxides, no credible accident has been identified to pose intermediate or high 

radiological consequences to the public. There are credible intermediate chemical consequence events 

resulting from potential uranium oxide releases. This is due to the acute chemical exposure of the uranium 

material, not its radiological component. Two uranium compounds pose a credible hazard to the off-site 

environment due to their solubility: UF6 and UO2F2. However, no credible accident is identified that could 

result in a release of soluble uranium resulting in intermediate or high off-site environmental 

consequences. 

4.12.3.2 Natural Phenomena (Revised section.) 

Analyses of potential accidents include the effects of natural phenomena. Only a seismic event and wind 

generated projectiles were identified as potential initiators that result in intermediate or high 

consequences to the public. 

Seismic 

A seismic event may produce loads on processing piping and components beyond their capacity to 

maintain their structural integrity resulting in radiological and hazardous chemical material releases. 

Additionally, the linear movement may cause motion of certain items such that process piping and 

components are damaged by impact, which also may result in material releases. In such areas where the 

radioactive or hazardous chemical release results in high or intermediate consequences to the public, 

process systems are designed and components restrained to meet a design basis earthquake event. 

Therefore, given the bounding expected earthquake occurs at the IIFP Facility plant site, it is not expected 

that a mitigated radiological or hazardous chemical material release will occur such that intermediate or 

high consequences to the public will result. Thus, the impact to the public from Phase 1 or Phase 2 

operations from seismic events is anticipated to be SMALL.

Tornadoes and Straight Winds 

The buildings are designed to withstand tornado the design basis wind loadings (as described in the 

Natural Phenomena Analysis Summary in the following paragraphs) including tornado generated 

projectiles. The tornado parameters are based on a 100,000-year period of recurrence. This tornado return 

parameter has been designated as the design basis tornado for the IIFP facility. DUF6 cylinders stored 

outside are placed in saddles to prevent movement during a bounding wind event. Additionally, the 

cylinders are robust vessels that are expected to maintain their structural integrity during impact from a 

wind generated projectile. Therefore, given that the bounding expected tornado/wind event occurs at the 

IIFP plant Facility site, it is not expected that a mitigated radiological or hazardous chemical material 

release will occur such that intermediate or high consequences to the public will result. Thus, the impact 

to the public from Phase 1 or Phase 2 operations from tornado events is anticipated to be SMALL.
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NOAA NCDC Storm Events includes information for 527 tornado events reported for the state of New 

Mexico for the period 1950-2010 for an average of 8.78 events per year. Lea County reported 92 

tornadoes for the same period for an average of 1.53 tornadoes per year. Of these 92 tornado events for 

Lea County between 01/01/50 and 01/31/10, 63 - F0, 20 - F1, 8 - F2, and one- F3 tornadoes were 

reported. During this same sixty-year period, no F4 or F5 tornadoes were reported. (NCDC, 2010a)

The evaluation of tornadoes and straight winds was made based on NUREG/CR-4461, Revision 2 

(February, 2007) including data in Appendices A, B and C of the NUREG, DOE-1020-2002 and DOESTD-1022-2002 including Appendix D. It was determined from this evaluation that straight gust wind 

speeds will be used as the design basis for buildings and structures at the IIFP Facility. Design wind 

speeds for all buildings and structures that do not contain licensed material or for buildings and structures 

containing chemicals or processes that do not affect licensed material will be determined in accordance 

with the applicable model building codes (New Mexico Commercial Building Code (NMCBC, 2006) and 

American Society of Civil Engineers (ASCE 7-05) or latest editions adopted by the State of New Mexico 

at time of design). Specifically, these buildings and structures will be designed for a minimum straight 

gust wind speed of 90 mph.

Design wind speeds for all buildings and structures containing licensed material or buildings and 

structures containing chemicals or processes affecting licensed material are determined in accordance 

with NUREG-1520, Revision 1 and by reference to DOE-STD-1020-2002 which, in Table 3-2, lists 

recommended peak gust wind speeds for Category C exposure and for tornadoes at 10m (33 ft) above the 

ground versus Performance Category and Annual Probability of Exceedance for 23 DOE sites across the 

United States.

By definition, DOE Performance Category 3 (PC-3) buildings and other structures are buildings and other 

common structures not classified as PC-4 structures which contain sufficient quantities of toxic or 

explosive substances to be dangerous to the public if released. PC-4 SSCs are designated as “reactor like” 

in that the quantity of hazardous material and energies similar to a large Category A reactor (>200MWt). 

For the purposes of evaluating risks and determining design basis criteria relative to natural phenomena 

events, the IIFP conservatively used the equivalent PC-3 category for the IIFP process buildings and other 

structures containing licensed material or process buildings containing processes or materials potentially 

affecting licensed materials. This designation is consistent with Occupancy Category III buildings and 

structures as defined in ASCE 7-05 Table 1-1(DOE G 420.1-2, 3/28/00).

DOE-STD-1020-2002, Table 3-2 lists design wind speeds and probabilities of “exceeding” for straight 

winds and for tornadoes for several DOE sites for Performance Categories PC-1 thru PC-4 structures. The 

design wind speeds listed in Table 3-2 for PC-1 structures (2 x 10-2 probability of “exceeding” in one 

year) are consistent with the USGS wind speed maps adopted by the International Building Code (IBC2006) and ASCE 7-05. For all cases cited, where the design wind speed for PC-1 structures per the USGS 

wind speed maps is 90 mph (2 x10-2), the design wind speed per Table 3-2 for PC-2 structures is 96 mph 

(1x10-2), for PC-3 structures is 117 mph (1x10-3) and for PC-4 structures is 135 mph (1x10-4).

Per Table D-2 in DOE-STD-1020-2002, Appendix D, the performance goal for a PC-3 facility is to 

design for the facility to withstand a straight-line wind load that occurs at a 1x10-4. This 1x 10-4

performance goal is met at the IIFP facility by designing applicable structures (as defined above) using a 

135 mph straight wind gust at the 1x 10-4 probability level where no credit is taken for the Ratio of 

Hazard to Performance Probability allowed per Table D-2. Therefore, the IIFP design basis wind speed is 

one order of magnitude more conservative than the design basis required by DOE for PC-3 structures 

where a hazard probability of 1x10-3 with a Ratio of Hazard to Performance Probability of 10 may be 

used to meet the performance goal of 1 x 10-4.
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From the evaluation that was performed, it was determined that the likelihood of a tornado generating 

winds at 135 mph is at a probability level of less than 1x10-5. Also, according to Appendix A of 

NUREG/CR-4461, Rev.2, strike probabilities for the one-degree, the two-degree and the four-degree 

boxes containing the IIFP Site are 5.235 x 10-5yr-1, 8.444 x 10-5 yr-1 and 3.975 x 10-5 yr-1 respectively. 

Therefore, selection of a design basis wind speed for IIFP PC-3 structures of 135 mph at the 1x10-4

probability level represents a conservative approach. The IIFP Facility building and structures that 

contain hazardous radiological and chemical (if applicable) materials that must be controlled or mitigated 

to meet the performance criteria given in 10 CFR part 70.61, “Performance Requirements,” are defined as 

PC-3 structures per the Natural Phenomena Hazard Evaluation methods prescribed in DOE-STD-1020-

2002. As mentioned above, those structures will meet the performance category of 1x10-4, and be 

designed to withstand a 1x10-4 probability per year occurrence straight-line wind event. Hence, based on 

the order of magnitude scale for determining event likelihood using the ISA methodology in NUREG1520, Rev. 1, the collapse or loss of the building integrity is considered to be highly unlikely and meets 

the qualitative frequency scale of 10-5 per year or less. Events that occur at a highly unlikely frequency 

meet the performance criteria for acceptable risk without the need to further reduce the likelihood of 

hazardous release or mitigate its consequences. Therefore, designing the PC-3 facilities to withstand 

straight-line wind events with an occurrence frequency of 1x10-4 per year meets ISA risk acceptance 

levels regardless of the hazardous material inventories within the facilities and without consideration to 

mitigation of any hazardous release.

4.12.3.3 Fires 

Fires are prevented by limiting combustibles and flammable liquids in areas where significant 

radiological and hazardous chemicals are present. Flammable and explosive gases are also controlled 

along with potential ignition sources. Within process areas fire suppression system activation contains 

fires and prevents the breach of process systems and the subsequent release of radioactive and/or 

hazardous materials. For areas not covered by an automatic sprinkler system, such as outside in the DUF6

cylinder pads, a plant facility “fire brigade” assembles to contain the fire. Additionally, local fire fighters 

are summoned to extinguish the fire prior to a system breach and release of radioactive and/or hazardous 

material. Therefore, given that a significant fire occurs at the IIFP plant Facility site, it is not expected 

that a mitigated radiological or hazardous chemical material release will occur such that intermediate or 

high consequences to the public will result. Thus, the impact to the public from Phase 1 or Phase 2 

operations from fires is anticipated to be SMALL.

4.12.3.4 Process Upsets 

The remaining types of initiating events that result in possible intermediate or high chemical 

consequences to the public are process type upsets/incidents. Based on the facility prevention, mitigation 

designs, and proceduresAs mentioned above, no credible process upsets result in result in intermediate or 

high radiological consequences to the public or worker. These upsets involve the loss of process and 

safety controls resulting in the loss of containment of radioactive and hazardous materials. These 

initiating events are analyzed and documented in the IIFP Process Hazards Analysis in the IIFP ISA. The 

incidents that lead to a release include the loss of system integrity and the failure to filter, capture, and 

scrub process byproducts. In most cases adequate controls are in place to prevent a process upset/incident 

from propagating to the point of a significant radioactive and/or hazardous material release, but in a few 

cases mitigation controls are established to limit the amount of release off site, such as secondary 

containment systems. Due to a combination of safety prevention limits and controls and mitigation 

measures, a significant process upset condition is not expected to result in the mitigated release of 

radiological or hazardous chemical material such that intermediate or high consequences to the public will 
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result, thus process upset conditions during Phase 1 or Phase 2 operations are anticipated to have a 

SMALL impact to the public.

4.12.4 Decommissioning (Added new section.) 

Decommissioning and closure activities for the IIFP Facility will include, where feasible, the cleaning and 

removal of radioactive and hazardous waste contamination that may be present on materials, equipment, 

and structures. IIFP anticipates that the majority of radioactive material will be recovered from the IIFP 

Facility upon completion of the operation; however, the material will be dispersed through the 

components and piping. IIFP will develop a Decommissioning Plan for decommissioning and closure 

activities. During decommissioning and closure activities, worker exposures and potential release 

pathways will be controlled and monitored in accordance with internal procedures, license conditions, and 

regulatory requirements. 

A centralized air sampling system will be used to monitor airborne uranium concentrations in controlled 

areas. This system will be modified as appropriate and used to monitor routine and abnormal activities as 

necessary. Removal of this system will be delayed as long as practical. After removal, portable systems 

will be used as necessary for work area monitoring.

Another safety system that will be essential during decontamination activities (such as cutting, 

dismantling, and non-routine trash accumulation) is the fire alarm system, with fire alarm boxes 

strategically placed throughout the Site. Once triggered, the system will send out a coded alarm that 

identifies the area of the fire, ensuring prompt attention.

Necessary environmental monitoring programs established during the operation of the IIFP Facility will 

continue during the decommissioning and closure activities to assure that potential contaminants are 

being contained. Samples will continue to be taken at the stack release points, where applicable, as well as 

from soil and wells around the Site. These samples will be analyzed for specific contaminants.

Radiation exposure to employees will be monitored through existing programs, such as issuance of 

personnel monitoring devices, air sampling of airborne contamination, and routine bioassays. These 

programs will continue to be maintained to meet the regulatory requirements specified in 10 CFR 20.

Consistent with the policy during IIFP Facility operation, the policy during decommissioning is to reduce 

individual and collective occupational radiation exposure in accordance with the ALARA principles.

With implementation of the procedures described above, the impacts to public and occupational health 

associated with IIFP Facility decontamination and decommissioning activities are anticipated to be 

SMALL.

4.12.5 Cumulative Effects (Added new section.) 

The cumulative effects of construction, operation, and decommissioning of the IIFP Facility on public and 

occupational health are anticipated to be SMALL. The non-radiological chemicals (e.g., HF) potentially 

released from the IIFP Facility are not persistent and will not accumulate in the environment or cause 

cumulative health effects. The cumulative impact on public or occupational health from the use, release, 

and disposal of radiological materials during operation and decommissioning is expected to be SMALL, 

but will be managed according to BMPs and ALARA principles, as well as through the Radiation Safety 

Program and the Industrial Safety Program.
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Cumulative radiological impacts from the IIFP Facility have been considered throughout Section 4.12.2, 

and any public health impacts are expected to be SMALL because the predicted CEDE for the MEI is 

well below the EPA and NRC annual limits. Any increase in the number of workers at the IIFP Site 

during the construction or operation of these facilities may contribute to an increase in the number of 

recordable injuries and illnesses among workers. These projects will not affect the radiological impacts of 

the IIFP Facility because they will not contribute any additional radiological materials to the environment

or in the workplace. Any non-radiological impacts to worker or public health will be SMALL and will be 

managed by process and emission controls.

4.12.6 Control of Impacts (Added new section.) 

An essential component of IIFP’s strategy to avoid human health impacts is to control and minimize 

potential exposures to workers and the public through BMPs and ALARA practices. Mitigation measures 

will be in place to minimize the release of non-radiological and radiological effluents and to stay below 

regulatory limits. The Plant KOH Scrubbing System vents treated gases through a single stack. The threestage KOH scrubbing system is designed for removing fluoride bearing components in the gas streams at 

approximate efficiencies of greater than 80%, 95%, and 99% for the first, second, and third stages, 

respectively. The overall system removal efficiency is designed at greater than about 99.9 %. The Plant 

KOH Scrubbing System stack is monitored to measure for traces of fluorides or uranium in the vent gas. 

Worker health and safety at the IIFP Facility are protected by the Chemical Safety Program, the Radiation 

Protection Program, and the Industrial Safety Program. These programs comply with applicable State, 

NRC (10 CFR 20), and OSHA (29 CFR 1910) requirements. Work environments that present the 

potential for exposure to chemical, biological, or physical agents (e.g., radiation, noise, heat/cold, 

vibration) will be evaluated, and appropriate safety controls will be implemented and/or safety equipment 

will be assigned to workers. Personal protective equipment (PPE) requirements are based on the nature of 

the work and chemical and/or radiological hazards present and area key component of minimizing 

exposure to chemical and radiological agents. Exposure monitoring will be conducted on radiation 

workers to evaluate their potential for personal exposure; if personal monitoring is not feasible, work area 

monitoring will be used to represent personal exposure.

4.13.2 Waste Management System Description Site Preparation and Construction of the IIFP

Facility (Revised Section name and revised section.) 

Descriptions of the proposed IIFP waste management systems are provided in ER Section 3.12.

Construction of the IIFP Facility will generate solid waste materials that will need to be collected and 

transported off-site for recycling or disposal. It is expected that predominately refuse and construction 

debris typical of industrial construction projects will be generated during the construction phase. No 

radioactive waste is expected to be generated during the preconstruction and Phase 1 construction phases. 

The types of waste anticipated to be generated include paper, plastic, cardboard, packaging materials, 

wood scraps, metal building material scraps, roofing and insulation material scraps, masonry and ceramic 

materials, and empty paint and coatings containers. Small quantities of organic solvent-based residuals 

remaining from application of specialty paints, architectural coatings, sealants, and adhesives, as well as 

wastes from certain other materials that are used for construction; may be required to be managed as 

hazardous waste. The specific compositions and quantities for these construction waste types will depend 

on the final facility design.

The general design/build contractor selected for the IIFP Facility project will have responsibility for the 

day-to-day supervision of on-site waste collection and storage and for arranging for removal of these 

wastes from the IIFP Facility site. Good work practices for facility site waste management will be used to 
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collect and sort the wastes for recycling or disposal (e.g., using designated roll-off containers and 

collection areas for different types of wastes). Hazardous waste generated throughout the construction 

phase will be temporarily stored on-site and then shipped to an off-site facility appropriate for handling 

the waste composition, in accordance with established recycling and hazardous waste management 

programs. Therefore, the waste management impacts resulting from preconstruction and Phase 1 

construction of the IIFP Facility will be SMALL. Phase 2 construction will necessitate connections to 

existing Phase 1 facilities. Radiological materials will not be used in the construction of the Phase 2 

Facility itself. Thus, it is also anticipated that the waste management impacts from Phase 2 construction 

will be SMALL

4.13.3 Waste Disposal from the Operation of the IIFP Facility 

4.13.3.1 Radioactive and Mixed Waste Disposal Plans (Revised 2nd and 3rd paragraphs.) 

All radioactive and mixed wastes will be disposed of at off-site, licensed facilities. The impacts on the 

environment due to these off-site facilities are not addressed in this report. The facilities that may be used 

to process, or dispose of IIFP radioactive or mixed waste, include Energy Solutions near Clive, UT. Other 

off-site processing or disposal facilities may be used if appropriately licensed to accept IIFP waste types. 

The remaining mixed waste will either be pretreated in its collection container on site prior to off-site 

disposal, or shipped directly to a mixed waste processor for ultimate disposal. The solid radioactive and 

mixed waste management impacts resulting from Phase 1 and Phase 2 operation of the IIFP Facility will 

be SMALL.

The Clive site, located in South Clive, Utah, is owned and operated privately by Energy Solutions of 

Utah. This low-level waste disposal site is also licensed in an agreement state in association with 10 CFR 

61 (CFR, 2009e), and 40 CFR 264 (CFR, 2009z). Currently, the license allows acceptance of Class A 

waste only. In addition to accepting radioactive waste, the Clive facility may accept some mixed wastes. 

This facility is licensed to accept IIFP low-level waste either directly from the IIFP Ssite or as processed 

waste from off-site waste processing vendors. The disposal site is approximately 1,636 km (1,016 mi) 

from the IIFP facility. Impacts to the off-site, licensed facilities are evaluated in Section 4.13.3.2.

4.13.3.2 Environmental Impacts of Off-site Disposal of Depleted Uranium Oxide in a 

Licensed Disposal Facility (Added new section.) 

The NRC evaluated the environmental impacts of off-site disposal of depleted uranium oxide from the 

National Enrichment Facility (NUREG 1790) at Eunice, NM. Once the DUF6 is converted to depleted 

uranium oxides under one of three options, the waste will subsequently be transported to a licensed 

commercial disposal facility for final disposition. NRC found that the impacts of transporting the waste to 

a licensed disposal facility for final disposition will be SMALL (NRC, 2005).

The environmental impacts at the shallow disposal sites considered for disposition of low-level 

radioactive wastes will have been assessed at the time of the initial license approvals of these disposal 

facilities or as a part of any subsequent amendments to the license. For example, under its Radioactive 

Materials License issued by the State of Utah, the Envirocare (now called Energy Solutions) disposal 

facility is authorized to accept depleted uranium for disposal with no volume restrictions (Envirocare, 

2003). Several site-specific factors contribute to the acceptability of depleted uranium disposal at the 

Envirocare (Energy Solutions) site, including highly saline groundwater that makes it unsuitable for use 

in irrigation and for human or animal consumption, saline soils unsuitable for agriculture, and low annual 

precipitation. As Utah is an NRC Agreement State and Envirocare (Energy Solutions) has met Utah’s 

low-level radioactive waste licensing requirements, which are compatible with 10 CFR Part 61, NRC 
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assessed that the impacts from the disposal of depleted uranium generated by the proposed NEF at the 

Envirocare (Energy Solutions) facility would be SMALL (NRC, 2005). Similarly, the impacts from the 

disposal of depleted uranium from the IIFP Facility from the deconversion of DUF6 from enrichment 

plants will be SMALL. 

The quantity of depleted uranium generated as a result of IIFP’s operations will also affect the available 

disposal capacity for such material. Since the depleted uranium oxide to be generated by the deconversion 

of IIFP’s depleted tails will be a Class A low-level radioactive waste, it will need to be disposed of in a 

facility licensed to accept Class A waste. In a June 2004 report, the Government Accountability Office 

reported that sufficient disposal capacity exists at currently licensed low-level radioactive waste disposal 

facilities for Class A low-level radioactive wastes generated for more than the next 20 years (GAO, 

2004). Therefore, the potential impact on national disposal space that will be incurred due to IIFP’s 

operations will be considered SMALL.

4.13.3.24.13.3.3 Liquid Wastes (Renumbered Title and Revised 3rd paragraph.)

Contaminated water is treated to the limits in 10 CFR 20.2003, 10 CFR 20, Appendix B Table 3 and to 

administrative levels recommended by Regulatory Guide 8.37 (CFR, 2009a; NRC, 1993). Refer to ER 

Section 4.4, “Water Resource Impacts,” for additional water quality standards and permits for the IIFP 

facility. ER Section 3.12, “Waste Management,” also contains information on the IIFP systems and 

procedures to ensure water quality. The liquid waste management impacts resulting from Phase 1 and 

Phase 2 operation of the IIFP Facility will be SMALL.

4.13.5 Decommissioning Impacts (New Section added.) 

The plans for IIFP Facility decommissioning are described in Section 2.1.5, “Decommissioning.” With 

the permanent cessation of uranium deconversion operations and a reduction in the number of on-site 

workers, sanitary and process wastewater quantities generated by the IIFP Facility will decrease from the 

levels generated during operations to eventually zero by the end of the decommissioning phase. During 

the decommissioning phase, radioactive-contaminated solutions generated from IIFP Facility 

decontamination activities will be sent to an off-site licensed facility for volume reduction and/or 

treatment/disposal. Stormwater will continue to be routed from the IIFP Facility’s stormwater drainage 

system to the on-site stormwater retention basin during the decommissioning phase and after closure. 

Therefore, the wastewater management impacts resulting from decommissioning of the IIFP Facility will

be SMALL

Decommissioning activities will include the cleaning and removal of radioactive and hazardous waste 

contamination that may be present on materials, equipment, and structures. Solid wastes will be generated 

by these activities required for the decontamination, as well as by the removal of used process equipment 

from inside the buildings. Decontaminated used equipment will be shipped off-site to salvage or disposal 

facilities, as appropriate to the equipment type. In the event that structures needed to be demolished as 

part of the decommissioning activities, the demolition material will be shipped off-site. Radioactivecontaminated equipment and materials removed during decommissioning will be shipped to a licensed 

treatment or disposal facility (as appropriate for the material type) or disposed of in a manner authorized 

by the NRC. Similarly, hazardous waste materials removed during decommissioning will be shipped to a 

RCRA-permitted Subtitle C Treatment Storage and/or Disposal Facility or an appropriate licensed 

recovery facility. Therefore, the solid waste management impacts resulting from decommissioning of the 

IIFP Facility will be SMALL.
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4.13.6 Cumulative Impacts (New Section added.)

Minimal liquid wastes are generated during the construction of the IIFP Facility. All process liquid wastes

are recycled during the operation of the facility. Radioactive-contaminated solutions generated during 

decommissioning and decontamination activities will be sent to an off-site, licensed facility for volume 

reduction and/or treatment/disposal. Cumulative impacts due to liquid waste are SMALL.

Solid wastes sent off-site to a facility for landfill disposal would cumulatively consume a portion of the 

permitted landfill capacity limit over the preconstruction, construction, operation, and decommissioning 

stages of the IIFP Facility. These facilities have adequate capacity to continue accepting solid waste 

materials generated at the IIFP Site for the foreseeable future. IIFP is not aware of any closure or other 

plans that will impede the future acceptance of the appropriate waste materials generated from the 

operations at the Site. The cumulative impacts from solid waste generation from the IIFP Facility will be 

SMALL.

4.13.7 Control of Impacts (New Section added.)

Waste management impacts resulting from the IIFP Facility will be controlled by implementing a 

comprehensive program that incorporates the following waste management impact mitigation 

components:

• Minimizing the quantities of waste generated by the IIFP Facility by implementing the waste 

minimization plan discussed in Section 4.13.4;

• Performing an assessment for each on-site waste storage area to identify and prevent potential 

accidental releases to the environment; 

• Monitoring and inspecting on-site waste storage facilities on a periodic schedule to detect any 

leaks or releases to the environment due to equipment malfunctions so that corrective action can 

be taken promptly; and

• Shipping each waste generated by the IIFP Facility that requires off-site storage, treatment, or 

disposal to a licensed facility (as appropriate for the waste type) in compliance with EPA and 

NRC requirements.

The waste management impact mitigation measures that will be applied to the Proposed License Action

combined with the Phase 2 Facility are further discussed in Section 5.2.13, Waste Management 

(Mitigation Measures).
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RAI 2 

Provide Phase 1 and Phase 2 activities and impacts separately. 

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

activities and construction of buildings. 

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

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

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

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

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

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

from activities that are part of the proposed action. 

RESPONSE: 

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

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

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

read as follows: 

2.1.2.18 Phase 2 Construction

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

increasing DUF6 de-conversion capacity. During this construction stage, additions are planned for the 

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

Distillation Annex.

The entire site clearing will occur during preconstruction and Phase 1 construction. No roads will need to 

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

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

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

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

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

space will be added to the existing Phase 1 facility. Considering the total 640-Section area, minimal soil 

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

undisturbed areas. 

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

a strategic location near the Phase 1 production areas. The construction trailer will not maintain any 

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

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

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

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

Environmental Report Request for Additional Information Page 44 of 186

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

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

(FM)-4450 (FM, latest edition) or as classified by Underwriters Laboratory (UL) standard 1256 (UL, 

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

function as a containment-type barrier. The Oxide Process Building is 15.3 m x 15.3 m x 21.3 m (50 ft 

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

(50 ft x 20 ft x 30 ft)]. The existing Phase 1 DUF6 Autoclave Building [27.4 m x 18.3 m x 12.2 m (90 ft x 

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

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

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

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

Class 1 metal roofs meeting FM and UL requirements as stated above. The HF Distillation Annex is 7.6

m x 6.1 m x 18.3 m (25 ft x 20 ft x 60 ft). 

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

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

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

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

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

constructed of metal grating or metal flooring.

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

control rooms for the major processes, including appropriate monitoring, recording, alarm notification 

and control instrumentation. 
Environmental Report 

Environmental Report Request for Additional Information Page 45 of 186

RAI 3 

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

Isotopes Fluorine Products, Inc. (IIFP) facility. 

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

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

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

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

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

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

RESPONSE: 

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

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

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

receipts tax relief to a company. 

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

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

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

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

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

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

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

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

New Mexico Administrative Code. 

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

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

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

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

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

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

annual property tax estimated for the Phase 1 facility and the cumulative Phase 2 facility are provided in 

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

Environmental Report Documentation Impact: None. 
Environmental Report 

Environmental Report Request for Additional Information Page 46 of 186

RAI 3 

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

Isotopes Fluorine Products, Inc. (IIFP) facility. 

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

Costs-Benefit Estimates for the Proposed Action,” and 7.1.5.7, “Insurance and Taxes” of the ER 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Report Documentation Impact response to RAI 3.e. 
Environmental Report 

Environmental Report Request for Additional Information Page 47 of 186

RAI 3 

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

Isotopes Fluorine Products, Inc. (IIFP) facility. 

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

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

construction. 

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

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

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

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

RESPONSE: 

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

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

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

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

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

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

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

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

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

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

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

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

preconstruction and construction of the IIFP Facility are provided below: 

Estimated Property Taxes for the IIFP Facility During Initial Construction Periods 

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

Materials 

2011 Preconstruction $ 15,900 $ 22,700 

2012 Phase 1 Construction $ 87,800 $ 173,200 

2013 Continued Phase 1 

Construction 

$ 46,500 $ 246,900 

Future 

Years 

Future construction 

(such as the expansion 

to Phase 2) would occur 

in the years of 

operations and is 

included in the annual 

property taxes of the 

operating facility 

 

Environmental Report Documentation Impact: None. 
Environmental Report 

Environmental Report Request for Additional Information Page 48 of 186

RAI 3 

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

Isotopes Fluorine Products, Inc. (IIFP) facility. 

d. Identify the taxing entities including the two educational entities, as stated in Section 7.1.5.7, 

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

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

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

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

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

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

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

RESPONSE: 

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

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

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

Junior College. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

State. 

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

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

Environmental Report Request for Additional Information Page 49 of 186

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

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

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

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

(Expressed in Thousands of Dollars in Year 2009$)

Type of Taxa New Mexico

Phase 1

Lea 

County 

Phase 1

New Mexico 

Phase 2 

Increment

Lea County 

Phase 2 

Increment

Cumulative 

Phase 1 and 2 

Total

Gross Receipts 

Tax

High Estimate 118,100 8,800 165,400 12,400 304,700

Low Estimate 87,100 6,500 121,900 9,100 224,600

NM Corp. Income 

Taxb

High Estimate 77,200 N/Ac 222,400 N/Ac 299,600

Low Estimate 57,100 N/Ac 164.300 N/Ac 221,400

Property Tax

High Estimate Note “d” 13,700 Note “d” 12,700 26,400

Low Estimate Note “d” 8,700 Note “d” 8,100 16,800

TOTAL TAX 

ESTIMATE 

RANGE

144,200-

195,300

15,200-

22,500

286,200-

387,800

17,200-

25,100

462,800-

630,700

a

Tax Values based on Tax Rates as of 2009

b

Based on Average Earnings over the 40-Yr Analysis Period for the Proposed IIFP Facility c

Allocation would be made to the State of New Mexico

d

 Payments in lieu of property tax is distributed to school tax for Hobbs Municipal District and New Mexico Junior College.
Environmental Report 

Environmental Report Request for Additional Information Page 50 of 186

RAI 3 

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

Isotopes Fluorine Products, Inc. (IIFP) facility. 

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

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

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

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

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

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

RESPONSE: 

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

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

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

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

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

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

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

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

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

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

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

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

the operating periods of the IIFP Facility are provided below: 

The estimated annual property taxes for the IIFP Facility during the operations period are discussed in 

paragraph 7.1.5.7 of the IIFP Environmental Report. This paragraph is being updated as explained below.

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

Environmental Report Revision A has been revised to update estimates of property taxes and to show a 

break out of the taxes by Phase 1 and Phase 2 facility operations. 

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

incentive package and the Industrial Revenue Bond (IRB) issuance that IIFP has with Lea County New 

Mexico. There are two educational local school taxes that are not part of the exemption. Two school 

districts are not exempt by the IRB; the Hobbs Municipal School District and the New Mexico Junior 

College. For this “non-exempt” property tax, the IRB provides that IIFP pay in lieu of the property tax an 

amount equal to the amount of property taxes that IIFP would have been required to pay if the IRB had 

not be issued and the project property had, consequently, been subject to property taxation. The annual 

estimate of those property taxes is based on a formula and information provided by Lea County. The 

property taxes (payments in lieu of) are estimated at an average of $317,000-$344,000 annually during 

the Phase 1 facility operations period and $530,000-$660,000 annually for the Phase 2 facility operations 

(the combined integrated Phase 1 and Phase 2 facility).$350,000 annually for the total Phase 1 and Phase 

2 facility.
Environmental Report 

Environmental Report Request for Additional Information Page 51 of 186

RAI 4 

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

a. Clarify whether replacement capital costs are construction or operations costs. Although 

replacement capital covers activities that are similar to construction, these activities occur after 

2017, and thus would occur during the operations phase of the project. Chapter 7, “Cost-Benefit 

Analysis” of the ER (IIFP, 2009a) presents replacement capital as construction. 

The information in Chapter 7, “Cost-Benefit Analysis,” of the ER (IIFP, 2009a) either needs clarification 

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the 

EIS. 

RESPONSE: 

Replacement costs are capital costs that occur during the facility operations period in order to replace 

equipment, materials and infrastructure as needed to maintain the IIFP in a safe and reliable condition. As 

such, those replacement costs are considered as operation capital costs rather than facility construction 

costs. Replacement capital is estimated and expended as a cash flow in the year(s) in which equipment or 

infrastructure is being replaced. 

In addition to replacement capital, annual expenses for maintenance material are required for repair and 

normal maintenance of equipment and infrastructure. These annual maintenance material costs are 

estimated at about 3% to 5% of the facility direct capital cost. Operating supplies are also included in this 

category. Operating supplies, for example, include items such as gloves, personnel safety items, office 

supplies, lab chemicals, lubricating oils, custodial supplies, etc. Annual operating supplies are estimated 

at about 0.75% to 1.2% of the direct capital costs. 

Environmental Report Documentation Impact: The first two paragraphs of Section 7.1.5.4 of the IIFP 

Environmental Report Revision A is being updated as follows: 

Material required for repair and normal replacement of equipment and infrastructure is estimated at 3% to 

5% of the plant direct capital cost not including engineering procurement and construction management 

costs or contingency. Additionally, replacement capital is estimated and expended as a cash flow in the 

year in which the equipment or infrastructure would be replaced. Replacement costs are capital costs that 

occur during the facility operations period in order to replace equipment, materials and infrastructure as 

needed to maintain the IIFP in a safe and reliable condition. As such, those replacement costs are 

considered as operation (capital) costs rather than facility construction costs.

Operating supplies are also included in this category. Operating supplies, for example, include items such 

as gloves, personnel safety items, office supplies, lab chemicals, lubricating oils, custodial supplies, etc. 

Operating supplies are estimated at 0.75% to 1.25% of the direct capital costs. These percentages are 

based on published cost methodology data and experiences at similar facilities (Timmerhaus, Peters and 

West, 2003b). 
Environmental Report 

Environmental Report Request for Additional Information Page 52 of 186

RAI 4 

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

b. Provide an estimate of the distribution of replacement expenditures over/between Phase 1 and the 

Phase 2 increment. 

The information in Chapter 7, “Cost-Benefit Analysis,” of the ER (IIFP, 2009a) either needs clarification 

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the 

EIS. 

RESPONSE: Table 7-5 of the IIFP Environmental Report Revision A will be revised to show the refined 

updated replacement capital cost estimate. All of the estimated replacement capital costs over the 40 year 

analysis period occur after the expansion of the Phase 1 facility to the Phase 2 facility (the Phase 1 plus 

the add on expansions that result in the combined facility, that is the Phase 2 facility). All of the 

replacement occurs during the time of the Phase 2 facility operation because Phase 1 operates only about 

3-4 years before the expansions are completed that result in the Phase 2 cumulative facility operation. 

During the time frame between 2017 and 2050, approximately 51% of the replacement capital cost is 

related to equipment and infrastructures that were installed in the initial Phase 1 construction. The 

remaining 49% of replacement costs are for the incremental equipment and infrastructures that were 

installed in the expansion to a Phase 2 facility. Thus, the average annual replacement cost distributed to 

the Phase 1 initial equipment/infrastructure is about 1-1.2 million dollars and that for the incremental 

equipment and infrastructure for expansion to the Phase 2 facility is approximately 0.9-1.2 million dollars 

per year. 

Environmental Report Documentation Impact: Table 7-5 of the IIFP Environmental Report Revision 

A is revised to read as follows: 

Table 7- 5 Estimated Replacement Capital 

Time Period of Replacement Cost Projected to 

be Incurred 

Range of Estimated Replacement Costs 

(Millions of $) (Expressed in 2009 Dollars) 

Years 2010 through 2016 (Phase 1 Operation only 

until late 2016) 

No replacement capital; all is estimated initial capital 

2017-2027 (Phase 1 + Phase 2 Operation) 9-129-11

2028-2037 (Phase 1 + Phase 2 Operation) 28-36 35-43 

2038-2050 (Phase 1 + Phase 2 Operation) 23-36 32-39

Total 40 Year Analysis Period 60-85 76-93
Environmental Report 

Environmental Report Request for Additional Information Page 53 of 186

RAI 4 

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

c. Provide the cost of raw materials. Section 7.1.5.1, “Raw Materials”, of the ER (IIFP, 2009a) 

does not present the cost of raw materials, other than that they are “low.” 

The information in Chapter 7, “Cost-Benefit Analysis,” of the ER (IIFP, 2009a) either needs clarification 

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the 

EIS. 

RESPONSE: The FEP and De-conversion processes have a relatively low raw materials cost for a 

chemical plant. The fluoride value in the FEP and AHF products comes from extracted fluorine of the 

waste uranium enrichment customer tails material. The extracted fluoride from DUF6 is the major raw 

material of the FEP process. As a raw material, it effectively has a negative cost because IIFP is paid a 

service fee (revenue) for the de-conversion of DUF6. 

Raw material usages were determined from process flow sheets and mass balance calculations for each 

respective process. Raw material and treating agent unit costs were obtained from vendors and supplier 

budget-type quotes for purposes of the economic analyses. Some factors were applied in consideration of 

the estimated efficiencies of utilization as opposed to theoretical stoichiometry. Annual costs were 

derived for each production case by using the unit cost and production volumes. 

Table 7-6, “Major Raw Materials and Treating Agents,” will be revised to provide unit cost for the major 

raw materials and treating agents. The raw material and treating agent costs for the Phase 1 facility are 

estimated to be $1.89 million (yr-2009$) per year. The Phase 2 facility (cumulative of Phase 1 and 

expansion to the Phase 2 facility) raw material and treating agent costs are estimated to be $2.71 million 

annually. 

Environmental Report Documentation Impact: Table 7-6 from the Environmental Report Section 

7.1.5.1, “Raw Materials,” will be revised to add the unit costs for the raw materials. Table 7-6 will read as 

follows: 

Table 7- 6 Major Raw Materials and Treating Agents 

Raw Material or 

Treating Agent 

Units Costs

2009 US$ Comments 

Silicon dioxide (SiO2) $1.20/pound Alternative to be evaluated in pilot test. Diatomaceous earth of much 

less unit cost is an option contingent on the product purity tests.

Boric Oxide (B2O3) $1.50/pound Used in production of BF3 product. 

Calcium Hydroxide 

[Ca(OH)2] $0.06/pound Used in hydrated lime treatment of process water to regenerate KOH and neutralize small amounts of aqueous HF wastes

Potassium Hydroxide 

(KOH) $0.28/pound

Treating agent bought as a 45% solution and used in scrubbing 

emissions from process off-gas vents. The agent is regenerated and 

recycled to avoid process water discharges and to minimize usage. 

Small make-up is required.

Hydrogen-gaseous 

(H2) $1.75/100 cubic feet Estimates for economic analysis obtained from vendor quotes assuming that supply would come from a on-site packaged system. 
Environmental Report 

Environmental Report Request for Additional Information Page 54 of 186

RAI 4 

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

d. Provide the utilities cost for Phase 1 and an incremental amount for Phase 2. Section 7.1.5.2, 

“Utilities,” of the ER (IIFP, 2009a) presents costs for operations utilities. The text states that 

Phase 2 operations add significantly to Phase 1 utilities cost. The value of 2.5 to 3.5 million 

dollars per year is provided, but it is not clear for which phase this value applies. 

The information in Chapter 7, “Cost-Benefit Analysis,” of the ER (IIFP, 2009a) either needs clarification 

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the 

EIS. 

RESPONSE: The last paragraph of Section 7.1.5.2 will be revised to provide separate estimated annual 

cost of utilities for Phase 1 only and the Phase 2 (combined Phase 1 plus expansion to Phase 2) facilities. 

The type of utilities are the same for the Phase 1 and Phase 2 facility, but there is a significant increase in 

usage of utilities amounts beginning in about 2016, especially in steam and electricity, for the integrated 

Phase 2 facility after the Oxide plant add-on. 

Environmental Report Documentation Impact: The Environmental Report, Section 7.1.5.2, 

“Utilities,” will be revised to show updated utility costs Phase 1 and Phase 2 operations and the last two 

paragraphs of the Section will read as follows: 

The type of utilities are the same for the Phase 1 and Phase 2 facility, but there is a significant increase in 

usage of utilities amounts beginning in about 2016, especially in steam and electricity, for the integrated 

Phase 2 facility after the Oxide plant add-on. 

Approximately 2.5 to 3.3 million dollars per year of utilities are estimated to be procured from utility 

companies located in the region or State thereby benefiting the local and State economies. 

Approximately 1.5 million dollars (2009$) per year of utilities are estimated to be procured during the 

Phase 1 facility operations each year between 2013 and the beginning of 2017. An additional 1.7 million 

dollars (2009$) per year of utilities are estimated to be procured each year from 2017 through 2050 as a 

result of the expansion to the Phase 2 facility. After the expansion to Phase 2, the cumulative utilities 

procured will cost about 3.2 million dollars (2009$) each year from utility companies located in the 

region or State thereby benefiting the local and State economies. 
Environmental Report 

Environmental Report Request for Additional Information Page 55 of 186

RAI 4 

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

e. Provide sufficient data to quantify the sales and distribution annual costs for Phase 1 and Phase 

2 increment. Section 7.1.5.3, “Selling and Distribution,” of the ER (IIFP, 2009a) states, “The 

sales and distribution annual costs ... are estimated at 8% of the projected product cost.” It is 

not clear what the value of the “projected product cost” is. 

The information in Chapter 7, “Cost-Benefit Analysis,” of the ER (IIFP, 2009a) either needs clarification 

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the 

EIS. 

RESPONSE: The subject sales and distribution annual costs apply only to the high purity SiF4 product. 

There is no direct selling of the de-conversion services, other than agreements and contracts arranged 

between IIFP and suppliers/customers. Likewise the BF3 product and AHF by-product are sold in bulk 

quantities by contract agreements to a relatively small number of customers, thus the sales and marketing 

cost are minimal and absorbed in the product unit pricing. The added 8% sales and distribution is applied 

to the SiF4 because it is packaged and sold in smaller quantities to several customers thus requiring more 

marketing effort and incurring more direct distribution costs. 

The annual cost for the sales and distribution costs is estimated to be $200,000 to $250,000 based on 

year-2009$. There is essentially no difference in selling and distribution costs of the Phase 1 and future 

Phase 2 facility cumulative costs because production of fluoride compounds does not increase by the 

expansion to a Phase 2 facility 

Environmental Report Documentation Impact: None. 
Environmental Report 

Environmental Report Request for Additional Information Page 56 of 186

RAI 4 

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

f. Provide a breakdown of operations and maintenance materials costs for Phase 1 and Phase 2 

increment. Section 7.1.5.4, “Operational and Maintenance Materials,” of the ER (IIFP, 2009a) 

states that the average cost of maintenance materials and operating supplies are 3 to 4 million 

dollars annually, but the distinction between Phase 1 and Phase 2 is not clear. 

The information in Chapter 7, “Cost-Benefit Analysis,” of the ER (IIFP, 2009a) either needs clarification 

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the 

EIS. 

RESPONSE: The Phase 1 facility annual maintenance material costs and operating supplies costs are 

estimated at 2.1million dollars (in yr-2009$) and 0.63 million dollars (in yr-2009$), respectively. Those 

annual costs increase for the incremental expansion to a Phase 2 facility by $1.2 million per year for 

maintenance materials and by $0.36 million per year for operating supplies. The cumulative Phase 1 and 

Phase 2 facility annual maintenance material costs are estimated to be $3.3 million and the annual 

operating supplies costs are estimated to be $0.99 million. All these costs are expressed in year-2009$. 

Environmental Report Documentation Impact: None. 
Environmental Report 

Environmental Report Request for Additional Information Page 57 of 186

RAI 4 

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

g. Clarify Phase 1 and Phase 2 incremental costs for waste disposal. Table 7-10, “Estimated Range 

of Annual Waste Disposal Costs,” of the ER (IIFP, 2009a) presents the annual waste disposal 

costs for Phase 1 and Phase 2, but from the values, it seems that the Phase 2 column is the 

cumulative Phase 1 and 2 waste disposal costs. If the Phase 2 costs are cumulative of Phase 1 

and 2, then so state. 

The information in Chapter 7, “Cost-Benefit Analysis,” of the ER (IIFP, 2009a) either needs clarification 

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the 

EIS. 

RESPONSE: Phase 2 costs are cumulative of Phase 1 and Phase 2 costs because the Phase 2 facility 

results from an expansion of the initial Phase 1 facility.

Environmental Report Documentation Impact: Table 7-10 and its introduction in Section 7.1.5.6 of 

the IIFP Environmental Report Revision A will be changed to read as follows: 

Table 7-10 provides a range of estimated waste disposal costs by type of waste. The Phase 2 costs are 

cumulative of Phase 1 and Phase 2 costs because the Phase 2 facility results from an expansion of the 

initial Phase 1 facility.

Table 7- 10 Estimated Range of Annual Waste Disposal Costs 

Type Waste Phase 1 Facility (Thousand of $ Per 

Year in 2009$) 

Phase 1 and Phase 2 Facility 

(cumulative) (Thousands of $ Per 

Year in 2009$) 

Depleted uranium oxide 2,600-5,500 6,970 8,000-16,000 22, 500

Other process LLW 1,000-1,700 250-400 1,100-1,800 260-450

Misc. LLW 225-350 450-650 

RCRA 9-209- 35 14-2514-45

Sanitary 1-2 2-3 1-2 2-3
Environmental Report 

Environmental Report Request for Additional Information Page 58 of 186

RAI 4 

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

h. Provide 2010 market value per pound of each Fluorine Extraction Process product. 

The information in Chapter 7, “Cost-Benefit Analysis,” of the ER (IIFP, 2009a) either needs clarification 

or additional data, as described above, to perform a quantitative assessment of costs and benefits in the 

EIS. 

RESPONSE: Product market prices (in yr-2010$) of $30 per pound and $10 per pound are used for highpurity SiF4 and for BF3, respectively. The de-conversion service fees are expected to range from $ 2.40 

per pound DUF6 de-converted, where oxide disposal costs are paid (pass-through cost) by the customer, 

to $3.95 per pound where oxide disposal costs are not a pass-through cost to the customer. De-conversion 

costs are expressed in year-2010$. For purposes of the Environmental Report cost-benefit calculations, 

IIFP used a $3.85 (yr-2009$) per pound DUF6 estimated fee because oxide disposal costs are included in 

the cost-benefit information provided in the Environmental Report (See line item #1 of Table 7-10 in the 

report). 

Environmental Report Documentation Impact: None. 
Environmental Report 

Environmental Report Request for Additional Information Page 59 of 186

RAI 5 

Provide clarifications and additional information regarding UO2 shipments. 

a. Clarify the packaging and number of packages per shipment for UO2 byproduct material. Section 

3.2.2.2, “Facility Operation Phase,” of the ER (IIFP, 2009a) states that low-level radioactive 

waste (LLW) will be shipped in 55-gallon drums, with 20-25 drums per shipment. State whether 

these drums will contain the UO2 byproduct from the deconversion process, and whether the LLW 

discussed in Section 3.2.2.2 “Facility Operation Phase” is the UO2 byproducts from the 

deconversion process. If not, describe the packaging and truck loading for UO2 and describe the 

material that is considered LLW referred to in Section 3.2.2.2 “Facility Operation Phase.” 

The ER (IIFP, 2009a) provides scaled information from other analyses, but it does not present sufficiently 

detailed information for a project-specific analysis. The requested data above are necessary to perform a 

radiological consequence analysis with the computer code, RADTRAN, for the IIFP project in order to 

assess the associated transportation impacts in the EIS. 

RESPONSE: Packaging will be in DOT-approved containers that meet the requirements of 10 CFR 71 

(CFR, 2009m) and 49 CFR 171-173 (CFR, 2009hh; CFR, 2009ii). The exact amount (poundage) to be 

included in a container will depend on the bulk density of the material being shipped such that the number 

of containers in the shipments will meet the DOT load requirements. All LLW will be disposed off site, at 

a licensed burial site, including uranium oxides produced from the deconversion process.

For number of packages per shipment of each type of low-level wastes, see the Environmental Report 

Documentation Impact for RAI 5-e. 

Environmental Report Documentation Impact: The 1st paragraph of Section 3.2.2.2, “Facility 

Operations Phase,” subheading “Uranium Wastes” will be revised to provide this clarification and will be 

revised to read as follows: 

Uranium Wastes 

Radioactive waste materials will be transported in packages by truck via highway in accordance with 10 

CFR 71 (CFR, 2009m) and 49 CFR 171-173 (CFR, 2009hh; CFR, 2009ii). Detailed descriptions of 

radioactive waste materials which will be shipped from the IIFP facility for disposal are presented in ER 

Section 3.12, “Waste Management.” These wastes will typically be packaged and shipped in 55-gal 

drums using trucks with a nominal 20 to 25 drums per truck shipment. The exact amount (poundage) to 

be included in a container will depend on the bulk density of the material being shipped such that the 

number of containers in the shipments will meet the DOT load requirements. All LLW will be disposed 

off site, at a licensed burial site, including depleted uranium oxides produced from the deconversion 

process.
Environmental Report 

Environmental Report Request for Additional Information Page 60 of 186

RAI 5 

Provide clarifications and additional information regarding UO2 shipments. 

b. Provide the radionuclide inventory (in curies) of each package of UO2 and the expected dose rate 

at contact, 1 meter, and 2 meters. 

The ER (IIFP, 2009a) provides scaled information from other analyses, but it does not present sufficiently 

detailed information for a project-specific analysis. The requested data above are necessary to perform a 

radiological consequence analysis with the computer code, RADTRAN, for the IIFP project in order to 

assess the associated transportation impacts in the EIS. 

RESPONSE: Table RAI 5-e-1 will be used in the review and modeling for incident-free transport of 

radioactive material. Table 4-4, “Annual Incident-Free Transportation Radiological Dose to the Public 

and Worker,” will be updated for the uranium oxide and miscellaneous LLS shipments.

Table RAI 5-e-1, Shipments of Miscellaneous Low-Level Waste 

Waste Material 

Material 

Mass 

(lb/drum) 

Depleted 

Uranium 

Mass 

(lb/drum) 

Curies 

(Ci/drum) 

Expected Dose Rates 

Contact 1 meter 2 meters 

Activated Alumina 98 4.9 8.00 E-04 6.19E-02 6.35E-03 2.03E-03 

Air Ventilation 

Filters 14 0.28 4.57 E-05 3.72E-03 3.78E-04 1.21E-04 

Carbon 350 7 1.14 E-03 6.18E-02 6.46E-03 2.04E-03 

Clinkers of DUF4 1,000 750 1.22 E-01 1.55E+00 1.64E-01 5.05E-02 

Coke 140 1.4 2.29 E-04 1.71E-02 1.77E-03 5.63E-04 

Contaminated 

Pallets 210 2.1 3.43 E-04 2.32E-02 2.41E-03 7.65E-04 

Crushed Drums 392 3.9 6.37 E-04 2.55E-02 2.65E-03 8.33E-04 

Dust Collector 

Bags 70 10.5 1.71 E-03 1.38E-01 1.41E-02 4.52E-03 

Ion Exchange Resin 343 10.3 1.68 E-03 8.58E-02 8.99E-03 2.84E-03 

Radioactive Waste 

Trash 70 0.7 1.14 E-04 9.25E-03 9.45E-04 3.02E-04 

Scrap Metal 392 3.9 6.37 E-04 2.55E-02 2.65E-03 8.33E-04 

Sintered Metal 

Tubes 700 7 1.14 E-03 3.71E-02 3.92E-03 1.22E-03 

Sodium Fluoride 679 6.8 1.11 E-03 1.99E-02 2.08E-03 6.47E-04 

Spent Blasting Grit 1,000 50 8.16 E-03 1.94E-01 2.07E-02 6.39E-03 

Uranium Oxide 1,000 881.48 1.44E-01 1.83E+00 1.93E-01 5.95E-02 

Reference: DOE-STD-1136-2009, Section 2.5 

Curies/drum = (pounds DU per drum) x (453.59 gram/pound) x (3.6E-7 Curies/gram) 

Environmental Report Documentation Impact: Table 4-4, “Annual Incident-Free Transportation 

Radiological Dose to the Public and Worker,” will be revised based on these shipments of depleted 

uranium oxide and miscellaneous low-level wastes shown in Table 3-2, “Shipments Based on Estimated 

Annual Quantities of Low Level Waste Generated at the IIFP Facility.” See Environmental Report 

Documentation Impact for ER RAI-5e.
Environmental Report 

Environmental Report Request for Additional Information Page 61 of 186

RAI 5 

Provide clarifications and additional information regarding UO2 shipments. 

c. Clarify the number of shipments of UO2. In the ER, Table 4-4, “Annual Incident-Free 

Transportation Radiological Dose to the Public and Worker,” states that there will be 450 

shipments of uranium oxide and miscellaneous LLW. 

The ER (IIFP, 2009a) provides scaled information from other analyses, but it does not present sufficiently 

detailed information for a project-specific analysis. The requested data above are necessary to perform a 

radiological consequence analysis with the computer code, RADTRAN, for the IIFP project in order to 

assess the associated transportation impacts in the EIS. 

RESPONSE: 

The DOT maximum axle load limit is approximately 42,000 pounds. Density of the uranium oxide is 

approximately 2.5g/cc or 156 lb/ft3

. Drums can be filled to approximately 1,000 lb per drum plus 50 lb 

drum weight or a total 1,050 lb/drum of UO2. Shipments of UO2 will be expected to contain 

approximately 40 drums. Assuming consistent bulk density and 40 drums per shipment then Phase 1 UO2

shipments will be approximately 145-155. Other LLW materials will not be bulk density consistent, 

therefore, bulk density will be much smaller and trailers will be space limited or volume limited, not 

weight limited. 

Environmental Report Documentation Impact: Section 4.2.6.2, “Radioactive Treatment and 

Packaging Procedure,” will be revised to provide this clarification. Section 4.2.6.2 will read as follows:

4.2.6.2 Radioactive Treatment and Packaging Procedure 

Specific handling of radioactive and mixed wastes is discussed in detail in ER Section 3.12, “Waste 

Management.” Packaging of product material, radioactive waste and mixed waste will be in accordance 

with plant facility implementation procedures that follow 10 CFR 71 (CFR, 2009m) and 49 CFR 171-173 

(CFR, 2009hh; CFR, 2009ii). Depleted UF6 shipments will have additional packaging controls in 

accordance with ANSI N14.1 (ANSI, 2001). Waste materials will have additional packaging controls in 

accordance with each respective disposal or processing site's acceptance criteria (CFR, 2009m). The DOT 

maximum axle load limit is approximately 42,000 pounds. Density of the depleted uranium oxide is 

approximately 2.5g/cc or 156 lb/ft3. Drums can be filled to approximately 1,000 lb per drum plus 50 lb 

drum weight or a total 1,050 lb/drum of DUO2. Shipments of DUO2 will be expected to contain 

approximately 40 drums. Assuming consistent bulk density and 40 drums per shipment then Phase 1 

DUO2 shipments will be approximately 145 to 155 annually. In Phase 2 DUO2 total shipments are 

approximately 450 to 500 annually.

Other LLW materials will not be bulk density consistent, therefore, bulk density will be much smaller and 

trailers will be space limited or volume limited, not weight limited. These LLW materials will include:

• Activated Alumina,

• Activated Carbon

• Air Ventilation Filters,

• Carbon,

• Clinkers of DUF4,
Environmental Report 

Environmental Report Request for Additional Information Page 62 of 186

• Coke,

• Contaminated Pallets,

• Crushed Drums,

• Dust Collector Bags,

• Ion Exchange Resin,

• Radioactive Waste Trash,

• Scrap Metal,

• Sintered Metal Tubes,

• Sodium Fluoride, and

• Spent Blasting Sand/Grit.
Environmental Report 

Environmental Report Request for Additional Information Page 63 of 186

RAI 5 

Provide clarifications and additional information regarding UO2 shipments. 

d. Clarify if each of the 450 shipments contains 20-25 drums of UO2 per shipment. 

The ER (IIFP, 2009a) provides scaled information from other analyses, but it does not present sufficiently 

detailed information for a project-specific analysis. The requested data above are necessary to perform a 

radiological consequence analysis with the computer code, RADTRAN, for the IIFP project in order to 

assess the associated transportation impacts in the EIS. 

RESPONSE: 

The DOT maximum axle load limit is net 42,000 pounds. Density of the uranium oxide is approximately 

2.5g/cc or 156 lb/ft3

. Drums can be filled to approximately 1,000 lb per drum plus 50 lb drum weight or a 

total 1,050 lb/drum of DUO2. Shipments of DUO2 is expected to contain approximately 40 drums. 

Assuming consistent bulk density and 40 drums per shipment then Phase 1 DUO2 shipments will be 

approximately 145-155. In Phase 2, DUO2 total shipments are approximately 450-500. Other LLW 

materials will not be bulk density consistent, therefore, bulk density will be much smaller and trailers will 

be space limited or volume limited, not weight limited. 

Environmental Report Documentation Impact: See Environmental Report Documentation Impact for 

ER RAI 5-c for the revision of Section 4.2.6.2, “Radioactive Treatment and Packaging Procedure.” 
Environmental Report 

Environmental Report Request for Additional Information Page 64 of 186

RAI 5 

Provide clarifications and additional information regarding UO2 shipments. 

e. Describe the shipment of “miscellaneous LLW” in terms of types of packages, number of 

packages, and curie content. 

The ER (IIFP, 2009a) provides scaled information from other analyses, but it does not present sufficiently 

detailed information for a project-specific analysis. The requested data above are necessary to perform a 

radiological consequence analysis with the computer code, RADTRAN, for the IIFP project in order to 

assess the associated transportation impacts in the EIS. 

RESPONSE: Table RAI 5-e-1 will be used in the review and modeling for incident-free transport of 

radioactive material. Table 4-4, Annual Incident-Free Transportation Radiological Dose to the Public and 

Worker will be updated for the uranium oxide and miscellaneous LLS shipments. Section 3.2.2.2, 

“Facility Operations Phase,” will be revised to show the shipments of low-level wastes generated during 

the operations of the IIFP Facility. Also, Table 3-2, “Shipments Based on Estimated Annual Quantities of 

Low Level Waste Generated at the IIFP Facility,” will be added. Additionally, Section 4.2.4.3, 

“Operations” will be revised to show the impact from the low-level waste shipments along with other 

operational deliveries and UF6 cylinder shipments. 

Table RAI 5-e-1, Shipments of Miscellaneous Low-Level Waste 

Waste Material 

Estimated Material 

Mass 

(lb/drum) 

Depleted Uranium Mass 

(lb/drum) 

Curies 

(Ci/drum) 

Activated Alumina 98 4.9 8.00 E-04 

Activated Carbon 140 7 1.14E-03 

Air Ventilation Filters 14 0.28 4.57 E-05 

Carbon Filter Elements 350 7 1.14 E-03 

Clinkers of DUF4 1,000 750 1.22 E-01 

Coke 140 1.4 2.29 E-04 

Contaminated Pallets 210 2.1 3.43 E-04 

Crushed Drums 392 3.9 6.37 E-04 

Dust Collector Bags 70 10.5 1.71 E-03 

Ion Exchange Resin 343 10.3 1.68 E-03 

Miscellaneous 70 2.1 3.43E-04 

Radioactive Waste Trash 70 0.7 1.14 E-04 

Scrap Metal 392 3.9 6.37 E-04 

Sintered Metal Tubes 700 7 1.14 E-03 

Sodium Fluoride 679 6.8 1.11 E-03 

Spent Blasting Grit/Sand 1,000 50 8.16 E-03 

Uranium Oxide 1,000 881.48 1.44E-01 

Reference: DOE-STD-1136-2009, Section 2.5 

Curies/drum = (pounds DU per drum) x (453.59 gram/pound) x (3.6E-7 Curies/gram) 

Environmental Report Documentation Impact: The 2nd paragraph of the Environmental Report 

Section 3.2.2.2, “Facility Operations Phase,” subheading “Uranium Wastes” will be revised to show the 

shipments of low-level wastes generated during the operations of the IIFP Facility to read as follows: 
Environmental Report 

Environmental Report Request for Additional Information Page 65 of 186

Low-Level Radioactive Waste (LLW) generated from the processing the DUF6 will be shipped to an offsite disposal facility. The majority of wastes generated during the operations of the IIFP Facility will be 

LLW. The maximum number of shipments from each of the LLWs expected to be generated during Phase 

1 and Phase 2 operations is shown in Table 3-2. The expected disposal site is the Energy Solutions facility 

at Clive, UT. A potential site that could be licensed in the future is the Waste Control Specialists facility 

near Eunice, NM. Refer to ER Section 3.12.2.2, “Radioactive and MixedSolid Wastes Management,” for 

disposition options of other wastes. 

Table 3-2 Shipments Based on Estimated Annual Quantities of Low Level Waste Generated at the 

IIFP Facility

Material

Estimated 

Mass

(lb/drum)

Phase 1 Wastes Phase 2 Wastes

Range

(lb) Drums Shipmentsper yr*

Range

(lb)

Drums Shipments

per yr*

Activated 

Alumina 98 2,000-4,000 20-40 1 2,000-4,000 20-40 1

Air Ventilation 

filters 14 50-100 4-8 0.2 65-100 5-8 0.2

Carbon 350 25,000-

35,000 71-142 3.6 25,000-35,000 71-142 3.6

Off-specification

DUF4

1,000 5,000-

10,000 5-10 0.3 5,000-10,000 5-10 0.3

Coke 140 8,000-

12,000 58-86 2.2 8,000-12,000 58-86 2.2

Contaminated 

Pallets 210 1,000-4,000 14-57 1.4 3,000-

12,000 43-171 4.3

Crushed Drums 392 1,000-3,000 3-8 0.2 2,000-5,000 3-8 0.2

Dust Collector 

Bags 70 500-3,000 7-43 1.1 1,000-3,000 14-43 1.1

Ion Exchange 

Resin 343 1,000-2,000 3-6 0.2 2,000-4,000 6-12 0.3

Radioactive Waste 

Trash1 70 35,000-

55,000 500-785 19.6 70,000-100,000

1,000-

1,429 35.7

Scrap metal 392 4,000-8,000 10-20 0.5 12,000-

16,000 30-40 1

Sintered Metal 

Tubes 700 1,000-2,000 2-3 0.1 2,000-3,000 3-5 0.1

Sodium Fluoride 679 2,000-4,000 3-6 0.2 2,000-4,000 3-6 0.2

Spent Blasting 

Grit2 1,000 100-200 0 0 100-200 0 0

Uranium Oxide 1,000 2,800,000-

5,800,000 70-145 1383 8,700,000-18,000,000

8,700-

18,000 4293

*Maximum Shipments at 40 drums per trailer or 42,000

pounds/shipment 169 4801

1 waste not compacted.

2

 Blasting grit to be recycled.

3

Theoretically. Phase 1 shipments show average 145 to 155, while Phase 2 shipments should average 218 to 450.
Environmental Report 

Environmental Report Request for Additional Information Page 66 of 186

Environmental Report Documentation Impact: Section 4.2.4.3, “Operations” will be revised to show 

the impact from the low-level waste shipments along with other operational deliveries and UF6 cylinder 

shipments. 

The maximum potential increase to traffic due to operational deliveries and waste removal shipments 

during Phase 1 is estimated at about 2,650 round trips per year. This value is based on estimated 55700 

radiological shipments per year plus 2,1,9500 non-radiological shipments per year. Thus, an average of 

approximately 10 round trips for operational deliveries and waste management will occur daily during a 

normal 5-day work week. During Phase 2 operations, the number of radiological shipments per year will

increase to 2,150 or a total of 4,100 shipments annually. Operational delivery and waste removal 

shipments would increase to 16 round trips per year. Compared with the transportation commuting 

statistics in Lea County from the 2000 census data and the traffic count on the specific highways, this 

increase in traffic from operational deliveries and waste removal will be SMALL either for Phase 1 or 

Phase 2 operations. One mitigation measure to be considered by IIFP is to schedule operations worker 

shift changes and truck shipments for off-peak traffic periods, when practical. 

Environmental Report Documentation Impact: Section 4.2.6.3, “Incident-Free Scenario Radiological 

Dose,” will be revised to incorporate the revised shipments of uranium oxides and low-level wastes. 

Table 4-4, “Annual Incident-Free Transportation Radiological Dose to the Public and Worker,” will be 

revised based on these shipments of uranium oxide and miscellaneous low-level wastes shown in Table 3-

2, “Shipments Based on Estimated Annual Quantities of Low Level Waste Generated at the IIFP 

Facility.” 

4.2.6.3 Incident–Free Scenario Radiological Dose 

The radiological dose equivalents from incident-free transportation for categories of shipping are 

presented in Table 4-4, “Incident-Free Transportation Dose to the Public and Worker.” Each shipment 

category represents the various material shipments to and from the IIFP Ssite during Phase 2 operations. 

Within each category, radioactive material may be shipped to different locations. For calculation 

purposes, the worst-case dose equivalent was calculated and showed SMALL impact. The collective dose 

equivalent to the general public from the worst case (highest dose) route in each shipping category (waste 

and DUF6) totaled 1.50E-06 person-Sv/year (1.50E-04 person-rem/year). Similarly, the dose equivalent to 

the onlooker, driver and worker were 8.1911.76E-03, 9.509.21E-01, 3.0925.4E-08 04 person-Sv/year 

(8.1911.76E-01, 9.509.21E+00, 3.0925.4E-06 02 person-rem/year), respectively. 

The cumulative dose equivalent to the general public from transportation of DUF6 and solid waste was 

based on the model in NUREG/CR-0130 (NRC, 1978), which in turn was based on WASH-1238 (NRC, 

1972). NUREG/CR-0130 (NRC, 1978) defines the dose to the general public resulting from the 

transportation of radioactive materials as equal to 1.2E-07/person/Sv/km (1.9E-05 person-rem/mile), 

based on several demographic variables. This dose equivalent per distance was corrected for each route to 

or from the IIFP Ssite. The 2000 census demographics information was proportioned to each route, 

resulting in a correlated dose equivalent to the general public, while still employing the same assumption 

in NUREG/CR-0130 (NRC, 1978) and WASH-1238. 
Environmental Report 

Environmental Report Request for Additional Information Page 67 of 186

Table 4- 4 Annual Incident-Free Transportation Radiological Dose to the Public and Worker 

Facility 

Number 

of 

Shipments 

Distance 

(km) 

Dose Equivalent to General 

Public1 

Dose Equivalent to OnLookers2 Dose Equivalent to Drivers3 

Person-Sv Person-rem Person-Sv Person-rem Person-Sv Person-rem 

NEF, Eunice, NM 7895 56 1.41E-08 1.41E-06 2.70E-03 2.70E-01 9.31E-03 9.31E-01 USEC, Paducah, KY 7895 1,415 4.06E-07 4.06E-05 2.70E-03 2.70E-01 2.35E-01 2.35E+01 USEC, Piketon, OH 7895 1,950 7.15E-07 7.15E-05 2.70E-03 2.70E-01 3.24E-01 3.24E+01 GLE, Wilmington, NC 7895 2,350 5.91E-07 5.91E-05 2.70E-03 2.70E-01 3.91E-01 3.91E+01 NEF, Eunice, NM 7896 56 1.41E-08 1.41E-06 5.40E-03 5.40E-01 9.31E-03 9.31E-01 USEC, Paducah, KY 7896 1,415 4.06E-07 4.06E-05 5.40E-03 5.40E-01 2.35E-01 2.35E+01 USEC, Piketon, OH 7896 1,950 7.15E-07 7.15E-05 5.40E-03 5.40E-01 3.24E-01 3.24E+01 GLE, Wilmington, NC 7896 2,350 5.91E-07 5.91E-05 5.40E-03 5.40E-01 3.91E-01 3.91E+01 Energy Solutions, Clive, UT 

5007

4507

1635

1,636

5.95E-081.63E-08

5.95E-061.63E-06

1.27E-038.10E-05

1.27E-018.10E-03

2.21E-021.55E-01

2.21E+001.55E+01

WCS, Eunice, NMAndrews, TX

50074507

6156

2.75E-078.04E-09

2.75E-058.04E-07

1.27E-038.10E-05

1.27E-018.10E-03

2.69E-025.31E-03

2.69E+00

5.31E-01

GTS Duratek, Oak Ridge, TN 

5007

4507

1992

1,776

3.38E-086.77E-08

3.38E-066.77E-06

1.27E-038.10E-05

1.27E-018.10E-03

8.27E-041.68E-01

8.27E-02

1.68E+01

1Collective dose equivalent based on population density along route 2Collective dose equivalent to onlookers was calculated by multiplying the dose equivalent rate at 2 container, times 3 minutes, times 10 people exposed to each container, times number of shipments. 3Collective dose equivalent based on two truck drivers per shipmentgarage personnel was calculated by multiplying the dose equivalent rate at 2 m (6.6 ft) on side from the container, times 10 minutes, times two garage personnel exposed5 Full DUF6 Cylinders (removed Description Column from Revision A) 6 Empty DUF6 Cylinders 7 DUO2 and Misc. LLW Waste (Phase 1) 
Environmental Report 

Environmental Report Request for Additional Information Page 68 of 186

RAI 6 

Provide the radionuclide inventory of an “empty” DUF6 cylinder. 

Table 4-4, “Annual Incident-Free Transportation Radiological Dose to the Public and Worker,” of the 

ER (IIFP, 2009a) refers to 789 shipments of empty DUF6 cylinders. It is expected that these empty 

cylinders would contain a heel comprised of nonvolatile uranium progeny and possibly some nonsublimated DUF6. The curie content of these progeny would be considerably less than the heel described 

in Table D-1 of the Louisiana Energy Services (LES) EIS (NRC, 2005), which represents an enriched 

heel. The ER does not provide the radionuclide inventory of an empty cylinder and, thus, does not present 

sufficiently detailed information for a project-specific analysis. The requested data are necessary to 

perform a radiological consequence analysis with the computer code RADTRAN for the IIFP project in 

order to assess the associated transportation impacts in the EIS. 

RESPONSE: 

Nonvolatile uranium progeny produced in a DUF6 cylinder are assumed to remain after the cylinder is 

initially emptied. The heel of an empty cylinder generally contains no more than 50 pounds of depleted 

UF6 plus the quantities of progeny generated from decay of a full DUF6 cylinder. Table RAI 6-1 

illustrates the radionuclide inventory 30 days after the cylinder is initially emptied. Inventory values were 

determined by Microshield® 8.03 software. 

Table RAI 6-1 Radionuclide Inventory of an Empty DUF6 Cylinder 

Isotope Inventory 30 Days After Cylinder is Initially Emptied (Ci) 

Ac-227 1.82E-05

Bi-210 6.33E-07

Bi-211 1.82E-05

Bi-214 1.73E-06 

Fr-223 2.52E-07

Pa-231 3.65E-05

Pa-234 4.34E-03

Pa-234m 2.71E+00

Pb-210 6.34E-07

Pb-211 1.82E-05

Pb-214 1.73E-06

Po-210 6.15E-07

Po-211 4.96E-08

Po-214 1.73E-06

Po-215 1.82E-05

Po-218 1.73E-06

Ra-223 1.82E-05

Ra-226 1.73E-06

Rn-219 1.82E-05

Rn-222 1.73E-06

Th-227 1.79E-05

Th-230 1.61E-04
Environmental Report 

Environmental Report Request for Additional Information Page 69 of 186

Isotope Inventory 30 Days After Cylinder is Initially Emptied (Ci) 

Th-231 3.45E-02

Th-234 2.71E+00

Tl-207 1.81E-05

U-234 6.60E-04

U-235 6.39E-05

U-238 5.01E-03

Environmental Report Documentation Impact: None 
Environmental Report 

Environmental Report Request for Additional Information Page 70 of 186

RAI 7 

Provide information regarding hydrogen generation to support the description of the proposed action. 

a. Describe how hydrogen would be generated for use in the deconversion processes. 

The ER (IIFP, 2009a) contains limited information on the source of a major reactant. This information is 

needed in order to completely describe the proposed action within the EIS. 

RESPONSE: 

Hydrogen is generated on demand using a vendor supplied packaged unit. The hydrogen is produced by 

steam reforming natural gas followed by purification using pressure swing adsorption (PSA). This type 

system is being used at the DOE de-conversion plants (4 units installed at Portsmouth and 3 units 

installed at Paducah) and also in other commercial facilities for on-demand supply of hydrogen.

Environmental Report Documentation Impact: The hydrogen supply will be inserted into the 4th

paragraph of Section 2.1.3.2 with resulting in two paragraphs. The 4th paragraph and the resulting new 

paragraph will read as follows: 

The DUF6 cylinder is placed in a containment-type autoclave; where the contents are vaporized. The 

DUF6 vapor is fed to a reaction vessel where it undergoes exothermic reaction with hydrogen to produce 

DUF4 and AHF. The gaseous hydrogen supply for the DUF6 to DUF4 reaction vessel is generated on site 

using a vendor supplied packaged system of a safe design commonly used in other industrial applications. 

The hydrogen is produced by steam reforming natural gas followed by purification using pressure swing 

adsorption (PSA). The packaged unit is located about 107 m (350 ft) from the DUF4 Process Building and 

about 91 m (300 ft) from the nearest other process buildings. The generated hydrogen from the remote 

unit is piped through a relatively small diameter (about 1-2 in) steel pipe on an elevated pipe rack that has 

mechanical barrier protection. The piping enters the upper level of the DUF4 Process Building near the 

top of the reaction vessel mixing head. A minimum length of piping run is used inside the building. The 

unit when operating generates approximately 6-9 lb/hr of gaseous hydrogen at about 24.7 to 29.7 psia 

pressure. The unit starts and operates automatically to produce high purity hydrogen (> 99%) and is 

designed with internal safety system controls. The DUF6 to DUF4 process demand is estimated to be 

approximately 7 lb/hr. Theoretically, 12 to 18 lb/hr natural gas will be required to produce 6 to 9 lb/hr 

hydrogen. Assuming a unit efficiency of approximately 75% will place the natural gas requirement at 16 

to 24 pounds per hour or 359 to 539 SCFH. The 7 lb/hr demand will require 18.7 lb/hr or 420 SCFH of 

natural gas at 75% unit efficiency. No storage equipment is provided for the accumulation of hydrogen. 

However, a small surge tank is located at the package unit for pressure and flow control.

The DUF4 solid powder is continuously withdrawn from the reaction vessel bottom through a cooling 

screw mechanism and transferred to storage hoppers. A 2-stage dust collector system is provided to 

control and recycle DUF4 dusts that are internal to the solids handling equipment and generated by air or 

gas flows associated with the handling equipment. The DUF4 in the storage hoppers is transferred to the 

FEP plant for use as raw material feed in producing SiF4 and BF3. 
Environmental Report 

Environmental Report Request for Additional Information Page 71 of 186

RAI 7 

Provide information regarding hydrogen generation to support the description of the proposed action. 

b. Provide the production capacity of the hydrogen plant and the demand for hydrogen. 

The ER (IIFP, 2009a) contains limited information on the source of a major reactant. This information is 

needed in order to completely describe the proposed action within the EIS. 

RESPONSE: 

The hydrogen generating unit is capable of supplying approximately 6-9 lb/hr of gaseous hydrogen at 

about 24.7 to 29.7 psia. The DUF6 to DUF4 process demand is estimated to be approximately 7 lb/hr. The 

unit starts and operates automatically to produce high purity hydrogen (> 99%) and is designed with 

internal safety system controls. 

Environmental Report Documentation Impact: The 4th paragraph of Section 2.1.3.2 will be revised, 

resulting in two paragraphs. See Environmental Report Documentation Impact for RAI ER 7-a above. 
Environmental Report 

Environmental Report Request for Additional Information Page 72 of 186

RAI 7 

Provide information regarding hydrogen generation to support the description of the proposed action. 

c. State the hydrogen storage capacity. 

The ER (IIFP, 2009a) contains limited information on the source of a major reactant. This information is 

needed in order to completely describe the proposed action within the EIS. 

RESPONSE: 

No storage equipment is provided for the accumulation of hydrogen. However, a small surge tank is 

located at the package unit for pressure and flow control.

Environmental Report Documentation Impact: The 4th paragraph of Section 2.1.3.2 will be revised, 

resulting in two paragraphs. See Environmental Report Documentation Impact for RAI ER 7-a above. 
Environmental Report 

Environmental Report Request for Additional Information Page 73 of 186

RAI 7 

Provide information regarding hydrogen generation to support the description of the proposed action. 

d. State whether the provided natural gas demand includes the demand for generation of hydrogen. 

If not, provide the amount of natural gas required for hydrogen generation. 

The ER (IIFP, 2009a) contains limited information on the source of a major reactant. This information is 

needed in order to completely describe the proposed action within the EIS. 

RESPONSE: 

Theoretically, 12 to 18 lb/hr natural gas will be required to produce 6 to 9 lb/hr hydrogen. Assuming a 

unit efficiency of approximately 75% will place the natural gas requirement at 16 to 24 pounds per hour 

or 359 to 539 SCFH. The 7 lb/hr demand will require 18.7 lb/hr or 420 SCFH of natural gas at 75% unit 

efficiency. 

Environmental Report Documentation Impact: The 4th paragraph of Section 2.1.3.2 will be revised, 

resulting in two paragraphs. See Environmental Report Documentation Impact for RAI ER 7-a above. 
Environmental Report 

Environmental Report Request for Additional Information Page 74 of 186

RAI 8 

Provide additional information regarding air emissions during construction of the IIFP facility. 

a. Provide the site-specific assumptions that went into the estimates of the air emissions resulting 

from operation of off-road construction equipment in Table 4-11 of the ER (IIFP, 2009a). Include 

vehicle types and assumptions regarding quantity totals that make up the thirteen support 

vehicles and the thirteen construction vehicles. 

The requested air emissions and refueling information is needed to properly assess the impacts to air 

quality during construction. 

RESPONSE: 

The makeup and quantities of the thirteen construction vehicles and the thirteen support vehicles are 

shown in Table RAI 8-a-1 with the calculation of their contribution to each of the emission parameters. 

The calculations were performed in accordance with the Federal Energy Regulatory Commission, (FERC) 

Docket PF06-13-000. Downeast LNG Pre-filing Draft Resource Report 9, “Air and Noise Quality,” 

Appendix 9C, “Air Emissions Calculations – Terminal Construction,” July, 2006 (FERC, 2006). For the 

assumptions, all calculations are performed on a per hour basis. It is expected that construction in Phase 1 

will last approximately 18 months. Some the equipment will be utilized the entire time, some will be 

sequential, and others may be only intermittent. 

Table RAI 8-a-1 Emission Rates during Construction

Construction 

Equipment 

NOx 

lb/hr

VOC

lb/hr

SO2 

lb/hr

PM10

lb/hr

PM2.5

lb/hr

HAPS 

lb/hr

Tractor/Backhoe-2 0.760 0.110 0.324 0.022 0.084 0.082 

Grader 3.010 0.113 1.092 0.085 0.121 0.117 

Excavator 3.760 0.141 1.365 0.106 0.151 0.146 

Dump Trucks 2 1.720 0.200 0.560 0.046 0.150 0.150 

Dozer 3.010 0.113 1.092 0.085 0.121 0.117 

Air Compressors-2 3.760 0.128 0.846 0.100 0.108 0.104 

Concrete Pump 3.010 0.113 1.092 0.085 0.121 0.117 

Crane 0.640 0.144 0.757 0.019 0.128 0.124 

Fuel Truck 1.610 0.089 0.223 0.046 0.068 0.066 

Water Truck 1.740 0.107 0.391 0.053 0.101 0.098 

Support Equipment

Delivery Truck 0.064 0.002 0.011 0.000 0.002 0.002 

Light Duty Trucks-2 0.025 0.023 0.343 0.000 0.002 0.000 

Medium Duty Trucks-2 0.123 0.005 0.022 0.000 0.003 0.003 

Forklifts-2 2.780 0.172 0.626 0.084 0.162 0.156 

Flatbeds-2 2.780 0.172 0.626 0.084 0.162 0.156 

Generators-2 0.120 0.012 0.064 0.006 0.008 0.008 

Welding Machines 0.240 0.008 0.192 0.008 0.034 0.034 

Totals 29.152 1.652 9.626 0.826 1.526 1.480 

 TSP =1.2 tons/acre/month-AP42 section 13.2.3.3 

NOX – Nitrogen Oxides, VOC – Volatile Organic Chemicals, SO2 – Sulfur Oxides, PM10 Particulate Matter less than 10 microns, PM2.5 

Particulate Matter less than 2.5 microns, HAP – Hazardous Air Pollutants 
Environmental Report 

Environmental Report Request for Additional Information Page 75 of 186

Environmental Report Documentation Impact: Section 4.6.1, “Air Quality Impacts from 

Construction,” will be revised based on the calculations from the FERC reference. The 3rd, 4th, 5th and 6th

paragraphs will be revised the 9th paragraph will be deleted to read as follows: 

In addition to fugitive-dust emissions generated by the movements of heavy, off-road construction 

equipment at the IIFP facility site, additional air emissions will be released from the exhaust of the diesel 

engines used to power this equipment. Different mixes of heavy-duty, off-road construction equipment 

will be used for IIFP facility site preparation and access road construction (e.g., dozers, graders, loaders) 

than will be used during the later construction stages involving erection of the buildings, installation of 

utilities, and other general construction activities (e.g., cranes, forklifts, aerial lifts). Exhaust air emissions 

from diesel-engine-powered, off-road equipment consist of carbon monoxide (CO), hazardous air 

pollutants (HAP), nitrogen oxides (NOx), sulfur dioxide (SO2), PM, and VOCs. The emissions from each 

type of off-road equipment are a function of equipment-specific factors, including engine horsepower, 

load factor, and hours of operation. 

An estimate of the air emissions resulting from operation of the off-road construction equipment at the 

IIFP facility site was made using the site-specific assumptions. The estimated air emissions for the offroad construction equipment used at the IIFP facility site are presented in Table 4-11. 

Emission rates from vehicle exhaust and fugitive dust, as listed in Table 4-11, “Emission Rates during 

Construction,” were estimated for a 10-hour workday assuming peak construction activity levels were 

maintained throughout the yearper hour basis. Fugitive dust will originate predominantly from vehicle 

traffic on unpaved surfaces, earth moving, excavating and bulldozing, and to a lesser extent from wind 

erosion. It was assumed that the total disturbed area of the site was 16.2 ha (40 ac) and that the 

construction in Phase 1 will last approximately 18 months Some of the equipment will be utilize the entire 

time, some will be sequential, and others may be only intermittent. 

Table 4- 11 Emission Rates during Construction1

Pollutant Average Emissions1

g/hr lb/hr 

Vehicle Emissions 

Hydrocarbons as Aldehydes 272 0.6

Carbon Monoxide 3,400 7.5

Nitrogen Oxides 113,880222 269.2 

Volatile Organic Chemicals 748 1.7

Sulfur Oxides 7704,368 1.79.6

Particulates (PM10) 816376 10.8 

Particulates (PM2.5) 697 1.5

Hazardous Air Pollutants 671 1.5

Fugitive Emissions 

Particulates as TOC2 8,850 10.7

Total Suspended Particulates = 1.2 tons/acre/month

1

Based on 10 hours per day, 5 days per week, and 50 weeks per year 2

TOCs as evaporative exhaust crankcase refueling.

Source: APTS, 2009FERC, 2006. 

Of the combustion sources, vehicle exhaust will be the dominant source. Fugitive volatile emissions will 

also occur because vehicles will be refueled on site. Estimated vehicles that will be operating on the site 

during construction consist of two types: support vehicles and construction equipment. The support 
Environmental Report 

Environmental Report Request for Additional Information Page 76 of 186

vehicles included thirteen miscellaneous gasoline trucks and four smaller utility vehicles. Emission 

factors in AP-42 from the Federal Energy Regulatory Commission (FERC) Docket PF06-13-000 (FERC, 

2006) for highway mobile sources were used to estimate emissions of criteria pollutants and non-methane 

hydrocarbons for these vehicles. Thirteen pieces of miscellaneous construction equipment were used to 

estimate the emissions. Emission factors provided in AP-42, the U.S. Environmental Protection Agency's 

Compilation of Air Pollutant Emission Factors (EPA, 2009a) for diesel-powered construction equipment 

were used to estimate the total suspended particulates for these vehicles. Pre-licensing construction 

activities will reduce the work density and lower the concentration of air emissions at any given time. The 

gross amount of emissions will be unaffected. Gasoline and diesel fuel will be stored on site during 

construction and will be hand pumped into construction vehicles and other facility vehicles involved in 

construction. The fuel tanks will be stored on a containment-type pad, and trucks will be driven onto the 

containment-type pad to start the dispensing process. The pad will be sloped and curbed. The above 

ground fuel storage and dispensing apparatus is self-contained and includes a support frame on which a 

fuel storage tank is mounted and surrounded by a fuel containment vessel. 

No NAAQS has been set for hydrocarbons; however, the total annual emissions of hydrocarbons 

predicted from the site [approximately 12,130 kg (26,750 lb or 13.4 tons)] are well below the level of 

36,287 kg (40 tons) that defines a significant source of volatile organic compounds (40 CFR 50.21) (CFR, 

2009h). Air concentrations of the Criteria Pollutants predicted for vehicle emissions were all at least an 

order of magnitude below the NAAQS. PM10 emissions from fugitive dust were also below the NAAQS. 

The results of the fugitive dust estimates should be viewed in light of the fact that the peak anticipated 

fugitive emissions were assumed to occur throughout the year. These conservative assumptions will result 

in predicted air concentrations that tend to overestimate the potential impacts. ER Section 1.4.4,” State 

Agencies,” presents information regarding the status of all State of New Mexico permits.
Environmental Report 

Environmental Report Request for Additional Information Page 77 of 186

RAI 8 

Provide additional information regarding air emissions during construction of the IIFP facility. 

b. Describe how the on-site fueling of gasoline and diesel vehicles will take place. 

The requested air emissions and refueling information is needed to properly assess the impacts to air 

quality during construction. 

RESPONSE: 

Gasoline and diesel fuel will be stored on site during construction and will be hand pumped into 

construction vehicles and other facility vehicles involved in construction. The fuel tanks will be stored on 

a containment-type pad, and trucks will be driven onto the containment-type pad to start the dispensing 

process. The pad will be sloped and curbed for containment. The above ground fuel storage and 

dispensing apparatus is self-contained and includes a support frame on which a fuel storage tank is 

mounted and surrounded by a fuel containment vessel. The ER will be revised to address on-site fueling 

of IIFP vehicles. 

Environmental Report Documentation Impact: The 6th paragraph of Section 4.6.1, “Air Quality 

Impacts from Construction,” will be revised to address on-site fueling of gasoline and diesel vehicles. See 

the revised 6th paragraph of Section 4.6.1 from the Environmental Report Documentation Impact from 

RAI 8-a above. 
Environmental Report 

Environmental Report Request for Additional Information Page 78 of 186

RAI 8 

Provide additional information regarding air emissions during construction of the IIFP facility. 

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

The requested air emissions and refueling information is needed to properly assess the impacts to air 

quality during construction. 

RESPONSE: 

Assumptions 

1. A temporary on-site diesel fuel station is maintained to support construction activities. 

2. Assumed equipment types, quantities, maximum power, load factor, and weeks of operation are 

listed in Table RAI 8-c-1. 

3. Cumulative daily on-site fuel consumption of light duty, medium duty, and delivery trucks is 

equal to the fuel consumption of a single backhoe. 

4. Construction equipment is operated 10 hours per day, 5 days per week, 50 weeks per year. 

5. All construction equipment is fueled with diesel. 

6. On average, construction equipment consumes diesel fuel at a rate of 0.054 gal/hp-hr (ATTRA, 

2007). 

7. Annual storage tank evaporation losses are five percent of tank capacity (ATTRA, 2007). 

8. The temporary onsite fuel storage tank is equipped with enhanced vapor recovery equipment to 

minimize fugitive VOC emissions. 

Table RAI 8-c-1 Calculation of Average Annual Loaded Power 

Equipment Qty. 

Max 

Power 

(hp) 

Load 

Factor 

Loaded 

Power 

(hp) 

Total 

Loaded 

Power (hp) 

Weeks 

Operated 

Avg Annual 

Loaded 

Power (hp) 

Tractor/backhoe 2 150 0.21 31.5 63.0 36 45.4 

Grader 1 400 0.59 236.0 236.0 36 169.9 

Excavator 1 500 0.59 295.0 295.0 36 212.4 

Dump Trucks 2 300 0.21 63.0 126.0 36 90.7 

Dozer 1 400 0.59 236.0 236.0 36 169.9 

Air Compressor 2 325 0.43 139.8 279.5 50 279.5 

Concrete Pumps 1 125 0.43 53.8 53.8 36 38.7 

Crane 1 175 0.43 75.3 75.3 36 54.2 

Fuel Truck 1 250 0.59 147.5 147.5 50 147.5 

Water Truck 1 250 0.59 147.5 147.5 50 147.5 

Forklifts 2 200 0.59 118.0 236.0 50 236.0 

Flatbed, 2 ton 2 200 0.59 118.0 236.0 50 236.0 

Generators 2 33 0.43 14.2 28.4 50 28.4 

Welders 1 50 0.21 10.5 10.5 50 10.5 

Light, medium, 

and delivery trucks 1*

 75 0.105 7.9 7.9 50 7.9 

*

See assumption 3 
Environmental Report 

Environmental Report Request for Additional Information Page 79 of 186

Table RAI 8-c-2 Other IIFP Construction Parameters 

Value Units Reference Description 

10 hr/day n/a Hours Per Day That Construction Equipment Operates 

5 day/wk n/a Days Per Week That Construction Equipment Operates 

50 wk/yr n/a Weeks Per Year That Construction Equipment Operates 

0.054 gal/hp-hr ATTRA, 2007 Diesel Fuel Consumption Factor For Off-Road Equipment 

0.000028 lb/gal SBAP, 2010 Emission Factor For A Diesel Service Station 

2689 tons EPA, 2002 Annual VOC Emissions In Lea County For Year 2002 

53 lb/ft3 n/a Density Of Diesel Fuel 

0.1337 ft3/gal n/a Volume Conversion Factor 

2000 lb/ton n/a Mass Conversion Factor 

Table RAI 8-c-3 Calculate Onsite Fuel Consumption For Construction Equipment 

Average Annual Loaded Horsepower = 652 hp (sum of average annual loaded power listed in section 4.1) 

Annual Diesel Consumption = ( 652 hp ) × ( 10 hr/day ) × ( 5 day/wk ) × ( 50 wk/yr ) × ( 0.054 gal/hp-hr )

Annual Diesel Consumption = 88,020 gal

Table RAI 8-c-4 Calculate annual VOC emissions attributable to onsite fuel station operations

Annual VOC Emissions = ( 0.000028 lb/gal ) × ( 88020 gal ) 

Annual VOC Emissions = 2.46 gal 

Annual VOC Emissions = ( 2.46 gal ) × ( 53 lb/ft3 ) × ( 0.1337 ft3/gal ) 

Annual VOC Emissions = 17.43 pounds 

Table RAI 8-c-5 VOC Pollutant Emissions in Lea County, New Mexico 

Tier-1 Sources VOC Emissions (tons/yr) 

01 – Fuel Comb. Elec. Util. 0.0 

02 – Fuel Comb. Industrial 0.2 

03 – Fuel Comb. Other 95.3 

04 – Chemical & Allied Product Mfg 65.8 

06 – Petroleum & related industries 83.0 

07 – Other Industrial Processes 7.6 

08 – Solvent Utilization 683.0 

09 – Storage & Transport 511.0 

10 – Waste Disposal & Recycling 66.9 

11 – Highway Vehicles 951.0 

12 – Off-Highway 225.0 

14 – Miscellaneous 0.7 

Total 2,689 
Environmental Report 

Environmental Report Request for Additional Information Page 80 of 186

Table RAI 8-c-6 Compare IIFP fugitive VOC emissions with Lea County VOC emissions

Lea County Annual VOC Emissions = (2,689 tons ) × ( 2,000 lb/ton) 

Lea County Annual VOC Emissions = 5,378,000 pounds 

Fraction of IIFP Fuel Station Emissions to Lea County VOC Emissions = (17.43 pounds ) / ( 5,378,000 

pounds ) 

Fraction of IIFP Fuel Station Emissions to Lea County VOC Emissions = 3.2E-06 

Environmental Report Documentation Impact: The 10th paragraph (last paragraph) of Section 4.6.1, 

“Air Quality Impacts from Construction,” will be revised to show the impact of the operation of an onsite 

diesel fuel station. Additionally, A new paragraph 11 was added and Table 4-12 was updated to show the 

impact of total emissions during the construction of the IIFP Facility and will read as follows: 

Construction emissions generated in the site preparation phase could cause a local exceedance of the onehour NAAQS for NO2. However, NO2 concentrations would fall below the NAAQS at the site boundary 

and beyond. All other criteria pollutant concentrations attributable to construction activities would be well 

below the NAAQS. Peak year VOC and HAP emissions attributable to construction are 1.8 ton and 1.0 

ton, respectively. These emissions are negligible compared to annual VOC and HAP emissions in Lea 

County. The results of air modeling show that annual average and short-term ambient air concentrations 

from fugitive dust and on-site motor vehicle emissions produced by construction activities for the 

Proposed IIFP Facility will be orders of magnitude below the level of the applicable ambient air quality

standards. These incremental air quality impacts from the air emissions from preparation of the IIFP 

facility site and construction of the facility will not measurably change the existing ambient air quality in 

the vicinity of the Proposed IIFP Facility; therefore, the air quality impacts resulting from the 

preconstruction and general construction phases of the Proposed IIFP Facility are anticipated to be 

SMALL.

Additionally, the annual VOC emissions attributable to onsite fuel station operations from the annual

88,020 gal of diesel fuel consumption (ATTRA, 2007) is 17.4 lb (SBAP, 2010) which is 3.2E-06 fraction 

to the Lea County VOC emissions (EPA, 2002). Thus, annual VOC emissions attributable to the 

operation of an onsite diesel fuel station in support of IIFP construction activities represent a negligible 

increase in regional VOC emissions. The air quality impact resulting from the operation of an onsite 

diesel fuel station is SMALL. 

Table 4- 12 Predicted Property-Boundary Air Concentrations and Applicable National Ambient 

Air Quality Standards 

Emission Types Max 1-hr Max 3-hr Max 8-hr Max 24-hr Annual

Vehicle Emissions (μg/m3)

HC Modeled 

NAAQS

357

---

134

---

47

---

21

---

2

---

CO Modeled

NAAQS

4,441

40,000

1,670

---

591

10,000

258

---

20

---

NOx

Modeled

NAAQS

15,496

---

5,828

---

1,926

---

900

---

71

44

SOx

Modeled

NAAQS

998

---

375

1,310 

(secondary)

133

---

58

365

5

80
Environmental Report 

Environmental Report Request for Additional Information Page 81 of 186

PM10

Modeled

NAAQS

1,071

---

403

---

142

---

62

150

5

50

Fugitive Dust (μg/m3)

PM10

Modeled

NAAQS

11,548

---

4,343

---

1,536

---

671

150

53

50

HC – hydrocarbons; CO – carbon monoxide; NOx – nitrogen dioxide; SOx – sulfur oxides; PM10 – particulate matter less than 10 microns; 

NAAQS – National Ambient Air Quality Standards; μg/m3 – microgram per cubic meter; hr – hour--no standard

Pollutant Emissions 

(ton) Average NAAQS (ug/m3)

Maximum 

Impact (ug/m3)

Property 

Boundary 

Impact (ug/m3)

One Mile Impact 

(ug/m3)

CO 7.8 1-hr 10,000 115.7 29.0 17.05

8-hr 40,000 81.0 20.3 11.93

NOx 27.5 1-hr 100 373.41 93.7 55.03

Annual 188 6.1 1.5 0.90

PM2.5 8.0 24-hr 35 23.2 5.8 3.42

Annual 15 2.3 0.6 0.34

PM10 14.3 24-hr 150 40.4 10.1 5.95

SOx 0.8

1-hr 200 10.5 2.6 1.55

24-hr 365 1.8 0.4 0.26

Annual 80 0.2 0.0 0.03

HC – hydrocarbons; CO – carbon monoxide; NOx – nitrogen dioxide; SOx – sulfur oxides; PM10 – particulate matter less than 10 microns; 

NAAQS – National Ambient Air Quality Standards; μg/m3 – microgram per cubic meter; hr – hour--no standard

1

Exceedance of the NAAQS Standard

Assumptions:

1. Annual construction activities are performed 50 hours per week for 50 weeks 

2. Peak site preparation activities persist for 4 months in the first year

3. Post site-preparation activities persist for 7.5 months in the first year

4. Fugitive dust emissions are calculated separately for peak site preparation and post site-preparation

5. Fugitive TSP generation is 1.2 ton/acre/month for peak site preparation

6. Fugitive TSP generation is 0.3 ton/acre/month for the 3.25 months after site preparation is completed

7. Fugitive PM10 emissions are 15 percent of TSP

8. Fugitive PM2.5 emissions are 7.5 percent of TSP

9. The site is 40 acres

10. Sixty percent of the 40 acre site is disturbed at any given time

11. The disturbed area at any time has the same aspect ratio as the IIFP Site (aspect ratio = 1.3)

12. Sixty percent of construction equipment is operational at any given time

13. Application of water on unpaved surfaces reduces fugitive dust by 50 percent

14. All construction equipment is fueled with diesel

15. Construction equipment emission factors based on EPA AP-42

16. Regional impacts determined via SCREEN3 based on application of frequency-weighted site-specific meteorology
Environmental Report 

Environmental Report Request for Additional Information Page 82 of 186

RAI 9 

Provide additional information regarding air emissions during the operation of the IIFP facility. 

a. Describe representative capacity (make and models if available) of the gas-fired boilers to be 

used at the facility and the source of the data used to estimate the boiler emissions. 

The requested information is needed to properly assess the impacts to air quality during operation. 

Section 4.6, “Air Quality Impacts,” of the ER (IIFP, 2009a) contains much information on air dispersion 

coefficients and current annual emissions for the 50 mile radius. However, the ER does not include 

information on the plant boilers or diesel generators, or on the annual emissions expected from plant 

operations. In addition, the ER does not contain information on modeling input assumptions or stack 

parameter assumptions, and the meteorological data used for the ER (Midland-Odessa) or another NWS 

weather station have not been provided. 

RESPONSE: 

Boiler make and model has not been determined; however, emissions have been estimated using AP 42 

Table 1.4-1 and Table 1.4-2. IIFP requires two 10,000 lb/hr boilers operating one at a time. Further 

assumptions are presented below Table RAI 9-a. 

Table RAI 9-a Air Emissions during Operation of On-Site Boilers (Natural Gas) 

Pollutanta Emission Factor (lb/E+06 scf)b Tons/yrc

PM Total 7.6 0.49932 

SO2 0.6 0.03942 

NOx 100 6.57 

VOC 5.5 0.36135 

Methane 2.3 0.01971 

CO 84 5.5188 

TOC 11 0.7227 

CO2 120,000 7,884 a. PM10 – particulate matter less than 10 microns; SOx – sulfur oxides; NOx – nitrogen oxides; VOC – Volatile Organic Carbon; CO – carbon 

monoxide; TOC – Total Organic Carbon; CO2 – carbon dioxide b. Source AP 42 Table 1.4-1 and Table 1.4-2 Emission Factors For Criteria Pollutants and Greenhouse Gases From Natural Gas Combustion c. Assumptions: Emission Factor x scf x 8,760 hr/yr/2,000lb/ton = ton/yr 

Emission Factors from EPA –AP- 42, 1.4 natural gas emissions-uncontrolled. 

Two Boilers -10,000lb/hr each @ 80% efficiency, operate one at a time. 

1500 BTU/lb=15 MBTU/hr and at 1000 BTU/ft3

 =15000 scf/hr 

Environmental Report Documentation Impact: Table 4-13, “Air Emissions during Operations of OnSite Boilers,” will be revised as follows: 
Environmental Report 

Environmental Report Request for Additional Information Page 83 of 186

Table 4- 13 Air Emissions during Operation of On-Site Boilers (Natural Gas)

Pollutant Emission Factor Emissions (ton/year) 

Particulate Matter Less Than 10 Microns (PM10) 7.6E-06 0.50 

Sulfur Oxides (SOx) 6E-07 0.04 

Nitrogen Dioxide (NOx) 100E-06 6.57 

Volatile Organic Carbon (VOC) 5.5E-06 0.36 

Carbon Monoxide (CO) 8.4E-05 5.5 

TOC 11E-06 0.72 a. PM10 – particulate matter less than 10 microns; SOx – sulfur oxides; NOx – nitrogen oxides; VOC – Volatile Organic Carbon; CO – carbon 

monoxide; Total Organic Carbon; CO2 – carbon dioxide; TOC – total organic carbons b. Source AP 42 Table 1.4-1 and Table 1.4-2 Emission Factors For Criteria Pollutants and Greenhouse Gases From Natural Gas Combustion c. Assumptions: Emission Factors from EPA –AP- 42, 1.4 natural gas emissions-uncontrolled. Two Boilers -10,000lb/hr each @ 80% 

efficiency, operate one at a time. ~1500 BTU/lb=15 MBTU/hr and at 1000 BTU/ft3 =15000 scf/hr
Environmental Report 

Environmental Report Request for Additional Information Page 84 of 186

RAI 9 

Provide additional information regarding air emissions during the operation of the IIFP facility. 

b. Describe representative make and models of the diesel generators to be used at the facility, 

estimate the hours per year that the generators will be in use, and provide the source of the data 

used to estimate the generator emissions. 

The requested information is needed to properly assess the impacts to air quality during operation. 

Section 4.6, “Air Quality Impacts,” of the ER (IIFP, 2009a) contains much information on air dispersion 

coefficients and current annual emissions for the 50 mile radius. However, the ER does not include 

information on the plant boilers or diesel generators, or on the annual emissions expected from plant 

operations. In addition, the ER does not contain information on modeling input assumptions or stack 

parameter assumptions, and the meteorological data used for the ER (Midland-Odessa) or another NWS 

weather station have not been provided. 

RESPONSE: 

Diesel generator make and model have not been determined; however, emissions have been estimated 

using AP42 Table 3.4-1 and Table 3.4-2. IIFP standby generator will have an expected output of 530 HP 

and a firewater diesel pump with an output of approximately 75 HP. Emission data have been extracted 

from AP42 Tables 3.4-1 and 3.4-2. and modified based on the horsepower size from web site 

www.airquality.utah.gov to more conservative emissions. Additionally, air emissions from the on-site 

hydrogen generator have been estimated from vendor data. 

Environmental Report Documentation Impact: The 1st paragraph of 4.6.2, “Air Quality Impacts from 

Operations, will be revised to show the impact to the air emission from the addition of the fire-water 

pump and an-on-site hydrogen generator. “Table 4-14, “Estimated Air Emissions during Operation of OnSite Generator,” will be deleted and replaced with a table for on-site generators and fire water pumps with 

two emission factors (< and > 600 hp). Additionally, a new table (Table 4-15) will be added to show the 

air emissions from the operation of an on-site hydrogen generator. Section 4.6.2 will be revised as below. 

Table 4-16 is added to show the criteria pollutant emissions from the operation of the boilers, the 

hydrogen generator, the standby generator, and the water pumps. 

4.6.2 Air Quality Impacts from Operations 

On-site air quality will be impacted during operation due to the operation of boilers and an emergency 

diesel generator and fire-water pump. Additionally, the air quality will also be impacted by the operations 

of the on-site hydrogen generator. Operation emission types, source locations, and emission quantities are 

presented in Table 4-12, “Predicted Property-Boundary Air Concentrations and Applicable National 

Ambient Air Quality Standards.” Table 4-13 provides the air emissions from the operations of the on-site 

boilers, while Table 4-14 provides the air emissions from the operations of the on-site generator and firewater pump. Table 4-14 provides the emissions from the operation of the on-site hydrogen generator. 

Table 4-13, and Table 4-14, and Table 4-15 show that the total emissions from bothall these sources are 

far less than 100 tons per year. Thus, a Clean Air Act Title V permit will not be required. 

Table 4- 14 Estimated Air Emissions during Operation of On-Site Generators
Environmental Report 

Environmental Report Request for Additional Information Page 85 of 186

Pollutant Emission Factor (lb/gal) Emissions (lb/year)

Particulate Matter Less Than 10 

Microns (PM10) 0.0033 1.05

Sulfur Oxides (SOx) 0.00785 2.5

Nitrogen Dioxide (NOx) 0.24 7.7

Volatile Organic Carbon (VOC) 0.00034 0.1

Carbon Monoxide (CO) 0.005 1.6

PM10 – particulate matter less than 10 microns; SOx – sulfur oxides; NOx – nitrogen dioxide; VOC – Volatile Organic Carbon; CO – carbon 

monoxide

Table 4-14 Air Emissions during Operation of On-Site Generators and Fire Water Pumpc

Pollutanta Emission Factor 

lb/hp-hr <600 hp

Emission Factor 

lb/hp-hr >600 hp

Emissionsb 

(lb/year) 

Particulate Matter less 

than 10 microns (PM10) 0.0022 0.0007 25.3

Sulfur Oxides (SOx) 0.00205 0.0004045 23.575

Nitrogen Oxides (NOx) 0.031 0.024 356.5

Volatile Organic 

Chemicals (VOC) 0.002514 0.000705 28.911

Carbon Monoxide (CO) 0.00668 0.0055 76.82 a. PM10 – particulate matter less than 10 microns; SOx – sulfur oxides; NOx – nitrogen dioxide; VOC – Volatile Organic Carbon; CO – carbon 

monoxide b. Based on HP rating of 530 for diesel generator and 75 hp for diesel pump.

References: (1) AP-42-3.4 tables 3.4.1 and 3.4.2 Gaseous Emission Factors for large stationary diesel and all stationary dual-fuel engines

 (2) Air Emissions Internal Combusting Engines-Diesel page 2 emission factors for less than 600 HP

Assumptions: (1) Fire water pump operates 12 hours per year-for testing. Emission factor x HP x Hours = lb/yr

 (2) Diesel generator operates 20 hours per year-for testing. Emission factor x HP x Hours = lb/yr

Table 4-15 Air Emissions during Operation of On-Site Hydrogen Generation at the Hydrogen 

Generator Stack

Parameter Average Flue Gas Volume at 283 

scfm with H2 Demand of 35 scfm

Average Flue Gas Volume at 214 scfm

with H2 Demand of 13 scfm

Oxygen (O2) 13.98% 13.2 %

Nitrogen (N2) 72.88% 68.08 %

Water (H2O) 7.14% 6.74 %

Carbon Dioxide (CO2) 6.00% 5.66 %

Carbon Monoxide (CO) 42 ppm 39.6 ppm

Nitrogen Oxides (NOx) 4 ppm 3.8 ppm

Sulfur Oxides (SOx) 0 ppm 0 ppm

Volatile Organic 

Chemicals (VOC) 0 ppm 0 ppm

Hydrogen Sulfide (H2S) 0 ppm 0 ppm

Hydrogen (H2) 0 ppm 6%

Vendor Information-Air Liquide 1/31/2011

Table 4-16 shows the criteria pollutant emissions from the operation of the boilers, the hydrogen 

generator, the standby generator, and the water pumps. As seen from the Table, criteria pollutant 

emissions attributable to operations are well below the Title V thresholds. Regional impacts were 

evaluated with SCREEN3 based on frequency-weighted site-specific meteorological data. Maximum 
Environmental Report 

Environmental Report Request for Additional Information Page 86 of 186

pollutant concentrations are below the NAAQS, and concentrations at the site boundary are well below 

the NAAQS. Overall impacts on regional air quality would be small.

Table 4- 16 Air Emissions During IIFP Facility Operations

Pollutant Emissions 

(ton) Average NAAQS 

(ug/m3)

Maximum 

Impact 

(ug/m3)

Property 

Boundary 

Impact (ug/m3)

One Mile 

Impact 

(ug/m3)

CO 6.77 1-hr 10,000 49.20 6.12 3.18

8-hr 40,000 34.44 4.28 2.23

NO2 5.79 1-hr 100 78.30 9.74 5.07

Annual 188 6.26 0.78 0.41

PM2.5 0.51 24-hr 35 2.32 0.29 0.15

Annual 15 0.46 0.06 0.03

PM10 0.51 24-hr 150 2.32 0.29 0.15

SO2 0.05

1-hr 200 2.22 0.28 0.14

24-hr 365 0.89 0.11 0.06

Annual 80 0.18 0.02 0.01

Assumptions:

1

Criteria pollutant emission sources include the boilers, the hydrogen generator, the standby generator and fire water pumps 2

Boilers and hydrogen generator are assumed to operate 8760 hours per year 3

Standby generator and fire water pumps are operated 8 hours per week and 50 weeks per year 4

Regional impacts of criteria pollutant emissions evaluated as though released from a common stack, 12 meters tall, 0.2 meter diameter, 5.5 m/s 

exit velocity, and 422K exit temperature

5

Regional impacts calculated by SCREEN3 based on frequency-weighted site-specific meteorology
Environmental Report 

Environmental Report Request for Additional Information Page 87 of 186

RAI 9 

Provide additional information regarding air emissions during the operation of the IIFP facility. 

c. Describe the methods/analyses used to estimate the annual emissions from the facility, by 

pollutant, including the model (name and source of the model) used for estimating annual 

gaseous effluent concentrations, and modeling inputs and assumptions. 

The requested information is needed to properly assess the impacts to air quality during operation. 

Section 4.6, “Air Quality Impacts,” of the ER (IIFP, 2009a) contains much information on air dispersion 

coefficients and current annual emissions for the 50 mile radius. However, the ER does not include 

information on the plant boilers or diesel generators, or on the annual emissions expected from plant 

operations. In addition, the ER does not contain information on modeling input assumptions or stack 

parameter assumptions, and the meteorological data used for the ER (Midland-Odessa) or another NWS 

weather station have not been provided. 

RESPONSE: 

Process emissions from the IIFP Facility were estimated with the following assumptions: 

a. Scrubbers assumptions:-primary, secondary and tertiary with efficiencies 80%, 95% and 99% 

respectively (Total units-2 primary, 2 secondary, 2 tertiary). 

b. UF4 and Oxide Dust Collector Systems assumptions: 1% of hopper solids feed to primary dust 

collectors. Each dust collector has 99.5% efficiency (Total of 4 dust collectors for Phase 1and 6 for 

Phase 2). 

c. UF4 Vacuum Transfer Dust Collector System has primary plus secondary filter with 99.5 % 

efficiency and 99% efficiency, respectively. 

d. Calcium Fluoride Dust Collector System only has a primary filter and is 99.5% efficient from the 1% 

solids input. Dust Collector operates 4 hours per day = lb/hr x 310 days/yr. 

e. Lime Dust Collector 99.9% efficient, only used during unloading. 

f. Lb/yr = lb/hr x 8,760 x 0.85 on stream factor. 

A new table will be added to Section 4.6.2.1 to show the estimated emissions from the operations of the 

IIFP Facility. Additionally, Section 4.6.2.3 was revised and former tables 4-16 and 4-17 (new Tables 4-19 

and 4-20) will be updated with new calculations based on the new emission assumptions. 

Environmental Report Documentation Impact: Add new Table 4-17 “ Process Emissions from the 

Operation of the IIFP Facility” and revise the 1st paragraph of Section 4.6.2.1, “Description of Gaseous 

Effluents” to add the estimated process emissions from the operations of the IIFP Facility. The 1st

paragraph of Section 4.6.2.1 will read as follows with Table 4-17 inserted. 

4.6.2.1 Description of Gaseous Effluents 

Nonradioactive and radioactive process emissions were estimated for the operations of the IIFP Facility. 

Those process emissions are show in Table 4-17. Nonradioactive gaseous effluents include hydrogen 

fluoride (HF), silicon tetrafluoride (SiF4), and boron trifluoride (BF3) calcium fluoride (CaF2), lime, B2O3. 

HF releases are estimated to be about 8.999.8 kg (19.6 220 lb) each year with SiF4 and BF3 releases 

estimated at 82376 g (0.183 lb) and 39934.9 kg (0.8877 lb) each year. Approximately 72.6 kg (160 lb) of 

lime will be emitted annually from the operation of the IIFP Facility. Less than 3.5 kg (7.7 lb) of 

radioactive effluents are estimated in the stacks of the IIFP Facility. Predominately, emissions will come 
Environmental Report 

Environmental Report Request for Additional Information Page 88 of 186

from Ttwo natural gas-fired boilers that will be used to provide steam for the plant heating and autoclave 

feed system. Emission data estimated for the boilers indicate that it will not emit more than 13.2 metric 

tons (14.513 tons) per year of any regulated air pollutants. At 100% power, the boilers will emit 5.6 

metric tons (6.2 5.5 tons) per year of carbon monoxide (CO), 6.9 metric tons (7.66.6 tons) per year of 

nitrogen oxides (NOx), and 366 kg (0.4 tons) per year of volatile organic compounds (VOC). The boilers 

will also emit 5.6 metric tons (5.5 tons) per year of carbon monoxide. IIFP will investigate if Tthe boilers 

will not require an air quality permit from the State of New Mexico (NMEDAQB, 2009). 

Table 4-17 Process Emissions from the Operation of the IIFP Facility

Emission

Estimated Releases Phase 1

Estimated 

Additional 

Releases 

Phase 2

CaF2 Release 

Phase 2

Total Emissions

DUF6 to DUF4 

Scrubber Stack

DUF6 to DUF4

Dust Collector 

Stack

UF4 Vacuum 

Transfer Dust 

Collector

SiF4 & BF3 

Process 

Scrubber Stack

SiF4 & BF3 Dust 

Collector Stack

CaF2 Dust 

Collector

Lime Silo Dust 

Collector

B

O2 3 Silo

Oxide Process 

Scrubber Stack

Oxide Dust 

Collector Stack

CaF2 Dust 

Collector 

lb/yr

SiF4 N/A 0.007 0.82 0.827

BF3 N/A 3.9 104 107.9

HF 2.5 119 119 6.7 13.4 5.2 109 374.8

CaF2 7.4 1.3 1.3*

“U” 0.12 0.754 0.076 0.1 1.05

Lime 160 160

B2O3 0.54 0.54

Totals 2.5 119.12 119.754 10.607 118.296 7.4 160 0.54 5.2 109.1 1.3 646.417

*Phase 2 operations are not additive with Phase 1 operations for CaF2 since CaF2 is produced in much lower quantities during the Phase 2 

operations because the Phase 1 KOH scrubbing solution can be replaced with water.

a. Scrubbers assumptions:-primary, secondary and tertiary with efficiencies 80%, 95% and 99% respectively (Total units-2 primary, 2 

secondary, 2 tertiary).

b. UF4 and Oxide Dust Collector Systems assumptions: 1% of hopper solids feed to primary dust collectors. Each dust collector has 99.9% 

efficiency (Total of 4 dust collectors for Phase 1and 6 for Phase 2). 

c. UF4 Vacuum Transfer Dust Collector System has primary plus secondary filter with 99.5 % efficiency and 99% efficiency, respectively.

d. Calcium Fluoride Dust Collector System only has a primary filter and is 99.9% efficient from the 1% solids input. Dust Collector operates 4 

hours per day = lb/hr x 310 days/yr. 

e. Lime Dust Collector 99.9% efficient, only used during unloading.

f. Lb/yr = lb/hr x 8,760 x 0.85 on stream factor.

Environmental Report Documentation Impact: Table 4-16 “Dispersion Coefficients for Gaussian 

Plume Models” will be revised and renamed/renumbered Table 4-19 “Dispersion Coefficients Formulas 

Recommended by Briggs.” Additionally, Table 4-17, “Annual Average Atmospheric Dispersion 

Coefficients,” will be revised and renamed/renumbered Table 4-20 “Annual Average Dilution Factors by 

Sector and Distance for Lea County, NM (sec/m3

). Section 4.6.2.3 will be renamed “Calculations of 

Dilution Factors and Pollutant Dispersion” with text removed and replaced to address different 

modeling. 
Environmental Report 

Environmental Report Request for Additional Information Page 89 of 186

4.6.2.3 Calculation of Dilution Factors and Pollutant DispersionAtmospheric Dispersion 

and Deposition Factors

NUREG-1748 (NRC, 2003a) requires that atmospheric dispersion factors (X/Q's) be used to assess the 

environmental effects of normal plant operations and facility accidents. In the absence of on-site 

meteorological data, the analysis may be conducted using data from 5-year National Weather Service 

(NWS) summaries, provided applicability of these data to the proposed site is established. The X/Q's have 

been calculated using meteorological data from Midland-Odessa, Texas (1987 to 1991) and the Guassian

plume model equation documented in NUREG/CR-6410 (NRC 1988) and recommended in NRC 

Regulatory Guide 1.111 (NRC, 1977). The dispersion parameter is defined as:

χ/Q = 1 / (2πu σyσz)*exp(−0.5y2/σy

2

)*{exp[−0.5(z−h)2/σz

2

] + exp[−0.5(z+h)2/σz

2

]} 

where:

χ/Q = dispersion parameter, sec/ m3

U = wind speed, m/sec

σy and σz = dispersion coefficients in the y, and z directions, m

y = lateral distance of the receptor from the plume centerline at the downwind 

location, m (assumed to be zero if the receptor is at the centerline)

z = elevation of the receptor above the release point elevation at the downwind 

location (assumed to be 1.7 m)

h = release height above the ground, m (assumed to be zero for ground-level 

releases) 

Dispersion coefficients for Stability Classes A through F are computed from the equations shown in Table 

4-16 below, where x = downwind distance, m. 

Table 4-16Dispersion Coefficients for Gaussian Plume Models

Stability Class σy, m σz, m

A 0.22x*(1+0.0001x)-1/2 0.20x

B 0.16x*(1+0.0001x)-1/2 0.12x

C 0.11x*(1+0.0001x)-1/2 0.08x*(1+0.0002x)-1/2

D 0.08x*(1+0.0001x)-1/2 0.06x*(1+0.0015x)-1/2

E 0.06x*(1+0.0001x)-1/2 0.03x*(1+0.0003x)-1/2

F 0.04x*(1+0.0001x)-1/2 0.016x*(1+0.0003x)-1/2

Use of the Midland-Odessa data for predicting the dispersion of gaseous effluents was deemed 

appropriate. Midland-Odessa, Texas is the closest first-order NWS station to the IIFP site and both 

Midland-Odessa and the IIFP site have similar climates. A first-order weather data source is one that is a 

major weather station staffed by NWS personnel.

Distances to the 16.2-ha (40-ac) Site boundary were determined using guidance from NRC Regulatory 

Guide 1.145 (NRC, 1983). Annual average atmospheric dispersion is presented in Table 4-17 out to 80 

km (50 mi).

For steady effluent releases, pollutant concentrations are determined based on the Gaussian Plume Model 

documented in NUREG/CR-6410 (NRC 1998a) and recommended in NRC Regulatory Guide 1.111 

(NRC, 1977b).
Environmental Report 

Environmental Report Request for Additional Information Page 90 of 186

 

where:

C(x,y,z) = pollutant concentration at point (x,y,z), mg/m3 or Ci/m3

Q = release rate in mg/sec or Ci/sec

u = average wind speed, m/sec

σy and σz = dispersion coefficients in the y, and z directions, m

y = lateral distance of the receptor from the plume centerline, m

z = elevation of the receptor above the release point elevation, m

h = release height above the ground, m

Dispersion coefficients for Stability Classes A through F are calculated from the empirically-derived 

Briggs Formulas shown in Table 4-19 (NRC 1998a), where x = downwind distance, m. 

Table 4- 19 Dispersion Coefficient Formulas Recommended by Briggs

Stability Class σy, m σz, m

A 0.22x*(1+0.0001x)-1/2 0.20x

B 0.16x*(1+0.0001x)-1/2 0.12x

C 0.11x*(1+0.0001x)-1/2 0.08x*(1+0.0002x)-1/2

D 0.08x*(1+0.0001x)-1/2 0.06x*(1+0.0015x)-1/2

E 0.06x*(1+0.0001x)-1/2 0.03x*(1+0.0003x)-1/2

F 0.04x*(1+0.0001x)-1/2 0.016x*(1+0.0003x)-1/2

Dilution factors are determined as a quotient of the pollutant concentration and the pollutant release rate:

Dilution Factor = C(x,y,z) / Q, sec/m3

Based on more than a year of site specific meteorological data obtained from the State of New Mexico for

the southeastern region of the state (NMED 1998), the average annual dilution factors for the 50 mile (80 

km) region around the IIFP Site were determined. The results are illustrated in Table 4-20. 

Table 4-20 

Average Annual Dilution Factors by Sector and Distance for Lea County, NM (sec/m3)

Vector 1 mi 2 mi 3 mi 4 mi 5 mi 10 mi 20 mi 30 mi 40 mi 50 mi

N 1.19E-05 4.69E-06 2.65E-06 1.77E-06 1.31E-06 5.33E-07 2.33E-07 1.48E-07 1.08E-07 8.47E-08

NNE 1.50E-05 5.93E-06 3.34E-06 2.23E-06 1.65E-06 6.70E-07 2.93E-07 1.85E-07 1.35E-07 1.06E-07

NE 1.45E-05 5.76E-06 3.25E-06 2.18E-06 1.61E-06 6.59E-07 2.89E-07 1.83E-07 1.34E-07 1.05E-07

ENE 1.19E-05 4.82E-06 2.74E-06 1.85E-06 1.37E-06 5.61E-07 2.47E-07 1.56E-07 1.14E-07 8.99E-08

E 1.68E-05 7.02E-06 4.00E-06 2.69E-06 1.99E-06 8.12E-07 3.56E-07 2.25E-07 1.64E-07 1.29E-07

ESE 2.11E-05 8.92E-06 5.07E-06 3.40E-06 2.51E-06 1.02E-06 4.45E-07 2.82E-07 2.05E-07 1.61E-07

SE 2.19E-05 9.17E-06 5.20E-06 3.49E-06 2.57E-06 1.04E-06 4.55E-07 2.88E-07 2.10E-07 1.65E-07
Environmental Report 

Environmental Report Request for Additional Information Page 91 of 186

Vector 1 mi 2 mi 3 mi 4 mi 5 mi 10 mi 20 mi 30 mi 40 mi 50 mi

SSE 1.66E-05 6.64E-06 3.75E-06 2.51E-06 1.85E-06 7.55E-07 3.30E-07 2.09E-07 1.53E-07 1.20E-07

S 1.25E-05 4.96E-06 2.81E-06 1.89E-06 1.40E-06 5.75E-07 2.53E-07 1.61E-07 1.17E-07 9.23E-08

SSW 1.43E-05 5.76E-06 3.27E-06 2.19E-06 1.62E-06 6.63E-07 2.91E-07 1.84E-07 1.34E-07 1.06E-07

SW 1.74E-05 7.26E-06 4.13E-06 2.77E-06 2.05E-06 8.35E-07 3.65E-07 2.31E-07 1.69E-07 1.33E-07

WSW 1.71E-05 7.00E-06 3.96E-06 2.65E-06 1.96E-06 7.96E-07 3.48E-07 2.20E-07 1.61E-07 1.26E-07

W 1.49E-05 5.75E-06 3.22E-06 2.15E-06 1.58E-06 6.44E-07 2.82E-07 1.78E-07 1.30E-07 1.02E-07

WNW 1.38E-05 5.18E-06 2.88E-06 1.92E-06 1.42E-06 5.76E-07 2.52E-07 1.60E-07 1.17E-07 9.18E-08

NW 1.15E-05 4.28E-06 2.39E-06 1.60E-06 1.18E-06 4.82E-07 2.12E-07 1.34E-07 9.81E-08 7.72E-08

NNW 9.78E-06 3.70E-06 2.08E-06 1.39E-06 1.03E-06 4.22E-07 1.86E-07 1.18E-07 8.61E-08 6.78E-08

Source: NMED 1998

Environmental Report Documentation Impact: Tables 4-23 and 4-24 have been updated with new 

calculation based on updated emission data. Additionally, Tables 4-23 and 4-24 have been renumbered 

Table 4-25 “Estimated Annual Non-Radiological Gaseous Effluent” and Table 4-26 “Estimated and 

Bounding Radiological Releases from the Stacks.” Section 4.12.1.1 (renumbered 4.12.1.2) “Routine 

Gaseous Effluent,” paragraph one will be revised to accommodate table renumbering. 

4.12.1.21 Routine Gaseous Effluent 

Routine gaseous effluents from the plant are listed in Table 4-253, “Estimated Annual Non-Radiological 

Gaseous Effluent.” Radiological effluent estimates are shown in Table 4-264, “Estimated and Bounding 

Radiological Releases from the Stacks.” Worker exposure to in-plant gaseous effluents will be minimal. 

No exposures exceeding 29 CFR 1910, Subpart Z are anticipated (CFR, 2009g). Laboratory and 

maintenance operations activities involving hazardous gaseous or respirable effluents will be conducted 

with ventilation control (i.e., fume hoods, local exhaust or similar) and/or with the use of respiratory 

protection as required. All regulated gaseous effluents will be below regulatory limits as specified by the 

New Mexico Air Quality Bureau. 

Table 4- 25 Estimated Annual Non-Radiological Gaseous Effluent. 

Emission 

Estimated Releases 

DUF6 to DUF4 

Stack 

SiF4 & BF3 

Production Stack 

DUF6 to DU 

Oxide Stack 

SiF4 N/A 0.380.08 kg/yr (0.82718

lb/yr) N/A 

BF3 N/A 48.940.40 kg/yr (107.90.88

lb/yr) N/A 

HF 54.031.19 kg/yr 

(2.63119.12 lb/yr) 

58.475.17 kg/yr 

(128.90311.39 lb/yr) 

51.852.78 kg/yr 

(114.36.13 lb/yr) 

Table 4-26, Estimated and Bounding Radiological Releases from the Stacks 

Radionuclide

DUF6 to DUF4 SiF4 &BF3 DUF6 to DU 

Stack Production Stack Oxide Stack

kBq/yr Ci/yr kBq/yr Ci/yr kBq/yr Ci/yr
Environmental Report 

Environmental Report Request for Additional Information Page 92 of 186

Estimated Releases

234U 2.48E+03 6.71E-05 1.09E+03 2.95E-05 1.82E+03 4.92E-05

235U 2.40E+02 6.48E-06 1.06E+02 2.85E-06 1.76E+02 4.75E-06

238U 1.88E+04 5.09E-04 8.29E+03 2.24E-04 1.38E+04 3.73E-04

Total 2.16E+04 5.83E-04 9.49E+03 2.56E-04 1.58E+04 4.27E-04

Bounding Releases

234U 4.97E+03 1.34E-04 2.19E+03 5.91E-05 3.64E+03 9.84E-05

235U 4.80E+02 1.30E-05 2.11E+02 5.71E-06 3.52E+02 9.51E-06

238U 3.77E+04 1.02E-03 1.66E+04 4.48E-04 2.76E+04 7.47E-04

Total 4.31E+04 1.17E-03 1.90E+04 5.13E-04 3.16E+04 8.55E-04

Radionuclide

DUF6 to DUF4 

Stack

SiF4 & BF3 

Production Stack

DUF6 to DU 

Oxide Stack

kBq/yr Ci/yr kBq/yr Ci/yr kBq/yr Ci/yr

Estimated Releases

234U 2.15E+02 5.80E-06 2.09E+02 5.66E-06 4.19E+02 1.13E-05

235U 2.12E+01 5.73E-07 2.07E+01 5.59E-07 4.15E+01 1.12E-06

238U 1.65E+03 4.45E-05 1.61E+03 4.34E-05 3.22E+03 8.70E-05

Total 1.88E+03 5.08E-05 1.84E+03 4.96E-05 3.68E+03 9.94E-05

Bounding Releases

234U 4.29E+02 1.16E-05 4.19E+02 1.13E-05 8.39E+02 2.27E-05

235U 4.24E+01 1.15E-06 4.14E+01 1.12E-06 8.29E+01 2.24E-06

238U 3.29E+03 8.89E-05 3.21E+03 8.68E-05 6.43E+03 1.74E-04

Total 3.76E+03 1.02E-04 3.67E+03 9.93E-05 7.36E+03 1.99E-04

Environmental Report Impact: Beginning with the 8thparagraph of Section 4.12.2.2, (Renumbered 

4.12.2.2.2), “Public and Occupational Exposure Impacts,” will be revised. Former Table 4-25, “Annual 

and Committed Dose Equivalents for Exposures to the MEI from Gaseous Effluents” (renumbered Table 

4-27) and Former Table 4-26, “Annual and Committed Dose Equivalents for Exposures to the Nearest 

Resident from Gaseous Effluents” (renumbered Table 4-28). Former Figure 4-20 (renumber 4-19) will be 

replaced to identify the location of nearest neighbor. Former Table 4-27 (new 4-29) will be revised with 

updated calculations. Former Table 4-28 and 4-29 (new Table 4-30 and 4-31) will be revised to 

incorporate recalculated data. Section 4.12.2.2 beginning with the 8th paragraph will read as follows:” 

Dose equivalents for the MEI and the nearest resident due to gaseous effluents were calculated by 

pathway for the total body in adults, teens, children, and infants, and are presented in Tables 4-275 and 

Table 4-2628, respectively. The CEDE for the adult MEI from the Proposed IIFP Facility emissions was 

calculated to be 8.405.17E-06 08 mSv (8.405.17E-04 06 mrem) per year. For the adult full-time resident 

nearest to the facility, the CEDE from the IIFP facility was calculated to be 2.64E-08 6.40E-09 Sv 

(2.64E-066.40E-07 rem) per year. 
Environmental Report 

Environmental Report Request for Additional Information Page 93 of 186

Table 4- 25 Annual and Committed Dose Equivalents for Exposures to the MEI from Gaseous 

Effluents

Source Units Adult EDE Teen EDE Child EDE Infant EDE

Cloud Immersion Sv 9.78E-16 9.78E-16 9.78E-16 9.78E-16

rem 9.78E-14 9.78E-14 9.78E-14 9.78E-14

Inhalation Sv 8.14E-08 9.77E-08 1.65E-07 3.46E-07

rem 8.14E-06 9.77E-06 1.65E-05 3.46E-05

Ingestion Sv 2.21E-09 3.32E-09 3.98E-09 1.66E-08

rem 2.21E-07 3.32E-07 3.98E-07 1.66E-06

Ground Plane Exposure Sv 3.53E-10 3.53E-10 3.53E-10 3.53E-10

rem 3.53E-08 3.53E-08 3.53E-08 3.53E-08

Sum Total Sv 8.40E-08 1.01E-07 1.69E-07 3.63E-07

rem 8.40E-06 1.01E-05 1.69E-05 3.63E-05

Table 4-27, Annual and Committed Dose Equivalents for Exposures to 

the MEI from Gaseous Effluents

Source Units Adult EDE Teen EDE Child EDE Infant EDE 

Cloud Immersion 

Sv 8.54E-16 8.54E-16 8.54E-16 8.54E-16 

rem 8.54E-14 8.54E-14 8.54E-14 8.54E-14 

Inhalation 

Sv 4.94E-08 5.93E-08 1.00E-07 2.10E-07 

rem 4.94E-06 5.93E-06 1.00E-05 2.10E-05 

Ingestion 

Sv 1.93E-09 2.90E-09 3.48E-09 1.45E-08 

rem 1.93E-07 2.90E-07 3.48E-07 1.45E-06 

Ground Plane 

Exposure 

Sv 3.08E-10 3.08E-10 3.08E-10 3.08E-10 

rem 3.08E-08 3.08E-08 3.08E-08 3.08E-08 

Total Dose 

Sv 5.17E-08 6.26E-08 1.04E-07 2.25E-07 

rem 5.17E-06 6.26E-06 1.04E-05 2.25E-05 

Table 4- 26 Annual and Committed Dose Equivalents for Exposures to the Nearest Resident from 

Gaseous Effluents

Source Units Adult EDE Teen EDE Child EDE Infant EDE

Cloud Immersion Sv 7.46E-17 7.46E-17 7.46E-17 7.46E-17

rem 7.46E-15 7.46E-15 7.46E-15 7.46E-15

Inhalation Sv 6.20E-09 7.45E-09 1.25E-08 2.64E-08

rem 6.20E-07 7.45E-07 1.25E-06 2.64E-06

Ingestion Sv 1.68E-10 2.53E-10 3.03E-10 1.26E-09

rem 1.68E-08 2.53E-08 3.03E-08 1.26E-07

Ground Plane Exposure Sv 2.69E-11 2.69E-11 2.69E-11 2.69E-11

rem 2.69E-09 2.69E-09 2.69E-09 2.69E-09

Sum Total Sv 6.40E-09 7.73E-09 1.29E-08 2.77E-08

rem 6.40E-07 7.73E-07 1.29E-06 2.77E-06
Environmental Report 

Environmental Report Request for Additional Information Page 94 of 186

Table 4-28, Annual and Committed Dose Equivalents for Exposures to 

the Nearest Resident from Gaseous Effluents

Source Units Adult EDE Teen EDE Child EDE Infant EDE 

Cloud Immersion 

Sv 6.51E-17 6.51E-17 6.51E-17 6.51E-17 

rem 6.51E-15 6.51E-15 6.51E-15 6.51E-15 

Inhalation 

Sv 2.63E-08 3.15E-08 5.29E-08 1.12E-07 

rem 2.63E-06 3.15E-06 5.29E-06 1.12E-05 

Ingestion 

Sv 1.47E-10 2.21E-10 2.65E-10 1.10E-09 

rem 1.47E-08 2.21E-08 2.65E-08 1.10E-07 

Ground Plane 

Exposure 

Sv 2.35E-11 2.35E-11 2.35E-11 2.35E-11 

rem 2.35E-09 2.35E-09 2.35E-09 2.35E-09 

Total Dose 

Sv 2.64E-08 3.18E-08 5.32E-08 1.13E-07 

rem 2.64E-06 3.18E-06 5.32E-06 1.13E-05 

The annual direct dose equivalent during the 40 years life expectation of the site was calculated with the 

MCNP4C2 computer code (ORNL, 2000a). Included in the total was the expected number of full and 

empty DUF6 cylinders. The empty cylinders were included because they contain decaying residual 

material and produce a higher dose equivalent than full DUF6 cylinders due to the absence of selfshielding and the presence of uranium progeny. 

The photon source intensity and spectrum were calculated using the MicroShield ® computer code 

(ORNL, 2000b). In addition to the photon source term, there is a two-component neutron source term. 

The first component of the neutron source term is due to spontaneous fission by uranium. The second 

component is due to neutron emission by fluorine after alpha particle capture. Each of these components 

was also included in the direct dose determination. 

The annual offsite dose equivalent was calculated at the IIFP fence line assuming 2,000 hours per year 

occupancy. Implicit in the use of 2,000 hours is the assumption that the dose equivalent is to a nonresident (i.e., a worker at an unrelated business). The annual dose equivalents for the actual nearest 

worksite and at the nearest residence were also calculated. 

The highest dose equivalent at the IIFP fence line is 0.21 mSv/yr (20.80 mrem/yr) assuming 2,000 hours 

per year occupancy. The dose equivalent at the nearest actual worksite to the northeast, 1.82 km (1.13 mi) 

is 1.40E-03 mSv/yr (1.40E-01 mrem/yr). The dose equivalent at the nearest actual residence west 

northwesteast 8.5 2.6 km (5.31.6 mi) is 3.00E-043.53E-09 mSv/yr (3.00E-023.53E-07 mrem/yr). In the 

latter case, full-time occupancy (i.e., 8,760 hours per year) is assumed. 

Direct dose rates and deep dose equivalent (DDE) for the MEI and the nearest resident were calculated 

and are presented in Table 4-2729. The dose rates are reported for both the empty and full cylinder 

storage 

Table 4-29 Estimated Dose Rates for Site Boundary Locations, MEI, and Nearest Resident 
Environmental Report 

Environmental Report Request for Additional Information Page 95 of 186

Location 

Dose Rate, mSv per hour 

(mrem per hour) 

Empty Cylinder Storage 

Area 

Full Cylinder Storage 

Area 

North Boundary 1.08E-05 (1.08E-03) 2.96E-04 

South Boundary 3.63E-05 (3.63E-03) 5.75E-03 

East Boundary 1.04E-04 (1.04E-02) 6.05E-05 

West Boundary (MEI) 3.16E-05 (3.16E-03) 1.04E-02 

Nearest Industrial Site 7.05E-07 (7.05E-05) 

Nearest Resident 3.22E-083.53E-09 (3.22E-063.53E-07) 

Nearest On-Site Work Location 1.31E-03 (1.31E-01) 4.56E-05 (4.56E-03) 

areas as the closest boundary location is different for each staging pad. In the case of the nearest industrial 

site and nearest resident, the dose rates reported are for the total dose rates due to both staging areas. 

The CEDE and the DDE are totaled to determine the TEDE for the MEI. The TEDE was determined to be 

0.21 mSv/yr (20.80 mrem/yr). Therefore, radiological impacts during Phase 1 or Phase 2 operations to 

off-site receptors from routine combined effluent releases and direct radiation are anticipated to be 

SMALL. Doses for public receptors at other sites of interest (e.g., schools and hospitals) would be lower 

than the MEI because the airborne concentrations of uranium are lower at these more distant locations. 

Population Dose Equivalents

The local area population distribution was derived from U.S. Census Bureau 2000 data for counties in 

New Mexico and Texas (DOC, 2000a; DOC, 2000b; DOC, 2000c; DOC, 2000d) that fall all or in part of 

an 80-km (50-mi) radius of the IIFP site. A standard 16-sector compass rose was centered on the IIFP 

Ssite and divided into annular rings at selected distances. See Figure 4-1920 above. Population counts 

from census data that located significant population groups for towns or cities within the 80-km (50-mi) 

area were then distributed into those sectors that covered the groupings. After accounting for these 

significant population locations, the balance of the population for the different counties persons per 

square kilometer2
Environmental Report 

Environmental Report Request for Additional Information Page 96 of 186

Figure 4- 10 Sector Compass Rose Diagram around the IIFP Site 

(square mile2

) was distributed by equal area allocation based on the land area in the sector. For the first 8 

km (5 mi), site area observations provided information on the nearest known resident within 2.68.5 km 

(1.65.3 mi) in all sectors, which indicated that all of the 16 sectors had no resident population near the 

site. The resulting population for the 2000 census year is shown on Table 3-343, “Population Levels in 

the Region of Influence.” Census data for the year 2000 also provided information on the breakdown of 

the seven counties within 80 km (50 mi) by age (DOC, 2000d). From this data, age groups as a fraction of 

the total population were determined for infants under one year of age (1.54%), children ages 1-11 

(17.90%), teens ages 12-17 (10.93%) and adults ages greater than 17 (69.64%). This breakdown was 

applied to the total population distribution for all exposure pathways including the determination of 

annual committed dose equivalent from ingestion and inhalation where age also affects the amount of 

annual intake (air and food). 

For the ingestion of food products, it was assumed that the area produced sufficient volume to supply the 

entire population with their needs. Individual total effective dose equivalents were calculated for each age 

group by sector and then multiplied by the estimated age-dependent population for that sector to get the 

collective dose equivalent. The collective dose equivalents for each age group were then added to provide 

the total population collective dose equivalents. Table 4-30, “Collective Dose Equivalents to All Ages 

Population (Person-Seiverts)” and Table 4-31, “Collective Dose Equivalents to All Ages Population 

(Person-rem)” indicate the total collective dose for the entire population within the 80-km (50-mi) radius 

of the IIFP Ssite in units of Person-Sieverts and Person-rem, respectively. 
Environmental Report 

Environmental Report Request for Additional Information Page 97 of 186

Although routine operations at the IIFP facility create the potential for radiological and nonradiological 

impacts on the environment and members of the public, plant design has incorporated features to 

minimize gaseous and liquid effluent releases and to keep them well below regulatory limits. These 

features include: 

• DUF6 cylinders are moved only when cool and when DUF6 is in solid form, which minimizes the 

risk of inadvertent release due to mishandling. 

• Process off-gas from DUF6 purification and other operations passes through de-sublimers to 

solidify and reclaim as much DUF6 as possible. Remaining gases pass through high-efficiency 

filters and chemical absorbers, which remove HF and uranium compounds. 

• Liquid and solid waste handling systems and techniques are used to control wastes and effluent 

concentrations. 

• Gaseous effluent passes through pre-filters, high efficiency filters, and carbon filters, all of which 

greatly reduce the radioactivity in the final discharged effluent to very low concentrations. 

• Uranium bearing liquid waste is routed to the Decontamination Building for removal of uranium 

and the treated water is either evaporated or reused in the Decontamination Building. 

• Effluent paths are monitored and sampled to assure compliance with regulatory discharge limits. 
Environmental Report 

Environmental Report Request for Additional Information Page 98 of 186

Table 4- 28 30 Collective Dose Equivalents to All Ages Population (Person-Sv) (gas release pathw

Sector 

0-1.6 km 

(0-1 mi)

1.6-3.2 km 

(1-2 mi)

3.2-4.8 km 

(2-3 mi)

4.8-6.4 km 

(3-4 m)

6.4-8.0 km 

(4-5 mi)

8.0-16 km 

(5-10 mi)

16-32 km 

(20-30 mi)

32-48 km 

(20-30 mi)

48-68 km 

(30-40 mi)

64-80 

(40-50 

N 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 5.34E-06 7.19E-04 1.53E-05 3.25E-05 1.97ENNE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 3.78E-06 8.19E-06 1.02E-05 1.13E-05 1.24ENE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 3.82E-06 8.36E-06 1.14E-05 1.02E-05 1.14EENE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 5.01E-06 1.43E-05 2.12E-05 1.93E-05 2.15EE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 6.55E-06 2.58E-03 2.67E-05 3.35E-04 3.59EESE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 8.04E-06 2.04E-05 2.34E-05 2.27E-05 6.16ESE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 8.01E-06 1.88E-05 2.02E-05 2.23E-05 2.57ESSE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 5.92E-06 1.36E-05 1.56E-04 5.16E-05 4.09ES 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 6.58E-06 1.52E-05 1.87E-05 5.56E-05 2.80ESSW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 7.31E-06 1.67E-05 2.06E-05 2.51E-05 1.97ESW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 6.12E-06 1.39E-05 1.89E-05 2.31E-05 6.24EWSW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 4.44E-06 9.68E-06 1.30E-05 1.60E-05 8.45EW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 5.78E-06 1.33E-05 1.73E-05 2.11E-05 2.42EWNW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 7.22E-06 1.59E-05 2.02E-05 2.35E-05 2.53ENW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 8.89E-06 2.13E-05 2.77E-05 2.72E-05 2.77ENNW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 6.90E-06 1.63E-05 1.96E-05 2.29E-05 2.60ERing Totals 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 9.97E-05 3.50E-03 4.41E-04 7.19E-04 1.84ECum. Totals 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 9.97E-05 3.60E-03 4.04E-03 4.76E-03 6.60E
Environmental Report 

Environmental Report Request for Additional Information Page 99 of 186

Vector 0-1 1-2 2-3 3-4 4-5 5-10 10-20 20-30 30-40 

E 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 2.70E-04 6.00E-06 1.40E-05 

ENE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 5.50E-05 6.00E-05 0.00E+00 1.70E-05 

NE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 

NNE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 9.70E-06 0.00E+00 0.00E+00 

N 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 1.40E-04 5.30E-06 5.30E-06 

NNW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 1.50E-05 0.00E+00 0.00E+00 

NW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 

WNW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 

W 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 

WSW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 

SW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 

SSW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 

S 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 

SSE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 1.30E-05 0.00E+00 

SE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 

ESE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 6.60E-06 0.00E+00 0.00E+00 

Ring 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 5.50E-05 5.00E-04 2.40E-05 3.70E-05 

Cumul 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 5.50E-05 5.60E-04 5.80E-04 6.20E-04 
Environmental Report 

Environmental Report Request for Additional Information Page 100 of 186

Table 4- 28 31 Collective Dose Equivalents to All Ages Population (Person-rem) (gas release pathw

Sector 

0-1.6 km 

(0-1 mi)

1.6-3.2 km 

(1-2 mi)

3.2-4.8 km 

(2-3 mi)

4.8-6.4 

km(3-4 m)

6.4-8.0 km 

(4-5 mi)

8.0-16 km 

(5-10 mi)

16-32 km 

(20-30 mi)

32-48 km 

(20-30 mi)

48-68 km 

(30-40 mi)

64

(40

N 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 5.34E-04 7.19E-02 1.53E-03 3.25E-03 1NNE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 3.78E-04 8.19E-04 1.02E-03 1.13E-03 1NE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 3.82E-04 8.36E-04 1.14E-03 1.02E-03 1ENE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 5.01E-04 1.43E-03 2.12E-03 1.93E-03 2E 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 6.55E-04 2.58E-01 2.67E-03 3.35E-02 3ESE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 8.04E-04 2.04E-03 2.34E-03 2.27E-03 6SE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 8.01E-04 1.88E-03 2.02E-03 2.23E-03 2SSE 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 5.92E-04 1.36E-03 1.56E-02 5.16E-03 4S 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 6.58E-04 1.52E-03 1.87E-03 5.56E-03 2SSW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 7.31E-04 1.67E-03 2.06E-03 2.51E-03 1SW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 6.12E-04 1.39E-03 1.89E-03 2.31E-03 6WSW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 4.44E-04 9.68E-04 1.30E-03 1.60E-03 8W 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 5.78E-04 1.33E-03 1.73E-03 2.11E-03 2WNW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 7.22E-04 1.59E-03 2.02E-03 2.35E-03 2NW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 8.89E-04 2.13E-03 2.77E-03 2.72E-03 2NNW 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 6.90E-04 1.63E-03 1.96E-03 2.29E-03 2Ring Totals 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 9.97E-03 3.50E-01 4.41E-02 7.19E-02 1Cum. Totals 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 9.97E-03 3.60E-01 4.04E-01 4.76E-01 6
Environmental Report 

Environmental Report Request for Additional Information Page 101 of 186

Vector 0-1 1-2 2-3 3-4 4-5 5-10 10-20 20-30 30-40 

E 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 2.7E-02 6.0E-04 1.4E-03 

ENE 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 5.5E-03 6.0E-03 0.0E+00 1.7E-03 

NE 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 

NNE 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 9.7E-04 0.0E+00 0.0E+00 

N 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 1.4E-02 5.3E-04 5.3E-04 

NNW 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 1.5E-03 0.0E+00 0.0E+00 

NW 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 

WNW 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 

W 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 

WSW 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 

SW 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 

SSW 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 

S 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 

SSE 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 1.3E-03 0.0E+00 

SE 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 

ESE 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 6.6E-04 0.0E+00 0.0E+00 

Ring 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 5.5E‐03 5.0E‐02 2.4E‐03 3.7E‐03 

Cumul 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 5.5E‐03 5.6E‐02 5.8E‐02 6.2E‐02 
Environmental Report 

Environmental Report Request for Additional Information Page 102 of 186

RAI 9 

Provide additional information regarding air emissions during the operation of the IIFP facility. 

d. Provide the stack parameter assumptions such as stack height(s), stack diameter, gas exit 

velocity, and stack gas exit temperature. 

The requested information is needed to properly assess the impacts to air quality during operation. 

Section 4.6, “Air Quality Impacts,” of the ER (IIFP, 2009a) contains much information on air dispersion 

coefficients and current annual emissions for the 50 mile radius. However, the ER does not include 

information on the plant boilers or diesel generators, or on the annual emissions expected from plant 

operations. In addition, the ER does not contain information on modeling input assumptions or stack 

parameter assumptions, and the meteorological data used for the ER (Midland-Odessa) or another NWS 

weather station have not been provided. 

RESPONSE: 

Former Table 2-2, “IIFP Plant Major Vent Stacks,” provided the stack height for five (5) vent stacks. The 

table will be revised to include the stack diameter, gas exit velocity, and the gas exit temperature for those 

stacks as well as 8 other stacks that have been added and renumbered as Table 2-3. 

Environmental Report Documentation Impact: Former Table 2-2 showing five (5) stacks will be 

deleted and replaced with Table 2-3 showing fourteen (14) vent stacks with an additional column 

displaying the stack diameter, stack exit gas velocity, and gas exit temperature. 

Table 2-2 IIFP Plant Major Process Vent Stacks

Stack 

Identification 

(Number) and 

Description

Approximate 

Location

Approximate 

Heighta (ft)

Estimate Range 

of Vent Flow 

Ratesb (ft3/min)

Main 

Constituents in 

Flow Stream

(01) Plant KOH 

Scrubbing System

Slightly East of the 

DUF6 Autoclave 

Building

90 20-100

Trace quantities of 

fluoride, nitrogen, 

air

(02) DUF4 Dust 

Collector System

Northeast corner 

of DUF4 Process 

Building

80 4,800-10,600 Trace particulates

(03) FEP Dust 

Collector System

West side of FEP 

Process Building 80 3,800-7,600 Trace particulates

(04) Utilities 

Boiler Stack

Roof of Utilities 

Building 40 250-500 Combustion Gases

(05) (Future Phase 

2 Plant) Oxide 

Dust Collector 

System

Southeast corner 

of Oxide Process 

Building

80 3,800-7,600 Trace particulates

a

feet-multiply by 0.3048 to get meters b

cubic feet-multiply by 0.028317 to get cubic meters
Environmental Report 

Environmental Report Request for Additional Information Page 103 of 186

Table 2-23 IIFP Major Process Vent Stacks

Stack Identification 

(Number) and 

Description

Approximate 

Location

Approximate 

Heighta (ft)

Estimate 

Range of Vent 

Flow Ratesb

(ft3/min)

Main Constituents 

in Flow Stream

Stack 

Diameter 

(in) Stack 

Velocity 

(ft/min) 

Temperature

(01) Plant KOH 

Scrubbing System

Stack

Slightly East of 

the DUF4

Process

Building

90 20-100 HF/SiF4/BF3

4 

229-1,149

Ambient

(02) DUF4 Dust 

Collector System

Slightly East of 

DUF4 Process 

Building

80 3,800-7,600 UF4/HF

8

10,888-

21,776

Ambient

(03) FEP Dust 

Collector System

West Side of 

FEP Process 

Building

80 3,800-7,600

Uranium Oxide/

HF/BF3

8

10,888-

21,776

Ambient

(04) Utilities 

Boiler Stack

Roof of Utilities 

Building 40 250-500

Particulates/SO2/ 

NOx/VOC/

Methane/CO/TOC

/CO2

8

716-1,432

300 oF

(05) (Future Phase 

2 Plant) Oxide 

Dust Collector 

System

Northeast 

Corner of Future 

Oxide Process 

Building

80 3,800-7,600

Uranium 

Oxide/HF

8

10,888-

21,776

Ambient

(06) Laboratory 

Hood Stack

East of 

Laboratory 30 3,000-4,000

Various trace 

reagent chemicals

12

3,800-5,100

Ambient

(07) Calcium

Fluoride Dust 

Collector

Southwest 

Corner of the 

EPP

35 3,000-5,000

Particulates as 

CaF2

8

8,600-

14,334

Ambient

(08) Decon Dust 

Collector Stack

East of Decon 

Building 80 3,000-5,000

Trace Uranium & 

Metal Grit or Sand

8

8,600-

14,334
Environmental Report 

Environmental Report Request for Additional Information Page 104 of 186

Stack Identification 

(Number) and 

Description

Approximate 

Location

Approximate 

Heighta (ft)

Estimate 

Range of Vent 

Flow Ratesb

(ft3/min)

Main Constituents 

in Flow Stream

Stack 

Diameter 

(in) Stack 

Velocity 

(ft/min) 

Temperature

Ambient

(09) Lime Dust 

Collector Stack

Northwest 

Corner of EPP 35 1,500-3,000

Particulates as 

Ca(OH)2

42 

39-78

Ambient

(10) CaF2

Combustion Dryer 

Stack

Roof of EPP

Building 35 30-100

Particulates/SO2/ 

NOx/VOC/ 

Methane/CO/TOC

/CO2

8

86-300

500

(11)Water 

Evaporator Stack

East of EPP 

Building 35 50-100

Steam/Particulates

/SO2/NOx/VOC/M

ethane/CO/TOC/C

O2

8

143-300

212 oF

(12) H2 Generation 

Stack

East side of 

Plant near 

sanitary waste 

treatment

35 214-283

O2/N2/H2O/CO2/ 

CO

4

2,454-3,245

250

(13) DUF4

Vacuum Transfer 

Dust Collector 

Stack

Roof of FEP 

Building 80 4,800-10,600

Particulates as

UF4

8

13,753-

30,372

Ambient

(14) B2O3 Silo 

Dust Collector 

Stack

Above B2O3

Silo Building 80 2,000-4,200

Particulates as 

B2O3

8

5,733-

12,041

Ambient

a

feet-multiply by 0.3048 to get meters

b

cubic feet-multiply by 0.028317 to get cubic meters

HF – Hydrogen Fluoride SiF4 – Silicon Tetrafluoride BF3 – Boron Trifluoride UF4 – Uranium Tetrafluoride

SO2 – Sulfur Dioxide NOx – Nitrogen Oxides VOC – Volatile Organic Chemicals CO – Carbon Monoxide

TOC – Total Organic Chemicals CO2 – Carbon Dioxide CaF2 – Calcium Fluoride Ca(OH)2 – Calcium Hydroxide

N2 – Nitrogen O2 – Oxygen H20 – Water B2O3 – Boron Trioxide
Environmental Report 

Environmental Report Request for Additional Information Page 105 of 186

RAI 9 

Provide additional information regarding air emissions during the operation of the IIFP facility. 

e. Provide the five years (1987 to 1991) of hourly meteorological data from the Midland-Odessa, 

Texas, National Weather Service (NWS) station that were used in the ER. 

The requested information is needed to properly assess the impacts to air quality during operation. 

Section 4.6, “Air Quality Impacts,” of the ER (IIFP, 2009a) contains much information on air dispersion 

coefficients and current annual emissions for the 50 mile radius. However, the ER does not include 

information on the plant boilers or diesel generators, or on the annual emissions expected from plant 

operations. In addition, the ER does not contain information on modeling input assumptions or stack 

parameter assumptions, and the meteorological data used for the ER (Midland-Odessa) or another NWS 

weather station have not been provided. 

RESPONSE: 

As shown in 3rd, 4th and 5th paragraphs from below ER Section 3.6.1.4, “Wind,” and from the 1st

paragraph of ER Section 3.6.1.5, “Atmospheric Stability,” the data came from NUREG-1790, 

“Environmental Impact Statement for the Proposed National Enrichment Facility in Lea County, New 

Mexico.” The rationale used by the NRC for using this data is also provided in the 4th paragraph of 

Section 3.6.1.4 of the IIFP Environmental Report. The 3rd, 4th and 5th paragraphs from ER Section 3.6.1.4 

and from the 1st paragraph of ER Section 3.6.1.5 read as follows: 

In the Environmental Impact Study (EIS) conducted by the Nuclear Regulatory Commission (NRC) for 

the National Enrichment Facility at Eunice, New Mexico (NRC, 2005), NRC staff examined climatology 

data from four weather stations in the area. These locations include Eunice, New Mexico; Hobbs, New 

Mexico; Midland-Odessa, Texas; and Roswell, New Mexico. See Table 3-25, “Weather Stations Located 

near the IIFP Site,” for the distances and directions of these stations from the IIFP Site and the length of 

the records for the reported data. 

The data from the NRC study is presented in Figure 3-57, “Wind Roses for Midland-Odessa, Roswell, 

Hobbs, and Eunice for 1993.” From this one-year comparison, the general wind patterns for MidlandOdessa, Hobbs, and Eunice were somewhat similar. Roswell data appeared to be different with a stronger 

northerly and westerly component. The EPA requires that meteorological data be at least 75-percent 

complete (with less than 25% missing data) to be reliably usable as inputs for dispersion models. Despite 

the fact that Hobbs is the closest station to the IIFP Ssite, the Hobbs data did not meet the 75-percent 

completeness criteria. However, Hobbs observations can be used for a general description of the 

meteorological conditions at the IIFP Ssite. Midland-Odessa and Hobbs had comparable climate data 

based on a comparative analysis of meteorological data at the four locations surrounding the IIFP Ssite. 

Since Midland-Odessa was a first-order weather station with data completeness exceeding EPA 

requirements, NRC used the data from the Midland-Odessa weather station for its dispersion modeling for 

the EIS for the NEF. 

The hourly meteorological observations at Midland-Odessa were used to generate wind rose plots. 

Monthly wind speeds and prevailing wind directions at Midland-Odessa for the years 1987 to 1991 are 

presented in Figure 3-58. The annual mean wind speed was 11 mph and the prevailing wind direction was 

180 degrees with respect to North. The maximum five second wind speed was 70 mph (NRC, 2005). 
Environmental Report 

Environmental Report Request for Additional Information Page 106 of 186

Five years of data (1987-1991) from Midland-Odessa weather station were used to generate joint 

frequency distributions of wind speed (Figure 3-59) as a function of Pasquill stability class (A-F). The 

stability class was determined using the solar radiation/cloud cover method. Figure 3-60, “Distribution of 

Stability Classes for Midland-Odessa, 1987-1991” presents frequency distributions of wind speed and 

direction as a function of Pasquill stability class (A-F). The most stable classes (E and F) occur 18.9% 

and 13% of the time, respectively. The least stable (Class A) occurs 0.4% of the time. Important 

conditions for atmospheric dispersion, stability class F, and low wind speeds 1 to 3 mph, occur 2.2% of 

the time. The highest occurrences of the Class F and low wind speeds 1 to 3 mph with respect to wind 

direction are 0.28% and 0.23% with south and south-southeast winds (NRC, 2005).” 

The data that NRC used in that study was taken from the Environmental Report for the NEF December 

2003 (LES, 2003). Tables 3.6-12 through 3.6-18 from the NEF Environmental Report below are the fiveyear data for the 1987-1991 for the Midland-Odessa station. 
Environmental Report 

Environmental Report Request for Additional Information Page 107 of 186
Environmental Report 

Environmental Report Request for Additional Information Page 108 of 186
Environmental Report 

Environmental Report Request for Additional Information Page 109 of 186

 

Environmental Report Documentation Impact: None 
Environmental Report 

Environmental Report Request for Additional Information Page 110 of 186

RAI 10 - Provide additional information regarding accident analyses. 

Describe how the release rates required to exceed consequence levels at the IIFP facility boundary are 

determined from the Goode (1995) paper referenced in Section 4.1.2, “Consequence Analysis” of the 

IIFP Integrated Safety Analysis (ISA) Summary, (IIFP, 2009b). 

This information is needed to evaluate the IIFP analysis so that accidents can be presented in the NRC 

EIS. Neither the ER nor the ISA provide this information. 

RESPONSE: 

The Goode 1995 reference cited in the ISA Summary provides a descriptive overview of HGSYSTEM 

evaluations for HF releases at the Paducah and Portsmouth gaseous diffusion plants; however, the Goode 

1995 reference does not directly produce the release rates cited in the ISA Summary for the IIFP project 

(4 lb/hr and 91 lb/hr release rates to produce consequence levels 2 and 3). Instead, the release rates cited 

in the ISA Summary are based on preliminary calculations that were developed as part of the conceptual 

design. 

The conceptual design calculations applied HGSYSTEM to estimate the steady release HF release rate 

that would produce each of the eight conditions shown in the table below. For the purpose of evaluation, 

the distances to the site and property boundaries were assumed to be 200 meters and 900 meters, 

respectively. The AEGL2 and AEGL3 values were assumed at 0.82 mg/m3

 and 19.6 mg/m3, respectively. 

Releases were evaluated for F1 and D2.5 atmospheric conditions. The bolded results in the “Required HF 

Release Rate” column are cited in the ISA Summary. 

Index 

Based on these 

Atmospheric 

Conditions 

Produce this HF 

Concentration 

(mg/m3) 

At This 

Downwind 

Distance (m) 

Required HF 

Release Rate 

(kg/sec) 

Required HF 

Release Rate 

(lb/hr) 

01 F1 AEGL2 = 0.82 200 2.85E-05 0.23 

02 F1 AEGL3 = 19.6 200 7.28E-04 5.8 

03 F1 AEGL2 = 0.82 900 3.50E-04 2.8 

04 F1 AEGL3 = 19.6 900 9.05E-03 71.8 

05 D2.5 AEGL2 = 0.82 200 5.05E-04 4.01 

06 D2.5 AEGL3 = 19.6 200 1.15E-02 91.3 

07 D2.5 AEGL2 = 0.82 900 9.67E-03 76.7 

08 D2.5 AEGL3 = 19.6 900 2.06E-01 1635 

The release rates determined by HGSYSTEM, as described in the IIFP ISA Summary, Section 4.1.2, were 

explicitly developed as part of the early Process Hazards Analysis (PHA) to identify whether prevention 

or mitigation measures may be needed. However, these release rates were not applied beyond the early 

PHA stage of the project. In support of the ISA, all site boundary consequence calculations for all 

postulated accidents are based exclusively on the Gaussian Dispersion equation. None of the accident 

consequence calculations or conclusions is based on HGSYSTEM. Because the HGSYSTEM results were 

preliminary and do not support any of the results or conclusions of the ISA, the discussion about 

HGSYSTEM will be removed from the ISA Summary. 
Environmental Report 

Environmental Report Request for Additional Information Page 111 of 186

Environmental Report Documentation Impact: The 5th paragraph of Section 4.1.2, “Consequence 

Analysis,” of the ISA Summary will be deleted as shown below:

The HGSYSTEMS dispersion model (Goode, 1995) was used to calculate release rates required to exceed 

criteria concentrations at the site boundary for hypothetical HF releases. It is estimated that release rates 

of ~4 lb/hr are required to exceed intermediate (Category 2) consequence levels and ~91 lb/hr to exceed 

high (Category 3) consequence levels at the site boundary. It is anticipated that immediate plant 

emergency response to such an incident would reduce the duration of the release and mitigate any off-site 

impact.
Environmental Report 

Environmental Report Request for Additional Information Page 112 of 186

RAI 11 

Provide additional information regarding groundwater. 

a. Provide information about the existing site groundwater monitoring well network and indicate 

whether a baseline ground water quality assessment will be established. Clarify what role if any 

the Cunningham Plant monitoring wells, mentioned in the ER, Section 3.1.2, “Description of Offsite Areas,” will play in the groundwater assessment. Specify whether the following information 

is available for review onsite or can be submitted for reference: 

• location of existing groundwater monitoring wells, 

• New Mexico well registry numbers, 

• well capacity (gpm), 

• well depths, 

• groundwater quality data, and 

• any other relevant available information. 

This information is needed in order to analyze local and regional groundwater resources to provide 

sufficient detail for inclusion in the EIS. 

RESPONSE: 

Section 3.4.15.7,” Historical and Current Data from Site Wells,” will be revised to include the location of 

the existing Xcel Energy groundwater monitoring wells, well depths, and groundwater quality. Xcel 

Energy has analyzed groundwater for a limited number of constituents. IIFP is proposing four monitoring 

wells that will be sampled and analyzed for constituents that will be present at the IIFP facility. IIFP will 

also sample for analytes that exceed standards in Xcel Energy monitoring wells. 

Environmental Report Documentation Impact: Section 3.4.15.7 will be revised to include requested 

information above. The text and Figure in Section 3.4.15.7 will be replaced with the following text, 

figure, and table. Section 3.4.15.7 will be revised as follows: 

3.4.15.7 Historical and Current Data from Site Wells 

Four irrigation (monitoring) wells are on the IIFP site. See Figure 3-30, “Water Wells Located on the 

Proposed IIFP Site” for locations of these irrigation monitoring wells. For the M3 monitoring well in the 

upper left quadrant, the depth to water (DTW) is 16.8 m (55 ft) and the total depth (TD) is 50 m (164 ft). 

The M4 well in the lower left quadrant has a DTW of 21.3 m (70 ft) and TD of 57.9 m (190 ft). The 

irrigation M2 well in the upper right quadrant possesses a DTW of 16.8 m (55 ft) and a TD of 60.4 m 

(198 ft). The other M5 well on the site in the lower right quadrant has a DTW of 21.3 m (70 ft) and a TD 

of 54 m (177 ft).

Four wells are located in Section 27 of the IIFP Site. See Figure 3-32 for the location of these wells 

within Section 27 of the IIFP Site. Initial depth to groundwater (DTGW) in M3 (supply well for Xcel 

Energy Maddox Station) was 16.8 m (55 ft) when completed in 1965. Three Xcel Energy Cunningham 

Station monitoring wells are located along a north-south axis close to the western boundary of Section 27 

and have been monitoring for DTGW as recently as November 2009 (GLEI, 2010d). DTGW within these 

wells ranges from 18 m to 20.4 m (59 ft to 67 ft) below ground surface (bgs).
Environmental Report 

Environmental Report Request for Additional Information Page 113 of 186

Figure 3- 3032 Water Wells Located oin Section 27 of the Proposed IIFP Site 

The Xcel Energy Cunningham Station is located just west of Section 27. The Cunningham Station 

operated with an unlined cooling tower and boiler cleanout pond for a number of years. The pond has 

recently been lined. Xcel Energy monitoring wells located along the western IIFP Section 27 boundary 

were installed to monitor contaminants in groundwater that potentially originated from cooling water 

pond and/or agricultural fields. Shown in Figure 3-32 are monitoring wells locations within Section 27 

around the Xcel Energy Cunningham Station (CU6, CU7, and CU8) for which water quality data has been 

collected since 2004. Data from these monitoring well are shown in Table 3-10 (GLEI, 2010d). Results

that exceeded New Mexico Water Quality Control Commission (WQCC) Standards for Groundwater are 

bolded text. CU8 consistently exceeded standards for sulfate and total dissolved solids. CU9 consistently 

exceeded standards for sulfate, chloride, and total dissolved solids. Groundwater quality data has not been 

obtained for the Xcel Energy Maddox Facility supply well (M3). 

Four monitoring wells are proposed for the IIFP use. Three monitoring wells are proposed down gradient 

(south) from the DUF6 Cylinder Storage Pad, the Cylinder Pad Stormwater Retention Basin, and the 

Stormwater Retention/Evaporation Basin. One monitoring well is proposed up gradient (north) from the 

primary production facility just within the 1.2 ha (40-ac) security fence for the IIFP Facility. Refer to 

Figure 2-10, “IIFP Facility Site Plan.”
Environmental Report 

Environmental Report Request for Additional Information Page 114 of 186

An application for the Ground Wwater Discharge Permit has not been submitted to the Ground Wwater 

Quality Bureau (GWQB) of the New Mexico Environmental Department., but tThe GWQB has 

tentatively agreed to give approval to the proposed monitoring well locations prior to issuing the 

Groundwater Discharge Permit has issued a conceptual monitoring plan that is subject to change as more 

information becomes available during the discharge permit application process. The GWQB tentatively 

agrees with the number and location of down gradient wells, but anticipates up to four up gradient wells 

may be needed along the east and northeast side of the IIFP depending on the hydrologic information 

provided during the application process. NMED will require that total dissolved solids, sulfate, chloride, 

nitrate as nitrogen, total Kjeldahl nitrogen, fluoride, and isotopic uranium be analyzed for on a quarterly

basis (NMED, 2011).
Environmental Report 

Environmental Report Request for Additional Information Page 115 of 186

Table 3- 10 Site Water Quality As Depicted From Monitoring Wells from Xcel Energy Cunningham 

2004 2005 2006 2007 2008 

12/27 3/29 6/23 9/29 12/15 3/28 6/16 9/27 12/20 3/20 6/27 9/5 12/5/ 2/28 5/15 8/14 12/4 3/10/ 

CU6 Monitoring WellSO4 66 66 63 61 64 64 61 59 61 65 62 65 74 81 58 70 72 64 Cl 26 25 24 22 26 28 26 24 27 32 29 32 33 37 26 31 32 30 NO3 10.2 10.2 10.2 11.1 10.2 10.2 10.2 10.2 10.2 13.3 10.0 10.0 10.0 11.1 10.2 10.2 10.0 10.0 NO3-N 2.3 2.3 2.3 2.5 2.3 2.3 2.3 2.3 2.3 3.0 2.3 2.3 2.3 2.5 2.3 2.3 2.3 2.3 pH 7.5 7 7.4 7.5 7.3 7.5 7.6 7.5 7.3 7.5 7.4 7.3 7.5 7.5 7.5 7.3 7.4 7.4 TDS 377 365 363 354 354 359 364 355 384 365 378 378 370 336 348 383 376 358 B 0.47 0.85 0.05 0.03 0.06 0.02 0.01 0.14 0.09 0.03 0.13 0.01 0.11 NS 0.05 0.04 0.04 NS CU8 Monitoring WellSO4 782 742 714 712 716 732 672 666 636 662 652 658 679 674 628 617 637 619 Cl 136 135 132 136 130 133 129 130 118 130 126 128 129 134 121 122 135 126 NO3 15.1 18.2 18.2 20.8 18.2 19.9 19.9 19.9 19.0 19.9 18 19 19 19.0 16.8 19.0 21 19 NO3-N 3.4 4.1 4.1 4.7 4.1 4.5 4.5 4.5 4.3 4.5 4.1 4.3 4.3 4.3 3.8 4.3 4.7 4.3 pH 7.2 6.7 7.1 7.2 7.0 7.2 7.3 7.2 7.1 7.3 7.1 6.9 7.1 7.2 7.2 7.2 7.3 7.1 TDS 1569 1551 1536 1505 1502 1510 1492 1456 1479 1449 1456 1405 1379 1382 1364 1387 1357 1345 B 0.6 1.0 0.3 0.1 0.1 0.1 0.0 0.3 0.3 0.0 0.4 0.0 0.3 MS 1.1 0.1 0.1 NS CU9 Monitoring WellSO4 778 743 704 720 684 678 690 685 647 704 731 707 557 733 740 711 743 711 Cl 525 414 408 390 429 483 504 541 521 557 527 481 496 463 492 412 399 395 NO3 12.1 14.2 14.2 15.4 15.1 12.0 18.2 19.0 15.1 19.0 15 13 15 8.0 26.1 18.2 20 17 NO3-N 2.7 3.2 3.2 3.6 3.4 2.7 4.1 4.3 3.4 4.3 3.4 2.9 3.4 1.8 5.9 4.1 4.5 3.8 pH 7.3 6.7 7.4 7.2 7.3 7.2 7.2 7.2 7.2 7.3 7.3 7.1 7.3 7.3 7.3 7.3 7.3 7.3 TDS 2202 2202 1969 1924 1964 2058 2105 2147 2175 2169 2206 2101 2086 2057 2012 1994 1951 1893 B 0.6 1.1 0.4 0.1 0.2 0.1 0.0 0.1 0.3 0.1 0.4 0.0 0.3 NS 0.1 0.1 0.1 NS Source: GLEI, 2010d. Results that exceeded New Mexico WQCC Standards for Groundwater are bolded.SO4 – Sulfate Cl – Chloride NO3 – Nitrate NO3-N – Nitrate as Nitrogen pH – Hydrogen Ion Concentration TDS – Total Dissolved 
Environmental Report 

Environmental Report Request for Additional Information Page 116 of 186

RAI 11 

Provide additional information regarding groundwater. 

b. Describe the proposed site groundwater monitoring well network to include information on well 

locations, total depths, and well capacity (gpm). 

This information is needed in order to analyze local and regional groundwater resources to provide 

sufficient detail for inclusion in the EIS. 

RESPONSE: 

Four monitoring wells are proposed for the IIFP use. Three monitoring wells are proposed down gradient 

(south) from the DUF6 Cylinder Storage Pad, the Cylinder Pad Stormwater Retention Basin, and the 

Stormwater Detention/Evaporation Basin. One monitoring well is proposed up gradient (north) from the 

primary production facility just within the 40-acre security fence for the IIFP Facility. Refer to Figure 

RAI 11-b 1, “IIFP Groundwater Monitoring Well Locations.” An application for the Ground Water 

Discharge Permit has not been submitted to the Ground Water Quality Bureau (GWQB) of the New 

Mexico Environmental Department. The GWQB has issued a conceptual monitoring plan that is subject 

to change as more information becomes available the discharge permit application process. The GWQB 

tentatively agrees with the number and location of down gradient wells, but anticipates up to four up 

gradient wells may be needed along the east and northeast side of the IIFP Facility depending on the 

hydrologic information provided during the application process. NMED will require that total dissolved 

solids, sulfate, chloride, nitrate as nitrogen, total Kjeldahl nitrogen, fluoride, and isotopic uranium be 

analyzed on a quarterly basis (NMED, 2011). 
Environmental Report 

Environmental Report Request for Additional Information Page 117 of 186

Figure RRA 11-b-1 IIFP Groundwater Monitoring Well Locations 

Environmental Report Documentation Impact: Section 3.4.15.7 will be revised to include requested 

information above. See the Environmental Report Documentation Impact for RAI 11-a. The 

communications to the GWQB, “Groundwater Discharge Permit Monitoring Requirements,” and the 

GWQB communications, “Preliminary Description of Monitoring Requirements for the Proposed 

International Isotopes Uranium De-Conversion Facility near Hobbs, New Mexico,” will be included in 

Appendix B of the Environmental Report as below: 
Environmental Report 

Environmental Report Request for Additional Information Page 118 of 186
Environmental Report 

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Environmental Report 

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Environmental Report 

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RAI 11 

Provide additional information regarding groundwater. 

c. Describe the proposed site groundwater production wells to include well locations, total depths, 

and peak and average pumping rates (gpm), and annual maximum groundwater use; and 

This information is needed in order to analyze local and regional groundwater resources to provide 

sufficient detail for inclusion in the EIS. 

RESPONSE: 

The groundwater monitoring plan is in the initial stages of preparation. 

Environmental Report Documentation Impact: See Environmental Report Documentation Impact for 

RAI 11-a. 
Environmental Report 

Environmental Report Request for Additional Information Page 123 of 186

RAI 12 

Provide copies of the IIFP site land surveys. 

Information from surveys is necessary to accurately depict the site in figures and to provide a centroid for 

demography, environmental justice, air impacts, accident impacts, and monitoring. 

RESPONSE: 

Site land surveys of the IIFP Site are being conducted and will need to be confirmed. The land survey is 

currently scheduled for completion in the 2nd Qtr. of 2011. 

Environmental Report Documentation Impact: None. 
Environmental Report 

Environmental Report Request for Additional Information Page 124 of 186

RAI 13 

Provide additional information regarding employment. 

a. Provide an employment curve so the peak number of employees and the date that peak is 

anticipated can be determined. 

The information is needed to determine the maximum impact, as driven by an increase in the region-ofinterest population, to specific socioeconomic resources. Determining the approximate outmigration/work assignment completion dates influences the impacts of reduced dependency on some 

socioeconomic resources (housing and public education for example). 

RESPONSE: 

Employment ranges were provided in the Environmental Report for the various construction and 

operations phases. Table RAI 13-a-1 provides those employment ranges as well as the employment for 

the decommissioning phase of the IIFP Facility. 

Table RAI 13-a-1 IIFP Facility Construction, Operation, and Decommissioning Employment 

Year Preconstruction Construction Operations Decommissioning Total 

Low High Low High Low High Low High

2011 35 70 35 70 

2012 120 140 120 140 

2013 120 140 80 120 200 260 

2014 120 138 120 138 

2015 150 180 120 138 270 318 

2016 150 180 145 160 295 340 

2017-

2048 145 160 145 160 

2049 145 160 40 185 200 

2050 40 

2051 40 

Table RAI-13-a-2 provides the expected peak employment of the IIFP Facility by quarter with the overlap 

between construction and operations (Phase 2) projecting the maximum in the ranges shown in Table 

RAI-13-a-1. It is now projected that the Phase 1 construction is complete during the 2nd quarter 2013 with 

the functional testing for Phase 1 operations to begin during the 3rd quarter 2013 with operations startup in 

the 4th quarter 2013. The Environmental Report will be revised to reflect these schedule changes. 

Table RAI 13-a-2 Peak Employment During Construction, Operation, and Decommissioning of the 

IIFP Facility 

Year 1st Qtr. 2nd Qtr. 3rd Qtr. 4th Qtr. 

2011 35 70 

2012 100 120 140 140 

2013 140 120 80 120 
Environmental Report 

Environmental Report Request for Additional Information Page 125 of 186

Year 1st Qtr. 2nd Qtr. 3rd Qtr. 4th Qtr. 

2014 120 138 138 138 

2015 138 138 238 318 

2016 318 280 138 150 

2017-2048 160 160 160 160 

2049 200 200 200 200 

2050 40 40 40 40 

2051 40 40 40 40 

Environmental Report Documentation Impact: It is projected that the Phase 1 construction will be 

complete during the 2nd quarter 2013 with the functional testing for Phase 1 operations to begin during the 

3rd quarter 2013 with operations startup in the 4th quarter 2013. The Environmental Report will be revised 

to reflect these schedule changes. The sections below will be revised as indicated in the parenthesis as 

follows: 

EXECUTIVE SUMMARY –subheading “Proposed License Action (Renamed subheading Revised 4th

paragraph.) 

The IIFP facility will be constructed in two phases, with Phase 1 completing the DUF6 to depleted 

uranium tetrafluoride (DUF4) process and the DUF4 to fluorine products processes and the supporting 

infrastructure of the plantfacility. The Phase 1 facilityplant is scheduled for startup by the end of 20132. 

IIFP plans to expand the facility de-conversion capacity by completing construction of a Phase 2 plant 

facility with a scheduled start by midlate-2016. The Phase 2 plant facility will consist of additional deconversion capacity using a process for direct conversion of DUF6 to uranium oxides. 

1.1 General Description of the IIFP Facility and Proposed License Action (Renamed section and 

revised 5th paragraph.)

The IIFP initial Phase 1 plantfacility, scheduled for operation by end of 20132 consists of two main 

chemical processes that, when integrated, will comprise the Fluorine Extraction Process and Depleted 

Uranium De-conversion Plant (FEP/DUP). In performing the de-conversion services, IIFP utilizes the 

fluoride extracted from the DUF6 de-conversion to manufacture high-purity silicon tetrafluoride (SiF4) 

and boron trifluoride (BF3). These fluoride gas products are valuable materials for applications in the 

solar, semiconductor, and electronics industries. In addition, anhydrous hydrogen fluoride (AHF) is a byproduct of the de-conversion process and is sold as a high demand chemical for various industrial 

applications. 

1.1 General Description of the IIFP Facility and Proposed License Action (Renamed section and 

revised 8th paragraph.)

PrecConstruction of the Phase 1 plantfacility is expected to begin in late 2011 and startup of operations is 

expected to begin in the latemid-20132. The expansion construction for athe Phase 2 plant facility is 

expected to begin in 2015 and operations start up in late 2016. The “Proposed Action” term that was used 

in the Revision A of the Environmental Report has been renamed “Proposed License Action.” The ER 

does however include the Environmental Impacts and Cumulative Effects for both the Proposed License 

Action (which is the Phase 1 facility) combined with the Phase 2 facility in order for NRC to prepare an 

Environmental Impact Statement (EIS) for the integrated Phase 1 and Phase IIFP Facility. Prior to the 

Phase 2 expansion, IIFP will prepare and submit an amended license application for the Phase 2 Facility. 
Environmental Report 

Environmental Report Request for Additional Information Page 126 of 186

At the end of its useful life, the plantIIFP Facility would will be decommissioned consistent with the 

decommissioning plan that is developed and submitted in the IIFP License Application, Chapter 10, 

“Decommissioning”. 

1.2.3 Projected Construction and Operational Startup Schedules (Revised 1st paragraph.) 

Construction of the Phase 1 plant facility is expected to begin in late early 20112 and startup of operations 

in the late mid 20132. IIFP intends to request an exemption for some pre-license construction that could 

start by earlymid 2011. In this ER, pre-license construction is considered in evaluating the environmental 

impacts. It is anticipated that approval for pre-license construction will be obtained and that some 

selective construction activities will be accomplished prior to issuance of a license by NRC. These prelicense construction activities will be preparatory in nature and will not involve any process or safetyrelated equipment or systems. 

1.2.3 Projected Construction and Operational Startup Schedules (Revised Table 1-2.) 

Major milestones are shown in Table 1-2. 

Table 1- 12 Project Major Milestones

Milestones Projected Date 

Submit Licensing Application to NRC for Phase 1 

Facility 

End of 2009 (Complete)

Environmental Report to NRC for Phases 1 and 2 End of 2009 (Complete)

Complete Engineering for Phase 1 3rd Quarter 2011 

Start Pre-Licensing Construction 3rd Quarter 2011

Obtain NRC License for Phase 1 3rd 4th Quarter 2011 

Initiate Phase 1 Facility Construction 3rd 2nd Quarter 20112012

Complete Construction of Phase 1 Facility 3rd 2nd Quarter 20132

Startup Phase 1 Facility 4th 3rd Quarter 20132

Submit Phase 2 amended License Application 2nd Quarter 2013 

Complete Phase 2 Engineering and Initiate Phase 2 

Facility Construction 

1st 2nd Quarter 2015 

Complete Construction of Phase 2 Facility 1st 2nd Quarter 2016 

Startup Phase 2 Plant Facility 2nd Quarter 2016 

2.1 Proposed License Action (Renamed section and revised 5th paragraph.) 

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

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

• The Fluorine Extraction Process for producing SiF4 and BF3 by reacting the DUF4 produced 

in the de-conversion step with the oxides of silicon (SiO2) and boron (B2O3), respectively. 
Environmental Report 

Environmental Report Request for Additional Information Page 127 of 186

4.5.2 Proposed Schedule of Activities (Revised section.)

The following is a tentative, abbreviated schedule of proposed activities. Refer to ER Section 1.2.3, 

“Projected Construction and Operational Startup Schedules,” for major steps in the Proposed ActionIIFP 

Facility: 

• Submit Environmental Report--December 2009 (complete)

• Submit Integrated Safety Analysis--December 2009 (complete)

• Submit Facility License Application--December 2009 (complete)

• Initiate Pre-licensing ConstructionPreconstruction—Early 3rd Qtr. 2011 

• Initiate Phase 1 Facility Construction--LateEarly 20121

• Achieve Phase 1 Start-up Operation--—Late4th Qtr. 20132

• Complete Phase 2 Construction--—MarchMid 2016 

• Achieve Phase 2 Start-up Operation –June Mid 2016 

4.10.1 Facility Construction (Revised section.)

Pre-licensing construction activities are assumed to begin in 2011 and to conclude in the fall ofprior to the 

end of 2011 when NRC is expected to approve the IIFP license. Pre-licensing construction activities, 

described in Section 4.1.1.1, “Construction Impacts,” will be preparatory in nature and will not involve 

any process or safety related equipment or systems. IIFP Site general construction is scheduled to begin in

20121, with construction continuing into 20123.The maximum construction workforce during Phase 1 is 

anticipated to range from 120 to 140 workers during the 20121-20132 period. Construction of Phase 2 is 

scheduled to be accomplished in 2016 with an average construction crew of 150 to 180 workers. 

4.11.4 Proposed License Action (Renumbered and Renamed, revised 1st paragraph) 

If the Proposed Action is undertaken, pre-licensing construction of the Proposed IIFP Facility will begin 

in early 2011. In late 2012, Phase 1 operation of the facility will begin. By 2016, Phase 2 operation of the 

Proposed IIFP Facility is expected to be fully operational.The Proposed License Action addresses only 

the construction and operation of the Phase 1 IIFP Facility. Prior to the Phase 2 expansion, IIFP will 

prepare and submit an amended license application for the Phase 2 facility. However, the environmental 

justice impacts will be assessed for the construction and operation of both Phase 1 and Phase 2 Facilities.

4.11.4.2 Site Preparation and Construction (Renumbered and revised 1st paragraph.) 

Site preparation and construction of the Proposed IIFP Facility may require a labor force of as many as 

200 employees; construction employment is projected to vary depending on the site preparation and 

construction activities under way at any given time. Preparation of the IIFP facility site and construction 

of the IIFP facility is projected to take approximately 20-24 months, beginning in 2011 and ending in 

20132. During the site preparation and construction phase of the project, environmental impacts 

(discussed in detail in the sections noted in parentheses) may include the following: (Bullets omitted.) 

4.11.4.32 Operation (Revised 1st paragraph.) 

Operation of the Proposed IIFP Facility will be expected to begin operation of the Phase 1 plant facility in 

late 20132 and the Phase 2 plant facility in mid-the fall of 2016. The facility is projected to employ as 

many as 138 FTEs engaged in Phase 1 operations and 160 FTEs engaged in Phase 2 operations. During 
Environmental Report 

Environmental Report Request for Additional Information Page 128 of 186

the operation phase of the project, potential environmental impacts (discussed in detail in the sections in 

parentheses) may include the following: (Bullets omitted.) 

7. COST-BENEFIT ANALYSIS (Revised 3rd paragraph.) 

It must be noted that all Chapters of the ER assess, where applicable, the environmental impacts of not 

only a Phase 1 near-term construction, with facility operations scheduled to begin in late 20132, but also 

that of a later expansion to become a Phase 2 facility. 

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

(Renamed section and revised 1st paragraph.) 

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

mid-early 20110, and some pre-licensing constructionpreconstruction activities may start by earlymid

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

ofmidearly 20112 with startup of the Phase 1 operation for functional testing by the endthird quarter of 

20132. It is assumed that the facility would will not reach significant production operating levels and 

receipt of revenue streams until mid- to-late 20143, after operational checkout and test production runs 

are completed and operations are well underway. 

8.3.10 Socioeconomic Impacts (Revised 1st paragraph.) 

Pre-licensing constructions at the IIFP Ssite is scheduled for early mid-2011, with general construction 

continuing 20 to 24 months into 20132. A peak construction force of about 200 workers is anticipated 

during the period 20121-20132. 
Environmental Report 

Environmental Report Request for Additional Information Page 129 of 186

RAI 13 

Provide additional information regarding employment. 

b. Provide anticipated annualized wage (gross payments to employee, not total payroll costs, which 

would include benefits or overhead) for the average Phase 1 construction workforce employee 

(not by job category). 

The information is needed to determine the maximum impact, as driven by an increase in the region-ofinterest population, to specific socioeconomic resources. Determining the approximate outmigration/work assignment completion dates influences the impacts of reduced dependency on some 

socioeconomic resources (housing and public education for example). 

RESPONSE: 

It is anticipated that Phase 1 construction will begin in 2012 with preconstruction to start in the third 

quarter 2011 if the NRC license has not be received. The workforce for Phase 1 and Phase 2 construction 

is indicated in Table RAI 13-b-1. The annualized base wage for the average Phase 1 construction worker 

will be $32,700 for a 40-hour week. IIFP will work 5 days/week for 50 weeks. 

Table RAI 13-b-1 Maximum Employment During Phase 1 and Phase 2 Construction of the IIFP 

Facility 

Year 1st Qtr. 2nd Qtr. 3rd Qtr. 4th Qtr. 

2011 35 70 

2012 100 120 140 140 

2013 140 120 

2014 

2015 100 180 

2016 180 150 

Environmental Report Documentation Impact: None. 
Environmental Report 

Environmental Report Request for Additional Information Page 130 of 186

RAI 13 

Provide additional information regarding employment. 

c. Identify when Phase 1 operations workers will arrive on site (by month and year), total 

operations workforce (preferably a specific estimated number, not a range), and number of 

workers that will overlap with the construction workforce for Phase 1. Include an employment 

curve so the peak number of operations employees and the date that peak is anticipated can be 

determined. 

The information is needed to determine the maximum impact, as driven by an increase in the region-ofinterest population, to specific socioeconomic resources. Determining the approximate outmigration/work assignment completion dates influences the impacts of reduced dependency on some 

socioeconomic resources (housing and public education for example). 

RESPONSE: 

There will be minimal overlap with the ending of Phase 1 construction and Phase 1 operations. The 

construction will be complete during the second quarter 2013 while functional checkout of the systems 

will occur during the third quarter 2013 with startup occurring during the fourth quarter 2013. The 

operations employment curve is shown in Table RAI 13-c-1. 

Table RAI 13-c-1 Maximum Employment During Phase 1 and Phase 2 Operations of the IIFP 

Facility 

Year 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr 

2011 

2012 

2013 80 120 

2014 120 138 138 138 

2015 138 138 138 138 

2016 138 138 138 150 

2017-2048 160 160 160 160 

2049 160 160 160 160 

2050 

2051 

Environmental Report Documentation Impact: None. 
Environmental Report 

Environmental Report Request for Additional Information Page 131 of 186

RAI 13 

Provide additional information regarding employment. 

d. Provide an estimate of the peak workforce (i.e., an estimated number, rather than a range is 

needed to assess resources impacts in the ER) for Phase 2 construction only, the anticipated 

Phase 2 construction start date (month and year), the duration of this construction phase 

workforce on site (from month and year to month and year). Include an employment curve so the 

peak number of employees and the date that peak is anticipated can be determined. 

The information is needed to determine the maximum impact, as driven by an increase in the region-ofinterest population, to specific socioeconomic resources. Determining the approximate outmigration/work assignment completion dates influences the impacts of reduced dependency on some 

socioeconomic resources (housing and public education for example). 

RESPONSE: 

The employment curve for Phase 2 construction as well as Phase 1 construction is shown in the response 

to RAI 13-b as shown in Table RAI 13-b-1, “Maximum Employment During Phase 1 and Phase 2 

Construction of the IIFP Facility.” 

Environmental Report Documentation Impact: None. 
Environmental Report 

Environmental Report Request for Additional Information Page 132 of 186

RAI 13 

Provide additional information regarding employment. 

e. Provide anticipated annualized wage (without benefits or overhead) for the average Phase 2 

construction workforce employee (not by job category). 

The information is needed to determine the maximum impact, as driven by an increase in the region-ofinterest population, to specific socioeconomic resources. Determining the approximate outmigration/work assignment completion dates influences the impacts of reduced dependency on some 

socioeconomic resources (housing and public education for example). 

RESPONSE: 

The annualized wage (without benefits or overhead) for the average Phase 2 construction workforce 

employee is $29,600 for a 40-hour work week. 

Environmental Report Documentation Impact: None. 
Environmental Report 

Environmental Report Request for Additional Information Page 133 of 186

RAI 13 

Provide additional information regarding employment. 

f. Identify when Phase 2 operations workers will arrive on site (by month and year), total 

operations Phase 2 workforce (specific number, not a range), and number that will overlap with 

the construction workforce of Phase 2 and the operations workforce of Phase 1. Provide an 

employment curve so the peak number of employees and the date that peak is anticipated can be 

determined. 

The information is needed to determine the maximum impact, as driven by an increase in the region-ofinterest population, to specific socioeconomic resources. Determining the approximate outmigration/work assignment completion dates influences the impacts of reduced dependency on some 

socioeconomic resources (housing and public education for example). 

RESPONSE: 

The overlap in employment during Phase 1 and Phase 2 operations is shown in Table RAI 13-c-1, 

“Maximum Employment during Phase 1 and Phase 2 Operations of the IIFP Facility.” The overlap in 

employment during Phase 1 and Phase 2 operations and Phase 2 construction is shown in Table RAI 13-a2, “Peak Employment during Construction, Operation, and Decommissioning of the IIFP Facility.” 

Environmental Report Documentation Impact: None. 
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Environmental Report Request for Additional Information Page 134 of 186

RAI 14 

Provide reports of ecological field studies. 

It is our understanding that IIFP is conducting seasonal ecological surveys of the site over a one-year 

period. Provide any reports generated by these surveys. Information from trip reports or quarterly 

summaries is necessary to ensure complete and accurate ecology descriptions within the EIS. Given that 

the studies would continue to be conducted after the Draft EIS is completed, interim reports are 

important. 

RESPONSE: 

The vegetation survey conducted by GL Environmental, Inc. has been completed for 2010 (GLEI, 2010a). 

The 2010 Vegetation Survey Report is attached to these RAI responses. Sections 3.5.3 and 3.5.4 of the 

Environmental Report, Revision A, will be revised to reflect information from that survey. 

Additionally, field work has been completed by GL Environmental, Inc. to evaluate the IIFP Site for the 

possible presence of the dunes sagebrush lizard (called the sand dune lizard in the Environmental Report). 

Their report, “Status and Habitat of the Dunes Sagebrush Lizard at the Proposed Site for the International 

Isotopes Fluorine Products Facility in Lea County, New Mexico,” (GLEI, 2010b) is attached. Section 

3.5.7.2, “Sand Dune Lizard,” will be revised to reflect information from this field work. 

Environmental Report Documentation Impact: The 3rd paragraph of Section 3.5.3, “Major Vegetation 

Characteristics,” of the Environmental Report, Revision A, will be revised to incorporate information 

from the 2010 Vegetation Survey. The 4th, 5th, and 6th paragraphs of Section 3.5.3 will be deleted. Section 

3.5.3 will be revised to read as follows: 

3.5.3 Major Vegetation Characteristics 

The general vegetation community type that the subject property is located in is classified as Plains and 

Great Basin Grasslands. The community is further characterized by the presence of forbs, shrubs, and 

grasses that are adapted to the deep sand environment that occurs in parts of southeastern New Mexico. 

The Plains Grasslands north of the Mescalero Ridge on the eastern portion of the Lea County consist of 

the short-grass, mid-grass, and tall-grass prairies of the National Grasslands. These grasslands extend 

throughout the Great Plains physiographic province and occur within the Southern High Plains, Pecos 

Valley, Redbed Plains, and Texas High Plains eco-region sections. Climate ranges from subhumid to 

semiarid as these grasslands extend from east to west. The characteristic plant species that are abundant 

throughout the short-grass prairie include blue grama and buffalo grass. The mid-grass prairie ecosystem 

is co-dominated by little bluestem, blue grama, and plains bristle grass. The tall-grass prairie is dominated 

by big bluestem. These different prairie ecosystems are aggregated and reduced to one category for this 

assessment and reflects a wide range of ecological properties and processes (USDA, 2004). 

The Basin and Range Grassland occurs south of the Mescalero Ridge. These grasslands are higher in 

elevation and climatically cooler and moister than desert grasslands and are adjacent to and intermingle 

with juniper savanna ecosystems. The Great Basin Grasslands are similar to Brown’s (1994) Plains and 

Great Basin grasslands and Dick-Peddie’s (1993) Plains–Mesa grasslands except the geographic range of 

this category for this assessment is restricted to the Basin and Range Physiographic province. Diagnostic 

plant species include blue grama, galleta, Indian ricegrass, and sideoats grama. Some dropseeds and 

wolftail are co-dominant and add to the diversity of this category. The Great Basin grasslands tend to be 
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drier than the Shortgrass Steppe grasslands and have a blend of warm and cool season graminoid and forb

species. Shrubs that are present in association with grassland vegetation of this category include fourwing 

saltbush, sacahuista, small soapweed yucca, skunkbush sumac, and catcall mimosa. As this grassland 

integrades with savanna ecosystems, minor amounts of trees such as emory oak, alligator juniper, and 

Utah juniper dominated woodlands are evident (USDA, 2004). The IIFP site generally is characteristic of 

the Brown’s (1994) vegetation. The majority of plant species and soils present at the IIFP Site are typical 

of Plains-Mesa Grassland and Desert Grassland Communities (Dick-Peddie 1993). Plains-Mesa 

Grassland and Desert Grassland Communities are characterized by the presence of significant amounts of 

grasses with less than 10% of total cover being forbs and shrubs. Typical grasses for Plains-Mesa 

Grassland and Desert Grassland Communities are Bouteloua species (grama grasses), buffalo grass, 

Galleta grass, Indian ricegrass, Aristida species (three-awn grasses), Sporobolus species (drop seed 

grasses), needle-and-thread grass, and western wheatgrass. Typical shrub species present on Plains-Mesa 

Grassland and Desert Grassland Communities are honey mesquite and Echinocereus species (hedgehog 

cacti).

Hairy grama is prevalent on the IIFP site and is a native, warm-season, perennial grass. The height is 

between 10 and 20 inches. The leaf blade is flat or slightly rolled; narrow; mostly basal; margins hairy. 

See Figure 3-33. This grass yields more if it is not overgrazed and grazing is deferred every 2 to 3 years 

during the period of most active growth. Hairy grama makes little growth before summer rains begin. If 

moisture is adequate, it matures rapidly.

During exceptionally dry years, it produces little forage but withstands drought well. In the northern part 

of its range, this grass usually has only 1 or 2 spikes per seedhead and short stolons that form a sod. 

Further south, it grows taller, more like a bunch grass, and has 2 to 4 spikes per seedhead. It is adapted to 

sandy and sandy loam soils and gravelly loams and does well on soils neutral to slightly calcareous. It is 

often associated with blue grama, but is more drought resistant (NRCS, 2007).

Ring Muhly (Figure 3-34) is also observed on the site with hairy grama and other various forbs and 

grasses. Mesquite, prickly pear, horse crippler cacti, and rainbow cacti were also observed. See Figure 

3-35 for a typical site photograph of ground cover on the IIFP site.

A vegetation survey (GLEI, 2010a) was conducted at the proposed location in Section 27, Township 18 

South, Range 36 East, Lea County, New Mexico. Several data collection methodologies were employed 

to determine total vegetative cover, production of perennial grasses and shrubs, and shrub density at the 

IIFP Site.

A total of eighteen plant species was observed in cover transects during the 2010 survey (Table 3-13). 

The total vegetative cover was 45.1%. Of this, 97.6% of the relative vegetative cover consisted of 

perennial grasses. Bouteloua gracilis (blue grama) contributed the largest portion of relative cover at 

27.8%, followed by Scleropogon brevifolius (burrograss) at 4.3%. B. eriopoda (black grama) and 

Pleuraphis jamesii (James’ Galleta grass) were the next two largest contributors. These species 

represented 2.6% and 2.7% of the relative vegetative cover, respectively (GLEI, 2010a).
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Table 3- 13 List of species observed on the IIFP Site 

Scientific Name Common Name 

Forbs

Croton texensis Texas Croton 

Helianthus ciliaris Texas Blueweed 

Grindelia nuda Curly-Cup Gumweed 

Two unknown species Two unknown species 

Grasses

Bouteloua curtipendula Side-oats grama 

Bouteloua eriopoda Black grama 

Bouteloua gracilis Blue grama 

Eragrostis trichodes Sand lovegrass 

Lycurus setosus Bristly wolfstail 

Muhlenbergia pungens Sandhill muhly 

Pascopyrum smithii Western wheatgrass 

Pleuraphis jamesii James' Galleta 

Scleropogon brevifolius Burrograss 

Sporobolus cryptandrus Sand dropseed 

Stipa comata Needle and thread grass 

Shrubs

Prosopis glandulosa Honey mesquite 

Echinocereus Sp Hedgehog cactus 

Two shrub species occurred in the cover transects. Shrubs contributed 1.2% of the relative vegetative 

cover. Prosopis glandulosa (honey mesquite) was the dominant shrub present with 0.54% total cover 

(GLEI, 2010a).

Vegetation species present in cover transects consisted of the following forms: five (5) forb species, 

eleven (11) grass species, and two (2) shrub species. Two forb species were not able to be identified 

during the 2010 IIFP Vegetation Survey due to lack of distinguishing floral characteristics. Subsequent 

surveys and reports will attempt to identify these unknown species (GLEI, 2010a). 

The IIFP Site is dominated by perennial grasses with 96.8% of the relative frequency. Blue grama 

accounted for 62.6% of the relative frequency value. Black grama was the second greatest contributor 

with 7.3% of the relative frequency. Forbs totaled 2.5% of the relative frequency with Croton texensis 

(Texas croton) at the greatest value of 1.1%. Shrubs accounted for the least relative frequency at 1.2%. 

Shrub frequency was predominantly honey mesquite at 1.1% of the relative frequency (GLEI, 2010a). See 

Figures 3-35 and 3-36 for a typical site photographs of ground cover on the IIFP Site.
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Figure 3-35 Perennial Vegetation Cover on IIFP Site 

Figure 3-36 Site Photograph of Ground Cover on IIFP Site

Environmental Report Documentation Impact: The 5th paragraph of Section 3.5.4, “Habitat 

Importance,” of the Environmental Report, Revision A, will be revised to show the contact with

appropriate State and federal officials for threatened or endangered plant species of the IIFP Site. The 5th

paragraph of Section 3.5.4 will read as follows: 

Shrubs provide habitat and seeds for bird and small mammal species. Perennial grasses provide forage for 

large grazing mammals and seeds for small mammals. The dominant plant species should be distributed 

uniformly across the site, such that no one area of the site contains that specie exclusively. New Mexico 

Department of Game and Fish, U.S. Fish and Wildlife Service, and the New Mexico State Forestry 
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Department personnel will be contacted for any threatened or endangered plant species on the IIFP site

Consultation with the New Mexico Department of Game and Fish and U.S. Fish and Wildlife Service 

indicated that there are currently no threatened or endangered plant species listed for Lea County, New 

Mexico. Additional consultation was sought with the New Mexico Ecological Services for potential 

habitat and known populations of a candidate species (Wright’s Marsh Thistle). The nearest location 

containing known populations of Wright’s Marsh Thistle are in the Black River drainage at least 32.2 km 

(20 mi) southwest of Carlsbad, New Mexico and at least 97 km (60 mi) from the IIFP property. 

Additionally, no potential habitat was found to be present on the IIFP Site for the Wright’s Marsh Thistle 

during the vegetation survey.

Environmental Report Documentation Impact: The 3rd paragraph of the “Habitat Requirements” 

subsection of Section 3.5.7.2, “Sand Dune Lizard,” will be revised to include the conclusion of the field 

work conducted to evaluate the site for the possible presence of the sand dune lizard. That 3rd paragraph 

will become the 3rd and 4th paragraphs of this subsection. The 3rd and 4th paragraphs of the Environmental 

Report, Section 3.5.7.2, “Habitat Requirements” subsection, will be revised to read as follows: 

Dunes that have become completely stable by vegetation appear to be unsuitable habitat. The sand dune 

lizard diet consists primarily of insects such as ants, crickets, grasshoppers, beetles, spiders, ticks and 

other arthropods. Most feeding appears to take place with or immediately adjacent to patches of 

vegetation. It is likely that the IIFP Ssite provides an adequate food source for the sand dune lizard.;

The proposed site for the IIFP is comprised of a shortgrass prairie with intermittent mesquite. Shortgrass 

prairies are comprised of several herbaceous plant-soil associations including side-oats grama (Bouteloua 

curtipendula), blue grama (Bouteloua gracilis), and buffalograss (Büchloe dactyloides) on well drained 

soils or rocky slopes and blue grama/hairy grama and (Bouteloua hirsuta) on loamy or sandy soils. The 

IIFP Site contains sandy loam soils. The lack of the shinnery oak on the proposed location leads to the 

conclusion that the sand dune lizard does not exist at this site. The site does not support shinnery oak or 

have the required sand blowouts which comprise the sand dune lizard’s primary habitat. In addition to the 

lack of appropriate soil types, there are not enough sand particles in the appropriate size range to meet the 

habitat needs of this species (GLEI, 2010b). hHowever, the habitat areas likely containing the sand dune 

lizard starts approximated 191.3 km (12 7 mi) south of the IIFP Ssite. See Figure 3-40,41 “Expected 

Range of the Sand Dune Lizard,” in Lea, Eddy, and Chaves Counties, New Mexico (Painter, 2004). The 

lack of the shinnery oak and sand dunes on the proposed location makes it unlikely that the dunes

sagebrush lizard exists at this location.
Environmental Report 

Environmental Report Request for Additional Information Page 139 of 186

RAI 15 

Provide the rationale, including appropriate documentation, that jurisdictional wetlands are, or are 

not, present within the proposed 40-acre facility (plant compound) construction area. 

It is our understanding that IIFP may submit a jurisdictional wetlands determination application for the 

depressional areas that appeared to support some hydrophytic vegetation. During the NRC site visit on 

July 27, 2010, the NRC staff noted one depression had standing water.

RESPONSE: 

It should be noted that a very heavy rainfall event (approximately 8 in) occurred the previous weekend 

prior to the July 27, 2010 NRC visit. GL Environmental, Inc. evaluated the IIFP Site for a jurisdictional 

determination with respect to Waters of the United States on October 15, 2010. The depressional areas 

during this site visit were dry. The jurisdictional determination letter to the USACE for Section 27, Range 

18 South, Township 36 East (GLEI, 2010c) is attached to these responses to the RAIs. Communications 

with the USACE confirm that the USACE agrees with the GL Environmental assessment. The 

Jurisdictional Determination from the USACE that there are no waters of the United States on the project 

site was issued January 26, 2011. The Environmental Report will be revised to reflect the results of the 

evaluation concerning surface drainage and surface depressions and the wetlands determination. 

Environmental Report Documentation Impact: Section 3.4.9, “Description of Wetlands,” will be 

revised to reflect the results of the surface depressions evaluation conducted by GL Environmental, Inc. 

October 15, 2010. Section 3.4.9 will be revised as follows: 

3.4.9 Description of Wetlands 

An evaluation of the site and of available wetlands information has been used to determine that the site 

does not contain jurisdictional wetlands or those areas subject to the regulations of the Clean Water Act of 

1977. Jurisdiction wetlands are generally concave or low-lying topographic forms that collect, store, or 

flow water frequently enough to favor a majority of plants that are adapted to saturated soil conditions. 

There exist “undivided” wetlands as shown in Figure 3-27, “Watercourses, Floodplains, and Playas Map.”

Small surface depressions are located throughout Section 27. Several of the most substantial depressions 

are identified on Figure 3-3. The depressions tend to be circular in shape and range from 15.2 m to 91.4 m 

(50 ft to 300 ft) in diameter and 0.9 to 1.5 m (3 ft to 5 ft) in depth below the surrounding grade. The 

depressions occasionally fill with water in response to precipitation events. The frequency and duration of 

surface water in the depressions is unknown, however, it is likely that water or saturated conditions are 

present for less than 10% of the year (GLEI, 2010c).

A change from the surrounding vegetation community occurs within the surface depressions. Vegetation 

within the depressions is dominated by the perennial grasses Burro grass (Scleropogon brevifolius) and 

Galleta Grass (Pleuraphis jamesii). Neither plant species are included in the National List of Vascular 

Plant Species that Occur in Wetlands: 1996 National Summary. Vine Mesquite (Panicum obtusum), 

Western wheatgrass (Pascoyrum smithii), and Blueweed (Helianthus cilaris) were present at low densities 

(<5% of areal herbaceous cover). Each of these three species is described as equally likely to occur in 

wetlands or non-wetlands (estimated probability 34%-66%). in the National List. A soil core was 

collected from two of the deeper depressions on Section 27. Each of the cores was approximately 16 
Environmental Report 

Environmental Report Request for Additional Information Page 140 of 186

inches in depth. The soil consisted of dark brown sandy to silty loam with some organic matter. No 

mottling or sulfidic material was observed in the cores (GLEI, 2010c).

“Waters of the U.S” are not present in Section 27. Surface drainage flows are infrequent, low volume and 

short in duration. Additionally, the drainage is not connected through surface channels to regional surface 

water features. See Section 3.1.1, “Land Use Status,” for additional information on surface drainage and 

for a site map showing the surface drainage and the surface depressions. Surface depressions are not 

dominated by wetland plants, lack indicators of anoxic soil conditions, and most likely are not saturated 

for more than 10% of the year. The surface depressions lack the characteristics of wetlands as defined in 

the Corps of Engineers “Wetlands Delineation Manual,” January 1987 (GLEI, 2010c). Concurrence has 

been obtained from the USACE that the water features on Section 27 are isolated and “Waters of the 

U.S.” are not present within Section 27 (USACE, 2011). 

Environmental Report Documentation Impact: Section 3.1.1, “Land Use Status,” will be revised to 

reflect the results of the surface drainage conducted by GL Environmental, Inc. October 15, 2010. A new 

paragraph fifth will be added and former paragraph five will shift down with revisions. Rename and 

replace figure for Figure 3-3 “Location of Intermittent Surface Water Around the IIFP Site.” Section 

3.1.1 will read as follows: 

Two small intermittent drainages are located on the southwest quadrant of Section 27. Surface flow most 

likely occurs in response to precipitation events. The drainages grade to the southeast and coalesce 

approximately 396 m (1,300 ft) south of the section boundary. The western drainage is clearly defined on 

Section 27 due to a moderately incised channel and the presence of Honey Mesquite bushes along the 

banks. The drainage to the east is shallow and not easily delineated from the surrounding land surface

(GLEI, 2010c).

The coalesced drainage continues to grade to the south/southeast toward Monument Draw. Monument 

Draw is a major surface drainage feature in southern Lea County and is clearly present in topographical 

maps approximately 22.5 km (14 mi) southeast of the section boundary. Although the drainage present in 

Section 27 grades toward Monument Draw, a review of topographic maps did not reveal a clear physical 

connection to Monument Draw. The drainage terminates in a playa approximately12.9 km (8 mi)

southeast of the section (GLEI, 2010c). Surface drainage at the site is also contained within a few 

depressions that have no external drainage. See Figure 3-3 for location of these depressions and the two 

intermittent drainages from the site. Runoff does not drain to one of the state’s major rivers. Surface water 

is lost through evaporation, resulting in high salinity conditions in both the waters and soils associated 

with the playas. These conditions are not favorable for the development of viable aquatic or riparian 

habitats. There is also a small stream that runs from the northwest to the southeast across the property that 

is predominantly dry during the year. See Figure 3-3 which is a topographic map of the proposed IIFP site 

which shows the low terrain where the stream and playas are located during periods of rain. There is no 

designated Federal Emergency Management Agency (FEMA) Zone A area at the IIFP location that would 

be inundated during a 100-year flood event. Refer to Figure 3-27, “Watercourses, Floodplains, and Playas 

Map.”
Environmental Report 

Environmental Report Request for Additional Information Page 141 of 186

Source: GI Environmental, Inc. 

Figure 3- 3 Location of Intermittent Surface Water Around the IIFP Site Topographic Map of the 

Proposed IIFP Site

Environmental Report Documentation Impact: Section 3.4.12.2, “Drainage Areas,” will be revised to 

reflect the results of the surface drainage conducted by GL Environmental, Inc. October 15, 2010. Insert 

new Figure 3-28 “Surface Drainage from the IIFP Site” (after text). The 3rd paragraph of Section 3.4.12.2 

will be revised to read as follows: 

Two small intermittent drainages are located on the southwest quadrant of Section 27. The drainages 

grade to the southeast and coalesce approximately 396 m (1,300 ft) south of the section boundary. The 

coalesced drainage continues to grade to the south/southeast toward Monument Draw. Monument Draw is 

a major surface drainage feature in southern Lea County and is clearly present in topographical maps 

approximately 22.5 km (14 mi) southeast of the section boundary. Although the drainage present in 

Section 27 grades toward Monument Draw, a review of topographic maps did not reveal a clear physical 

connection to Monument Draw. The drainage terminates in a playa approximately 12.9 km (8 mi)

southeast of the section (GLEI, 2010c). See Figure 3-28. Thus, Ssurface drainage at the 259 ha (640-ac)

Section is contained within several local depressions playas lakes that have no external drainage. Runoff 
Environmental Report 

Environmental Report Request for Additional Information Page 142 of 186

does not drain to Pecos River. The Pecos River Basin has a maximum basin width of 209 km (130 mi) 

and a drainage area of 115,345 km2

 (44,535 mi2)

Figure 3- 28 Surface Drainage from the IIFP Site

Environmental Report Documentation Impact: The U.S. Army Corps of Engineers has issued it 

jurisdictional determination of isolated waters in Section 27 of the IIFP Site (USACE, 2011). A copy of 

that determination will be added to Appendix B” of the Environmental Report “Consultation 

Documents.” The copy of the correspondence is below: 

 
Environmental Report 

Environmental Report Request for Additional Information Page 143 of 186
Environmental Report 

Environmental Report Request for Additional Information Page 144 of 186
Environmental Report Request for Additional Information Page 145 of 186

RAI 16 

Provide additional information regarding ambient noise level monitoring results mentioned in the ER. 

It is our understanding that IIFP is conducting noise level readings at the corners of the site to document 

existing conditions. The results of those measurements and survey report are needed in order to document 

the existing baseline noise at the site for the Affected Environment section of the EIS. 

RESPONSE: 

The baseline noise survey of the IIFP Site has not been conducted. The noise survey is being scheduled 

for the third quarter 2011. 

Environmental Report Documentation Impact: None. 
Environmental Report 

Environmental Report Request for Additional Information Page 146 of 186

RAI 17 

Clarify the status and/or schedule of the various state permits mentioned in the ER, including a list of 

those determined to not be necessary. 

IIFP is preparing applications and requesting permits as described in the schedule presented in Table 1-

4, “Required Federal and State Permits”, of the ER (IIFP, 2009a). An update of the permit status since 

submittal of the ER in December 2009 is necessary to ensure accurate information in the EIS. Because 

the ER describes some permits as potentially unnecessary, this updated information is needed to ensure 

that extraneous information is not included in the EIS. 

Also provide a copy of the New Mexico Office of State Engineer Water Rights Permit for inclusion in the 

EIS. If the permit has not yet been received, provide a copy of the Water Rights Permit Application. 

RESPONSE: 

The existing Table 1-4 will be deleted and replaced with a new table showing the requirements for 

application and only those required for the IIFP Facility. The new table will be renumbered Table 1-3. 

The Air Construction Permit, the Air Operation Permit, and the NESHAPS Permit have been combined 

with the Air Quality: New Source Review/Authority to Construct Permit. The NPDES General Permit for 

Industrial Stormwater and the NPDES Construction Stormwater General Permits for both the federal and 

state agencies have been combined in the NPDES SWPPP/NOI Permit. The Hazardous Waste Permit, the 

EPA Waste Activity EPA ID Number, and the RCRA Operations Permits have been combined for the 

EPA Hazardous Waste ID Number. The Access Permit has been renamed Highway Right-of-Way Permit. 

The Drinking Water System Permit, the Above Ground Storage Tank Registration, and the Clean Water 

Act, Section 404 have been added to the new table. Also, a copy of the New Mexico Office of State 

Engineer Water Rights Agreement will be included in the Environmental Report, Appendix B as shown 

below in the Environmental Report Documentation Impact for Appendix B. 

Environmental Report Documentation Impact: Table 1-4, “Required Federal and State Permits,” will 

be deleted and replaced with Table 1-3, “IIFP Required Federal and State Permits. (Former Table 1-3, 

Revision A has been deleted.)The 2nd paragraph of Section 1.5, “Building Permits and Licenses,” will be 

revised to add the required permits with the revised Table 1-3. The 2nd paragraph and the table will read 

as follows: 

A number of licenses and permits will be required for construction and operation of the IIFP plantfacility. 

Permits include the following:

• Air Quality: New Source Review/Authority to Construct) Permit, 

• Ground Water Discharge Permit/Liquid Waste (sewage) Permit, 

• EPA Hazardous Waste ID Number, 

• Drinking Water System Permit

• Radiation Protection Permit,

• Above Ground Storage Tank Registration,

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

• State Access (Highway Right of Way) Permit, 

• Clean Water Act, Section 404, and

• Rare, Threatened, and Endangered Species Survey Permit.
Environmental Report Request for Additional Information Page 147 of 186

A summary The status of licenses and permits that are currently known to be required are is listed in the 

Table 1-34. During the federal and State permitting process, any changes in requirements will be reevaluated. 

Table 1- 3 IIFP Required Federal and State Permits

Permit Agency Required for Application Submittal 

Time Frame

NPDES 

SWPPP/NOI 

EPA Region 

6/NMED

Facility design layout, surface water flow diagram, 

best management practices, receiving waters 

determination, generate SWPPP, and produce and 

submit NPDES NOI.

2nd Qtr. 2011

Highway Rightof-Way NMDOT One month traffic study and right-of-way 

application. 2nd Qtr. 2011

Air Quality: New 

Source 

Review/Authority 

to Construct 

Permit

NMED/AQB

Equipment list for stacks, generators, boilers, etc. 

petroleum storage tanks, emission calculations, 

facility design layout, air dispersion modeling, and 

Public Notice

3rd Qtr. 2011

Ground Water 

Discharge 

Permit/Liquid 

Waste Permit

NMED/GWQB

Facility design; calculations for stormwater 

discharge rate, effluent discharge rate, and P.E. 

stamped water balance; effluent quality 

determination; effluent processing; treatment, 

storage, and disposal plans; baseline conditions; 

domestic waste land apply strategy; monitoring 

plan; contingency plan; and Public Notice

3rd Qtr. 2011

Drinking Water 

System Permit NMED/DWB Drinking water system design, monitoring plan, and operator certification 2nd Qtr. 2012

EPA Hazardous 

Waste ID 

Number

NMED/HWB

Determination of generator status (Large Quantity 

Generator, Small Quantity Generator, or Small 

Quantity Exempt)

3rd Qtr. 2012

Radiation 

Protection 

Permit

NMED/RCB List and description of all radiological source 

equipment. 2nd Qtr. 2012

Above Ground 

Storage Tank 

Registration

NMED/PSTB Petroleum storage tanks (size, design specifications, 

fuel type) 4th Qtr. 2012

Clean Water Act, 

Section 404 USACE Site vegetation characterization and wetland determination to the USACE Complete

Endangered 

Species Survey NMDFG

This permit would be required for conducting 

surveys of the U.S BLM lands for Lesser-Prairie 

Chicken and Sand Dune Lizard. 

Complete for 

Lizard 

2nd Qtr. 2011

Right-of-Entry 

Permit NMSLO IIFP has obtained this permit for entry onto Section 26, 27, 34, or 35. Complete

State Land Swap 

Arrangement NMSLO

This arrangement requires that an environmental 

assessment and a cultural resources survey be 

conducted on lands offered for exchange..

Complete
Environmental Report Request for Additional Information Page 148 of 186

Permit Agency Required for Application Submittal 

Time Frame

Class III Cultural 

Survey Permit NMSHPO IIFP has obtained this permit to conduct surveys on Section 26, 27, 34, or 35. Complete

NPDES – National Pollutant Discharge Elimination System; EPA – U.S. Environmental Protection Agency; NESHAP – National Emissions 

Standards for Hazardous Air Pollutants; NMDOT – New Mexico Department of Transportation; NMED/AQB – New Mexico Environment 

Department /Air Quality Bureau; NMED/HWB – New Mexico Environment Department/Hazardous Waste Bureau; NMED/RCB – New Mexico 

Environment Department/Radiological Control Bureau; NMED/GWQB – New Mexico Environment Department/Ground Water Quality Bureau; 

NMDGF – New Mexico Department of Game and Fish; NMSLO – New Mexico State Land Office; NMSHPO – New Mexico State Historic 

Preservation Office, NMED/DWB - New Mexico Environment Department/Drinking Water Bureau, USACE - U.S. Army Corps of Engineers,

NMED/PSTB - Petroleum Storage Tank Bureau, U.S. BLM – U.S. Bureau of Land Management
Environmental Report Request for Additional Information Page 149 of 186

Table 1- 3 IIFP Required Federal and State Permits

Permit Agency Required for Application Submittal 

Time Frame

NPDES 

SWPPP/NOI 

EPA Region 

6/NMED

Facility design layout, surface water flow diagram, 

best management practices, receiving waters 

determination, generate SWPPP, and produce and 

submit NPDES NOI.

2nd Qtr. 2011

Highway Rightof-Way NMDOT One month traffic study and right-of-way 

application. 2nd Qtr. 2011

Air Quality: New 

Source 

Review/Authority 

to Construct Permit

NMED/AQB

equipment list for stacks, generators, boilers, etc. 

petroleum storage tanks, emission calculations, 

facility design layout, air dispersion modeling, and 

Public Notice

3rd Qtr. 2011

Groundwater 

Discharge 

Permit/Liquid 

Waste Permit

NMED/GWB

Facility design; calculations for stormwater 

discharge rate, effluent discharge rate, and P.E. 

stamped water balance; effluent quality 

determination; effluent processing; treatment, 

storage, and disposal plans; baseline conditions;

domestic waste land apply strategy; monitoring 

plan; contingency plan; and Public Notice

3rd Qtr. 2010

Drinking Water 

System Permit NMED/DWB Drinking water system design, monitoring plan, and operator certification 2nd Qtr. 2012

EPA Hazardous 

Waste ID 

Number

NMED/HWB

Determination of generator status (Large Quantity 

Generator, Small Quantity Generator, or Small 

Quantity Exempt)

3rd Qtr. 2012

Radiation

Protection Permit NMED/RCB List and description of all radiological source equipment. 2nd Qtr. 2012.

Above Ground 

Storage Tank 

Registration

NMED/PSTB Petroleum storage tanks (size, design specifications, 

fuel type) 4th Qtr. 2012

Clean Water Act, 

Section 404 USACE Site vegetation characterization and wetland determination to the USACE Complete

Endangered 

Species Survey NMDFG

This permit would be required for conducting 

surveys of the U.S BLM lands for Lesser-Prairie 

Chicken and Sand Dune Lizard. 

Complete for 

Lizard 

2nd Qtr. 2011

Right-of-Entry 

Permit NMSLO IIFP has obtained this permit for entry onto Section 26, 27, 34, or 35. Complete

State Land Swap 

Arrangement NMSLO

This arrangement requires that an environmental 

assessment and a cultural resources survey be 

conducted on lands offered for exchange..

Complete

Class III Cultural 

Survey Permit NMSHPO IIFP has obtained this permit to conduct surveys on Section 26, 27, 34, or 35. Complete

NPDES – National Pollutant Discharge Elimination System; EPA – U.S. Environmental Protection Agency; NESHAP – National Emissions 

Standards for Hazardous Air Pollutants; NMDOT – New Mexico Department of Transportation; NMED/AQB – New Mexico Environment 

Department /Air Quality Bureau; NMED/HWB – New Mexico Environment Department/Hazardous Waste Bureau; NMED/RCB – New Mexico 

Environment Department/Radiological Control Bureau; NMED/WQB – New Mexico Environment Department/Water Quality Bureau; NMDGF 
Environmental Report Request for Additional Information Page 150 of 186

– New Mexico Department of Game and Fish; NMSLO – New Mexico State Land Office; NMSHPO – New Mexico State Historic Preservation 

Office, NMED/DWB - New Mexico Environment Department/Drinking Water Bureau, USACE - U.S. Army Corps of Engineers, NMED/PSTB 

- Petroleum Storage Tank Bureau, U.S. BLM – U.S. Bureau of Land Management

Environmental Report Documentation Impact: The Environmental Report, Appendix B will be revise 

to include a copy of the New Mexico Office of State Engineer Water Rights Agreement as shown :
Environmental Report Request for Additional Information Page 151 of 186

 
Environmental Report Request for Additional Information Page 152 of 186

Exhibit “A”

Subject Land

Resolution No. 10-DEC-043R

LCBC Meeting 12-09-2010

Page 2 of 2 

 
Environmental Report Request for Additional Information Page 153 of 186

Resolution No. 10-DEC-043R 
Environmental Report Request for Additional Information Page 154 of 186
Environmental Report Request for Additional Information Page 155 of 186
Environmental Report Request for Additional Information Page 156 of 186
Environmental Report Request for Additional Information Page 157 of 186
Environmental Report Request for Additional Information Page 158 of 186
Official Use Only – Security Related Information 

Environmental Report Request for Additional Information Page 159 of 186

RAI 18 

Provide status of the radiological monitoring plan described in the “Radiological Monitoring” Section 

6.1 of the ER. 

Provide any updates which have been implemented to the facilities radiological monitoring requirements 

as a result of discussions with State and local officials. This information is necessary to address public 

comments in the EIS. 

RESPONSE: 

No updates have been implemented to the facilities radiological monitoring requirements as a result of 

discussions with State and local officials. However, soil and vegetation samples have been taken and 

analyzed as part of the pre-operational baseline. The 2010 Characterization Report completed by GL 

Environmental, Inc. (GLEI, 2010e) is attached. Results of the baseline characterization will be included in 

the appropriate sections of the Environmental Report, Chapter 6. 

Environmental Report Documentation Impact: Two new paragraphs and Figure 6-2 will be added 

after the 7th paragraph of Section 6.1.2.1, “Sampling Program,” of the Environmental Report to present 

the radiological results from the baseline soil and vegetation sampling. The new paragraphs will read as 

follows: 

On October 15, 2010, two soil and two vegetation samples were collected and shipped to analytical 

laboratories for analysis (GLEI, 2010e). Soil and vegetation sampling location 1 was sited on the IIFP 

“controlled area”. Soil and vegetation sampling location 2 was sited in the “owner-controlled area,” 

downwind and north of the proposed “controlled area.” See Figure 6-2 for locations of those samples. The 

predominant wind direction was determined using wind rose data shown in Figure 3-57. Radiological 

analysis for gamma spectroscopy was performed by contract analytical laboratory. Gamma spectroscopy 

included isotopes of uranium, actinium, bismuth, cobalt, cesium, potassium, protactinium, lead, thorium, 

and thallium. The contract analytical laboratory holds National Environmental Laboratory Accreditation 

Program (NELAP)-recognized certifications in numerous states, DOE Consolidated Audit Program 

(DOECAP) approval, USACE approval, U.S. Department of Agriculture (USDOA) approval, and 

Department of Defense through the US Army. These certifications satisfy the IIFP ER quality control 

requirements in section 6.1.2.2 for contract analytical laboratories. 

Results for soil analysis had U-234 values ranging from 4.42E-07 to 5.95E-07 μCi/g. U-235/236 ranged 

from 5.58E-09 to 2.60E-08 μCi/g. U-238 results ranged from 5.86E-07 to 5.95E-07 μCi/g. Results from

vegetation tissue samples for isotopic uranium results for sampling location 1 were all less than minimum 

detectable concentrations (MDC). Sampling location 2 had a positive result of 1.04E-08μCi/g for U-238. 

All other isotopic uranium results were less than MDC (GLEI, 2010e).

Environmental Report Documentation Impact: The 2nd paragraph of Section 6.2.3, “Effluent 

Monitoring,” of the Environmental Report will be revised to present the chemical analyses of the baseline 

sampling conduction in October 2010. The 2nd paragraph of Section 6.2.3 will read as follows: 

Parameters for continuing environmental performance will be developed from the baseline data collected 

during preoperational sampling. On October 15, 2010, two soil and two vegetation samples were 

collected and shipped to analytical laboratories for analysis. See Figure 6-2 for locations of those samples. 
Official Use Only – Security Related Information 

Environmental Report Request for Additional Information Page 160 of 186

RCRA metal concentrations in the soil samples for barium ranged from 88.5 to 109 mg/kg, cadmium 

from 0.27 to 0.42 mg/kg, chromium from 10.0 to 12.2 mg/kg, and lead from 11.7 to 14.7 mg/kg. All other 

Figure 6- 2 Site Map with Sampling Locations

RCRA metals were less than laboratory minimum detectable levels (MDL). There were no positive 

results for organics in soil samples taken on October 15, 2010. For vegetation samples, barium results 

ranged from 10.6 to 10.9 mg/kg, and all other RCRA metal results were less than MDL values. 

Laboratory analysis indicated trace amounts of benzoic acid, phenol, and bis(2-ethylhexyl) phthalate in 

soil samples. Benzoic acid was present in sampling locations 1 and 2 at 0.48 and 0.46 mg/kg, 

respectively. Bis(2-ethylhexyl) phthalate was found in vegetation sample1 at 0.26 mg/kg, and in sample 2 

at 0.19 mg/kg. Phenol was found in sample location 1 at a concentration of 0.40 mg/kg (GLEI, 2010e). 

Operational monitoring surveys will also be conducted using sampling sites and at frequencies established 

from baseline sampling data and as determined based on requirements. Operational monitoring surveys 

are determined based on requirements contained in EPA Region 6 NPDES General Discharge Permits as 

well as the NMED/GWQB Ground Wwater Discharge Permit/Plan. 
Environmental Report 

Environmental Report Request for Additional Information Page 161 of 186

RAI 19 

Provide full citations of references listed in the “Ecological Resources” Section 3.5 of the ER but not 

identified in the "List of References” Chapter 9 of the ER. 

The following references are called in Section 3.5, “Ecological Resources”, but not cited in Section 9, 

“List of References”, of the ER (IIFP, 2009a): Painter (2004), CBD (2002), CBD (2009), and USFWS 

(2008). Therefore, provide either the reference itself or the complete citation for these references. If any 

references in Section 3.5 are extraneous and not needed, then please indicate this fact. 

RESPONSE: 

A review of the references, particularly in Section 3.5 has been completed, and several references will be 

added to Chapter 9, “List of References”. 

Environmental Report Documentation Impact: Chapter 9 will be revised to add references indicated 

above as well as references added as a result of these responses to the RAIs. The following references will 

be added with the rationale for the addition of the reference: 

ATTRA, 2007. ATTRA – National Sustainable Agriculture Information Service, Publication #IP310, 

“Conserving Fuel on the Farm, National Center for Appropriate Technology, Butte, MT, 2007. (Added as 

a response to RAI 8-c revising Section 4.6.1, “Air Quality Impacts from Construction.”)

BDD, 2010. Buckman Direct Diversion Project, “Protecting Endangered Species, New Mexico 

Burrowing Owl,” Santa Fe, NM, 2010. (Added to show the source for Figure 3-48.) 

BEA, 1997. Bureau of Economic Analysis Regional, “A User Handbook for the Regional Input-Output 

Modeling Systems (RIMS II),” U.S. Department of Commerce, Washington, D.C., 1997. (Reference not 

used in Environmental Report.)

CBD, 2002. Center for Biological Diversity, “Petition to List the Sand Dune Lizard Sceloporus 

arenicolus as a Threatened or Endangered Species under the U.S. Endangered Species Act,” New 

Mexico, May 2002. (Added as a response to this RAI and added to show the source of Figure 3-39.)

CBD, 2009. Center for Biological Diversity, “Endangered Species Act Works, Arctic Peregrine Falcon,” 

New Mexico, May 2009. (Added as a response to this RAI.)

CCI, 2006. Center for Conservation Incentives, “Aldo Leopold’s Land Ethic Inspires An IncentivesBased Conservation Partnership,” New York, 2006. (Added to show the source of Figure 3-41.)

Envirocare, 2003. Envirocare of Utah, “Envirocare of Utah: Expanding Waste Acceptance Criteria to 

provide Low-Level and Mixed Waste Disposal Options’” Utah State University, St. Lake City, Utah, 

February 2003. (Added as a response to new Section 4.13.3.2, “Environmental Impacts of Off-site 

Disposal of Depleted Uranium Oxide in a Licensed Disposal Facility.” See Environmental Report 

Documentation Impact for RAI 2-b.)

EPA, 2002. U.S. Environmental Protection Agency, Emissions by Category Report – Criteria Air 

Pollutants, Lea County, New Mexico for Volatile Organic Compounds for 2002. 
Environmental Report 

Environmental Report Request for Additional Information Page 162 of 186

http://www/epa/gov/air/data/geosel.html. (Added as a response to RAI 8-c revising Section 4.6.1, “Air 

Quality Impacts from Construction.”)

GAO, 2004. U.S. General Accounting Office, Report to the Chairman, Committee on Energy and Natural 

Resources, U.S. Senate, Low-Level Radioactive Waste, Disposal Availability Adequate in the Short 

Term, but Oversight Needed to Identify Any Future Shortfalls (GAO-04-604), Washington, D.C. June 

2004. (Added as a response to new Section 4.13.3.2, “Environmental Impacts of Off-site Disposal of 

Depleted Uranium Oxide in a Licensed Disposal Facility.” See Environmental Report Documentation 

Impact for RAI 2-b.)

GLEI, 2010a. GL Environmental, Inc., “2010 Vegetation Survey Report,” Las Vegas, NM, November 29, 

2010. (Added as a response to ER RAI 14 revising Sections 3.5.3, “Major Vegetation Characteristics’ and 

Section 3.5.4, “Habitat Importance.”)

GLEI, 2010b. GL Environmental, Inc., “Status and Habitat of the Dunes Sagebrush Lizard at the 

Proposed Site for the International Isotopes Fluorine Products Facility in Lea County, New Mexico,” Las 

Vegas, NM, November 29, 2010. (Added as a response to ER RAI 14 revising Section 3.5.7.2, Habitat

subsection.

GLEI, 2010c. GL Environmental, Inc., Letter to Department of the Army, Albuquerque District Corp of 

Engineers, “RE: Waters of the U.S. Determination,” Las Vegas, NM, November 29, 2010. (Added as a 

response to ER RAI 15 revising Sections 3.1.1, “Land Use Status” and Section 3.4.9, “Description of 

Wetlands.”)

GLEI, 2010d. GL Environmental, Inc., “Existing Groundwater Conditions in Section 27, Range 18 South, 

Township 36 East,” Las Vegas, NM, December 8, 2010. (Added as a response to RAI 11 revising Section 

3.4.15.7, “Historical and Current Data from Site Wells.”)

GLEI, 2010e. GL Environmental, Inc., “2010 Soil and Vegetation Characterization Report,” Las Vegas, 

NM, December 8, 2010. (Added as a response to ER RAI 18 revising Sections 6.1.2.1, “Sampling 

Program” and Section 6.2.3, “Effluent Monitoring.”)

National Geographic, 2010. National Geographic, “Peregrine Falcon Falco peregrines,” Washington, 

D.C. 2010. (Added to show the source of Figure 3-44.)

NMED, 2011. New Mexico Environment Department, Ground Water Quality Bureau, Letter from Clint Marshall,

“Preliminary Description of Monitoring Requirements for the Proposed International Isotopes Uranium DeConversion Facility near Hobbs, New Mexico,” Santa Fe, New Mexico, February 9, 2011. (Added as a result of ER 

RAI 11 from revised Section 3.4.15.7.)

Painter, 2004. Charles W. Painter, “Conservation of the Sand Dune Lizard in New Mexico, 

Recommendations Based on the Management Plan for the Sand Dune Lizard,” New Mexico Department 

of Game and Fish, New Mexico, February 2004. (Added as a response to this RAI.)

RMBO, 2010. Rocky Mountain Bird Observatory, “Conserving Birds and their Habitats,” Brighton, 

Colorado, 2010. (Added to show the source of Figure 3-45.)

SBAP, 2010. Small Business Assistance Program, Colorado Department of Public Health and 

Environment, “A Guide to Air Regulations for Gasoline and Diesel Fuel Dispensing Stations,” Denver, 
Environmental Report 

Environmental Report Request for Additional Information Page 163 of 186

Colorado, 2010. (Added as a response to RAI 8-c revising Section 4.6.1, “Air Quality Impacts from 

Construction.”)

USACE, 2011. U.S. Army Corps of Engineers, Letter to G.L. Environmental, Inc., Subject: Action No. 

SPA-2011-00030-LCO, International Isotopes Fluorine Products Facility, January 26, 2011. (Added as a 

response to RAI 15 revising Section 3.4.9, “Description of Wetlands” and added letter to Appendix B, 

“Consultation Letters.) 

USFWS, 2008 reference (Cited in this RAI) from Section 3.5.7.5, “American Peregrine Falcon,” revised 

to show the reference as USFWS, 2006. 
Environmental Report 

Environmental Report Request for Additional Information Page 164 of 186

RAI 20 

Provide additional information on construction wastes and operations wastes. 

a. Provide estimated quantities for construction wastes separately for Phase 1 and Phase 2. Section 

3.12.2.1, “Construction Wastes,” of the ER (IIFP, 2009a) provides a non-quantitative description 

of construction wastes. Include in the estimates the annual waste generation for each waste type 

and the total amount of construction waste by type for each phase. Section 4.2.4.2, 

“Construction,” of the ER (IIFP, 2009a) provides an estimate for the number of roundtrips due 

to construction materials deliveries and waste shipments. This implies that detailed estimates for 

waste generation are available. 

Additional detailed information on waste volumes, as described above, is necessary to fully evaluate 

potential environmental impacts associated with waste generation and disposal. Also, clarification is 

necessary in Table 3-55, as described above, because for the upper range limit of RCRA waste quantities, 

the Table shows more waste for Phase 1 than for “Total for Phase 1 and Phase 2.” 

RESPONSE: 

Construction wastes have been estimated for Phase 1 and Phase 2. The quantities of each type of wastes 

expected to be generated at the IIFP Facility during each phase of operations will be added to the 

Environmental Report. 

Environmental Report Documentation Impact: Section 3.12 will be revised to refer to a listing of the 

type of waste generated during Phase 1 and Phase 2. A new Table 3-58 “Listing of Waste Streams from 

the Operation of the IIFP Facility” with the new data will be added Table 3-55, “Estimated Annual 

Quantities of Waste Generated at the IIFP Facility,” from Section 3.12.2, “Solid Waste Management,” 

will be deleted and replaced with a table having a more detailed listing of wastes. The table will also be 

renumbered Table 3-59 and will read as follows: 

3.12 Waste Management

Waste Management for the IIFP facility is divided into gaseous and solid wastes. Liquid wastes are not 

discharged from the process. The types of wastes are tabulated in Table 3-58. Descriptions of the 

generation, management, and disposal of various wastes from construction and operations are discussed 

in this section. Disposal plans, waste minimization, and environmental impacts are discussed in ER 

Section 4.13, “Waste Management Impacts.” 
Environmental Report 

Environmental Report Request for Additional Information Page 165 of 186

Table 3- 1, Listing of Waste Streams from the Operation of the IIFP Facility

Phase 1 Phase 2

Gaseous Emissions

Fluoride Stack Emissions-Process Stack Fluoride Stack Emissions-Process Stack

Uranium Stack Emissions-Dust Collectors UF4 Dust Collector Stack

Boiler Stack Emissions Boiler And Diesel Generator Stack

Diesel Generator Stack Emissions Oxide Dust Collector Stack

Future Oxide Dust Collector Stack

Decon Dust Collector Stack Decon Dust Collector Stack

Building Air Vents Building Air Vents

Solid Waste

Carbon Carbon

Carbon Filters Carbon Filters

Coke Coke

Drums Drums

Ion Exchange Resin-Softeners Ion Exchange Resin-Softeners

Dust Collector Bags Dust Collector Bags

UF4 Clinkers UF4 Clinkers

Oil Sorb, Dirt Oil Sorb, Dirt

Oxide and Drums Oxide and Drums

Radioactive Waste Trash Radioactive Waste Trash

Sintered Tubes Sintered Tubes

Wood Trash Wood Trash

Aerosol Cans/Paint Cans/Bulbs Aerosol Cans/Paint Cans/Bulbs

Molecular Sieve Molecular Sieve

Municipal Trash Waste Municipal Trash Waste

Safety Gear Safety Gear

Waste Glass Waste Glass

Calcium Fluoride Calcium Fluoride

Oily Rags, Solvents Oily Rags, Solvents

Activated Alumina And NaF Activated Alumina And NaF

Lab Chemical Waste Lab Chemical Waste

Sanitary Waste Biomass Sanitary Waste Biomass

Maintenance Trash Maintenance Trash

Food Waste Food Waste

Trash Metal Trash Metal

Ion Exchange Resin-Decon Ion Exchange Resin-Decon

Medical Waste Medical Waste

HEPA Filters HEPA Filters

Grit Blast Material Grit Blast Material

Potential Liquid Waste

Boiler Blow-down/Not Discharged Boiler Blow-down/Not Discharged

Softener Resin Back Flush/Not Discharged Softener Resin Back Flush/Not Discharged

Laundry Waste/Not Discharged Laundry Waste/Not Discharged

Lab Liquids/Not Discharged Lab Liquids/Not Discharged

Decon Shower/Not Discharged Decon Shower/Not Discharged

Stormwater/Not Discharged Stormwater/Not Discharged

Sanitary Water/Tertiary Treated/Sent To Tree 

Farm

Sanitary Water/Tertiary Treated/Sent To Tree 

Farm
Environmental Report 

Environmental Report Request for Additional Information Page 166 of 186

Table 3-55 Estimated Annual Quantities of Waste Generated at the IIFP Facility

Material

Phase 1

(lb)

Total Phase 1 and Phase 2

(lb)

Depleted uranium oxide 

including drums 2,800,000-6,000,000 8,700,000-18,000,000

Other process LLW 42,000-68,000 45,500-73,000

Misc, LLW 35,000-55,000 70,000-100,000

RCRA 32,300-361,500* 45,500-174,000*

Industrial waste including 

sanitary waste 71,000-108,500 85,400-135,000

*Includes Calcium Fluoride which may not be RCRA Waste

Table 3-59 Estimated Annual Quantities of Waste Generated at the IIFP Facility

Material Type 

Phase 1 Phase 2 

Construction 

Waste (lb) 

Operations 

(lb) 

Construction 

Waste (lb) 

Operations

(lb) 

Adhesives, Resins, Caulking 

Residues RCRA 100-200 120-240 

Aerosol Cans/Paint 

Cans/Bulbs RCRA 1,000-3,000 2,000-4,000 

Calcium Fluoride* RCRA 200,000-

300,000 

60,000-

90,000 

Lab Chemicals RCRA 200-400 200-400 

Lead (Batteries) RCRA 100-250 100-250 

Oil Filters RCRA 100-200 100-200 

Oil Sorb (Dirt Removal) RCRA 2,000-5,000 3,000-

7,000 

Paint, Thinners, Solvents, 

Organic Residues RCRA 100-500 100-500 

Pesticides RCRA 100-150 100-150 

Petroleum Products, Oils, 

Lubricants Residues RCRA 100-500 100-500 

Total RCRA Waste RCRA 600-1,800 203,200-

308,400 620-1,840 65,200-101,400 

Activated Alumina LLW 2,000-4,000 2,000-

4,000 

Air Ventilation Filters LLW 50-100 65-100 

Carbon LLW 25,000-

30,000 

25,000-

35,000 

DUF4 Clinkers LLW 5,000-

10,000 

5,000-

10,000 

Coke LLW 8,000-

12,000 

8,000-

12,000 
Environmental Report 

Environmental Report Request for Additional Information Page 167 of 186

Material Type 

Phase 1 Phase 2 

Construction 

Waste (lb) 

Operations 

(lb) 

Construction 

Waste (lb) 

Operations

(lb) 

Crushed Drums LLW 1,000-3,000 2,000-

8,000 

Dust Collector Bags LLW 500-3,000 1,000-

3,000 

Ion Exchange Resin LLW 1,000-2,000 2,000-

4,000 

Oxide for Burial plus Drums LLW 2,800,000-

6,200,000

8,700,000-

18,000,000 

Radioactive Waste Trash LLW 35,000-

55,000 

70,000-

100,000 

Scrap Metal LLW 4,000-6,000 4,000-8,000 4,000-6,000 12,000-

16,000 

Sintered Metal Tubes LLW 1,000-2,000 2,000-

3,000 

Sodium Fluoride LLW 2,000-4,000 2,000-

4,000 

Spent Blasting Sand LLW 100 100-200 100 100-200 

Wood Trash (Pallets) LLW 1,000-1,500 1,000-4,000 1,000-1,500 3,000-

12,000 

Total LLW LLW 5,100-7,600 2,885,650-

6,337,300- 5,100-7,600 8,834,165-18,211,300 

Air Filters-Vehicles SW 50-100 50-100 

Cardboard/Packing SW 300-500 300-500 

Clothing SW 100-200 150-300 

Fiber Drums SW 300-500 300-700 

Molecular Sieve SW 300-500 300-500 

Municipal Trash Waste 

(Misc. and Sanitary) SW 60,000-90,000 

72,000-

108,000 

Safety Gear SW 200-400 400-800 

Waste Glass SW 50-200 75-300 

Total Other Solid Wastes SW 650-1,100 60,650-

91,300 650-1,300 72,925-109,900 

Total Solid Waste RCRA, 

LLW, SW 6,350-10,500 3,149,500-

6,737,000 6,370-10,740 8,972,290-18,422,600 

*Less CaF2 is generated from the operations in Phase 2 than in Phase 1. 

 
Environmental Report 

Environmental Report Request for Additional Information Page 168 of 186

RAI 20 

Provide additional information on construction wastes and operations wastes. 

b. Clarify the total Phase 1 and Phase 2 column entry for Resource Conservation and Recovery Act 

(RCRA) operation waste in Table 3-55, “Estimated Annual Quantities of Waste Generated at the 

IIFP Facility,” of the ER (IIFP, 2009a). The range of RCRA waste reported for both phases is 

45,500 lb to 174,000 lb, which is less than the range reported for Phase 1 which is 32,300 lb to 

361,500 lb. Please clarify. 

Additional detailed information on waste volumes, as described above, is necessary to fully evaluate 

potential environmental impacts associated with waste generation and disposal. Also, clarification is 

necessary in Table 3-55, as described above, because for the upper range limit of RCRA waste quantities, 

the Table shows more waste for Phase 1 than for “Total for Phase 1 and Phase 2.” 

RESPONSE: 

The major portion of the RCRA waste is the potential waste CaF2. The production of CaF2 is much less in 

Phase 2 than Phase 1. This is a result of using water on certain process scrubbers for capturing HF as 

aqueous HF (versus KF with KOH) and transferring this liquid to the Phase 2 oxide process to react with 

DUF6. The HF solution after reacting with DUF6 is eventually distilled and separated as anhydrous 

hydrofluoric acid. Updated estimates for Phase 1 and Phase 2 RCRA wastes are provided in Table 3-59 

shown in the Environmental Report Documentation Impact for RAI 20-a. Note the asterisk for the CaF2 in 

Table 3-59 which reads “Less CaF2 is generated from the operations in Phase 2 than in Phase 1.” 

Environmental Report Documentation Impact: Paragraph six of Section 3.12.2, “Solid Waste 

Management,” will be revised to clarify the negative differential in the RCRA waste from Phase 1 to 

Phase 2 operations. Section 3.12.2 will read as follows: 

Resource Conservation and Recovery Act (RCRA) hazardous wastes will be collected and packaged in 

approved containers and shipped by a licensed RCRA transporter and sent to licensed RCRA disposal 

facility. Under New Mexico regulations, a facility that generates more than 1,000 kg (2,200 lb) per month 

is a large quantity generator of RCRA wastes. In New Mexico, hazardous waste generators are classified 

by the actual monthly generation rate, not the annual average. The major portion of the RCRA waste is 

the potential waste CaF2. As shown in Table 3-59, the production of CaF2 is much less in Phase 2 than 

Phase 1. This is a result of using water on certain process scrubbers for capturing HF as aqueous HF 

(versus KF with KOH) and transferring this liquid to the Phase 2 oxide process to react with DUF6. The 

HF solution after reacting with DUF6 is eventually distilled and separated as anhydrous hydrofluoric acid.
Environmental Report 

Environmental Report Request for Additional Information Page 169 of 186

RAI 21 

Provide additional information regarding past land use of the project area that may have already been 

collected by IIFP. 

a. Provide any information that has been collected on non-developmental human use such as cattle 

grazing. Include, if available, property research results and informant interview memoranda. 

This information is necessary in order to document past land uses/activities that have taken place in the 

project area and also to evaluate the potential for historic and cultural resources within the project area. 

The Phase I Environmental Site Assessment documents past development through historic aerial 

photographs. These photographs document that the project area has been largely undeveloped, but do not 

document human use that would not be considered “development,” such as extensive use of the area as 

rangeland for cattle. Although it is not required in the negative survey report that was prepared by the 

archaeological consultant, this information may have been gathered through property research or 

informant interviews. 

RESPONSE: 

The 4th paragraph of Section 1.4.7, “Surveys Conducted,” of the Environmental Report provides a listing 

of various governmental agency databases that were reviewed as part of the Phase 1 Environmental Site 

Assessment conducted in 2009 by BBC International, Inc. on the subject property. The results of those 

reviews are provided in Section 1.4.7. Additionally, a real estate title search was conducted as part of the 

Phase 1 Environmental Site Assessment. The title search is included below. 

 
Environmental Report 

Environmental Report Request for Additional Information Page 170 of 186
Environmental Report 

Environmental Report Request for Additional Information Page 171 of 186
Environmental Report 

Environmental Report Request for Additional Information Page 172 of 186

 
Environmental Report 

Environmental Report Request for Additional Information Page 173 of 186
Environmental Report 

Environmental Report Request for Additional Information Page 174 of 186

Environmental Report Documentation Impact: None 

 
Environmental Report 

Environmental Report Request for Additional Information Page 175 of 186

RAI 21 

Provide additional information regarding past land use of the project area that may have already been 

collected by IIFP. 

b. Provide available information concerning previous development for oil/gas and other energy 

infrastructure such as exploratory wells, abandoned oil/gas exploration infrastructure, and gas 

and power line rights-of-ways.

This information is necessary in order to document past land uses/activities that have taken place in the 

project area and also to evaluate the potential for historic and cultural resources within the project area. 

The Phase I Environmental Site Assessment documents past development through historic aerial 

photographs. These photographs document that the project area has been largely undeveloped, but do not 

document human use that would not be considered “development,” such as extensive use of the area as 

rangeland for cattle. Although it is not required in the negative survey report that was prepared by the 

archaeological consultant, this information may have been gathered through property research or 

informant interviews. 

RESPONSE: 

No oil/gas drilling has been conducted on the site. However, numerous transmission lines and pipelines as 

well as miscellaneous oil/gas facilities are located on the site. The 2nd and 3rd paragraphs of Section 1.4.7, 

“Surveys Conducted,” of the Environmental Report provide a listing of the lines and miscellaneous 

facilities on the site. Figure 1-6 of the Environmental Report depicts the easements on the IIFP Site. 

Figure RAI 21-b-1 below provides a map of the 640-acre IIFP Site showing the right-of-ways to the gas 

and electric companies in relation to the IIFP Facility. Figure RAI-b-2 provides a listing of those right-ofways. 

Environmental Report Documentation Impact: None. 

 
Environmental Report 

Environmental Report Request for Additional Information Page 176 of 186

Figure RAI 21-b-1 Right-of Ways on IIFP 640-Ac site 

 
Environmental Report 

Environmental Report Request for Additional Information Page 177 of 186

Figure RAI 21-b-2 Listing of the Right of Ways on the IIFP 640-Acre Site 

 
Environmental Report 

Environmental Report Request for Additional Information Page 178 of 186

RAI 22 

Provide support for the ER claim of better than industry average occupational safety statistics. 

For example IIFP could provide the last 5 years of Occupational Safety and Health Administration 

reports for an IIFP facility that does comparable work. 

The discussion of worker safety in Section 3.11.2.1 of the ER (IIFP, 2009a) does not provide details to 

support the claim of better than industry average. 

RESPONSE: 

The first sentence of Section 3.11.2.1 claiming that occupational injuries rates are expected to be better 

than industry average occupational safety statistics has been deleted. The manufacturing industry and the 

private industry safety statistics are compared for the years 2005 through 2009 in Table RAI 22-1 with 

those of INIS. Since the total number of employees for INIS is generally below 30 for those years, 

comparisons with the private industry and manufacturing industry would not be valid. Section 3.11.2.1 

will be revised to reflect the 5-year data instead of the 2007 data supplied initially in the ER. 

Table RAI 22-1 Comparison of INIS Occupational Safety Statistics with the Manufacturing and 

Private Industries 

Industry Year 

Annual 

Average 

Employment 

(Thousands) 

Total 

Recordable 

Cases 

DART1

ORC1

Total DAFW1 DJTR1

Manufacturing 2009 12,696.5 4.3 2.3 1.0 1.3 2.0 

Manufacturing 2008 13,735.0 5.0 2.7 1.2 1.5 2.3 

Manufacturing 2007 14,071.4 5.6 3.0 1.3 1.7 2.5 

Manufacturing 2006 14,150.0 6.0 3.3 1.4 1.9 2.7 

Manufacturing 2005 14,212.8 6.3 3.5 1.5 2.0 2.8 

Manufacturing 

Average 

(2005-

2009) 13,773.1 5.4 3.0 1.3 1.7 2.5 

Private Industry 2009 111,469.1 3.6 1.8 1.1 .8 2.0 

Private Industry 2008 115,352.6 3.9 2.0 1.1 .9 1.9 

Private Industry 2007 114,833.4 4.2 2.1 1.2 0.9 2.1 

Private Industry 2006 111,273.1 4.4 2.3 1.3 1.0 2.1 

Private Industry 2005 109,127.0 4.6 2.4 1.4 1.0 2.2 

Private Industry 

Average 

(2005-

2009) 112,411.0 4.1 2.1 1.2 0.9 2.1 

INIS 2009 26.7 (actual) 0 0 0 0 0 

INIS 2008 30.6 (actual) 2 1 0 1 1 

INIS 2007 25.36 (actual) 1 1 0 0 1 

INIS 2006 25.53 (actual) 0 0 0 0 0 

INIS 2005 18.32 (actual) 0 0 0 0 0 

INIS Average (2005-

2009) 25.3 (actual) 0.6 0.4 0 0.2 .4 

1 DART – Days Away from Work, Job Transfer, or Restricted Cases; DAFW – Days Away from Work Cases; DJTR - Days of Job Transfer or

Restricted Only Cases; ORC – Other Recordable Cases 
Environmental Report 

Environmental Report Request for Additional Information Page 179 of 186

Environmental Report Documentation Impact: Section 3.11.2.1, “Occupational Injury Rates,” will be 

revised to delete the claim that occupational injury rates at the IIFP facility are expected to be better that 

the industry average and to use the 2005-2009 average industry rates for calculating the expected 

occupational injury rates for the construction of IIFP Facility and for the operations of the facility. Former 

Table 3-54 will be updated and renumbered to Table 3-57. 

3.11.2.1 Occupational Injury Rates 

Occupational injury rates at the IIFP facility are expected to be better than the industry average owing to 

the commitment that IIFP is making in a safe design basis for facilities and programs, the safety culture, 

and adherence to the ISMS program and procedures. IIFP senior management commitment to safety is 

evident by its safety experience at its Idaho Falls facility and the OSHA Safety and Health Achievement 

Recognition Program (SHARP) recognitions it has received. Common occupational accidents at uranium 

plants similar to the proposed IIFP plant facility typically involve hand and finger injuries, tripping 

accidents, minor burns and impacts due to striking objects or falling objects. Table 3-5457 shows 

incidence rates representative of the nonfatal occupational injuries from the construction and operation for 

Total Private Industry. This representative calculation is based on the Bureau of Labor Statistics of the 

U.S. Department of Labor (2005-20097). The representative number of injuries would be that number for 

the Total Private Industry rate if the industry had an average of 200 workers during the construction of the 

facility for 18 months and 150 average workers during the operations of the facility. 

Table 3- 57 Nonfatal Occupational Injuries Projected for Construction and Operations of the IIFP 

Facility 

Case Type 

Construction (18 months) Operations (Yearly) 

Incidence 

Rate1 Number Incidence Rate1 Number 

Total Recordable Cases (TRC) 4.12 12.36 4.12 6.23

Days Away from Work, Job Transfer, or 

Restriction Cases (DART) 2.1 6.3 2.1 3.15 

Days Away From Work Cases (DAFW) 1.2 3.6 1.2 1.8 

Days of Job Transfer or Restricted Only Cases 

(DJTR) 0.9 2.7 0.9 1.35

Other Recordable Cases (ORC) 2.1 6.3 2.1 3.15 

TRC by Employment Size 5.3 15.9 5.3 7.95

Source: Bureau of Labor Statistics, U.S. Department of Labor (BLS, 2005-20098) 1

2005-20097 Incidence Rate per 100 full-time workers for Total Private Industry 
Environmental Report 

Environmental Report Request for Additional Information Page 180 of 186

RAI 23 

Provide clarifications on mitigation measures. 

Separate the mitigation measures proposed in Sections 5.2.3, “Geology and Soils,” 5.2.4, “Water 

Resources,” 5.2.5, “Ecological Resources,” and 5.2.6, “Air Impacts,” into those that would be 

implemented during the project’s pre-construction/construction and during operations. The text in these 

sections describes the mitigation measures listed as being in place to minimize impacts during 

construction or operations. However, it is not always clear at which time a specific mitigation will be 

implemented. For example, in Section 5.2.3, one mitigation measure that “will be in place during prelicensing and general construction, operations, and decommissioning” is described as “Berms will be 

utilized and Spill Prevention Control and Countermeasures Plan will be implemented.” 

It is reasonable that a Spill Prevention Control and Countermeasures (SPCC) Plan will be implemented 

during construction to mitigate fuel or similar liquid spills; however, in Section 5.2.13, “Waste 

Management,” IIFP states that “a Spill Prevention Control and Countermeasures Plan will be prepared 

prior to the start of operation of the facility or prior to the storage of oil on site....” It is not clear when 

reading Section 5.2.3 and 5.2.13 if the SPCC Plan will be in place during pre-construction and 

construction as well as during operations. As written in the ER, the proposed mitigations cannot always 

be associated with a specific project activity. 

RESPONSE: 

Sections 5.2.3, 5.2.4, 5.2.5, and 5.2.13 will be revised to list separately the mitigation measures to be 

taken during construction activities and operations. 

Environmental Report Documentation Impact: Sections 5.2.3, 5.2.4, 5.2.5, and 5.2.13 will be revised 

to separate the mitigation measures to be taken during construction activities from the mitigation 

measures to be taken during operations. Revised Sections 5.2.3, 5.2.4, 5.2.5, and 5.2.13 will read as 

follows: 

5.2.3 Geology and Soils (Revised section.) 

Mitigation measures will be in place during preconstruction-licensing and general construction, 

operations, and decommissioning to minimize impact to geology and soils. These measures 

include:Erosional impacts due to site clearing and grading will be mitigated by utilization of construction 

and erosion control BMPs, some of which are further described below:.

• The construction footprint will be minimized to the extent possible.

• Disturbed soils will be stabilized by acceptable means as part of the construction work. 

• Earthen berms, dikes and sediment fences will be utilized as necessary during construction phases 

stages to limit suspended solids in runoff. 

• Cleared areas not covered by structures or pavement will be stabilized by acceptable means as 

soon as practical. 

• Watering may be used to control fugitive dust. 

• Collect surface runoff in temporary rdetention basins (during construction) and permanent 

retention/evaporation basins (during operations). 

• Standard drilling and blasting techniques, if required, will be used to minimize impact to bedrock; 

reducing the potential for over excavation thereby minimizing damage to the surrounding rock. 
Environmental Report 

Environmental Report Request for Additional Information Page 181 of 186

• Drainage culverts and ditches will be stabilized and lined with rock aggregate to reduce flow 

velocity. 

• Soil stockpiles generated during construction will be placed in a manner to reduce erosion. 

• Excavated materials will be reused whenever possible. 

• Berms will be utilized and Spill Prevention Control and Countermeasures Plan will be 

implemented.

Mitigation measures will be in place during the operations of the IIFP to minimize impact to geology and 

soils. These measures include:

• Routine visual inspections and preventive maintenance will be conducted. 

• Above ground storage tanks of appropriate materials will be constructed. 

• Secondary containment for tanks storing petroleum products and hazardous chemicals will be 

used. 

• Berms will be utilized and Spill Prevention Control and Countermeasures Plan will be 

implemented.

• Spill cleanup materials in the areas of fuel line and tank hose connections will be maintained. 

• Contaminated soils will be sampled, analyzed, and managed in accordance with NRC, State, and 

other Federal requirements. 

• An approved Decommissioning Plan for ultimate NRC release of the site for unrestricted use and 

license termination will be established and implemented.

5.2.4 Water Resources (Revised 1st paragraph resulting in 2 paragraphs.) 

Mitigation measures will be in place to minimize potential impact on water resources during 

preconstruction -licensing and general construction , operations, and decommissioning of the IIFP 

Ffacility. As discussed in ER Section 4.4.7, “Control of Impacts to Water Quality,” there is little impact 

on any groundwater or surface water resources. These mitigation measures also prevent soil 

contamination. These include employing BMPs and the control of hazardous materials and fuels. In 

addition, the following controls are also implemented: 

• Construction equipment will be in good repair without visible leaks of oil, greases, or hydraulic 

fluids. 

• Control of spills during construction will be in conformance with the Spill Prevention Control and 

Countermeasures Plan procedures. 

• Use of BMPs will assure storm-water runoff related to these activities will not release runoff into 

nearby sensitive areas. 

• BMPs will also be used for dust control associated with excavation and fill operations during 

construction. Water conservation will be considered when deciding how often dust suppression 

sprays will be applied. 

• Silt fencing and sediment traps will be used. 

• Stone construction pads will be placed at entrance/exit if unpaved construction access adjoins a 

state road. 

• Basins are arranged to provide for the prompt, systematic sampling of runoff in the event of any 

special needs. 

• Water quality impacts will be controlled during construction phases stages by compliance with 

the National Pollution Discharge Elimination System General Permit requirements and by 

applying BMPs as detailed in the Stormwater Pollution Prevention Plan. 
Environmental Report 

Environmental Report Request for Additional Information Page 182 of 186

• A Spill Prevention Control and Countermeasure Plan will be implemented for the facility to 

identify potential spill substances, sources and responsibilities. 

Mitigation measures will be in place to minimize potential impact on water resources during operations of 

the IIFP facility. These include:

• All above ground petroleum storage tanks will be bermed. 

• Conduct routine visual inspections and preventive maintenance. 

• Any hazardous materials will be handled by approved methods and shipped off site to approved 

disposal sites. Sanitary wastes generated during site construction will be handled by portable 

systems; until such time that the plant sanitary waste treatment facility is available for use. 

• The facilities liquid effluent collection and treatment system provides a means to control liquid 

waste with the plant including the collection, evaporation, and minimization of liquid wastes for 

disposal. 

• Liquid effluent concentration releases to the evaporative tank will be below 10 CFR 20 

uncontrolled release limits. 

• Control of surface water runoff will be required for activities as covered by the NPDES General 

Permit. As a result, no impacts are expected to surface or groundwater bodies. 

• Stormwater and effluent sampling would will be conducted as necessary by the NPDES permit to 

protect surface water quality. In addition, site-wide groundwater levels would will continue to be 

monitored routinely, and the groundwater monitoring-well and pumping-well networks would 

will continue to be analyzed to confirm that the changes in groundwater levels associated with the 

Proposed ActionIIFP Facility are minimal. 

5.2.5 Ecological Resources (Revised section.) 

Mitigation measures will be in place to minimize the potential impact on ecological resources during 

construction activities, operations and decommissioning of the facility. These include: 

• Use of BMPs recommended by the State of New Mexico or various federal agencies; 

• No herbicides will be used during construction;, but may be used in limited amounts according 

to government regulations and manufacturer’s instructions to control unwanted noxious 

vegetation during operation of the facility;

• Minimize the construction footprint to the extent possible; and

• The use of retention (evaporation) basins to avoid direct discharge of stormwater runoff from 

process areas to any waters of the United States; and

• Implement site stabilization practices to reduce the potential for erosion and deposition of 

sediment. After construction is complete, the site will be stabilized with native grass species, 

pavement, and crushed stone to control erosion. Ditches, unless excavated in rock, will be lined 

with riprap, vegetation, or other suitable material as dictated by water velocity to control erosion. 

Furthermore, any eroded areas that may develop will be repaired and stabilized. 

Mitigation measures will be in place to minimize the potential impact on ecological resources during 

operations of the facility. The measures and other proposed practices to minimize impact to wildlife 

include the following:

• The use of retention (evaporation) basins to avoid direct discharge of stormwater runoff from 

process areas to any waters of the United States; 
Environmental Report 

Environmental Report Request for Additional Information Page 183 of 186

• Herbicides may be used in limited amounts according to government regulations and 

manufacturer’s instructions to control unwanted noxious vegetation during operation of the 

facility. Proposed practices to minimize impact to wildlife include:

• Placement of a raptor perch in an unused open area; 

• Install bird feeders at the visitor’s center; 

• Placement of quail feeders in the unused open areas away from buildings; 

• The management of unused open areas, including areas of native grasses and shrubs for the 

benefit of wildlife; 

• Use native plant species (i.e., low-water consuming plants) to vegetate disturbed areas and to 

enhance wildlife habitat; 

• Use netting, or other suitable material, to ensure migratory birds are excluded from retention 

(evaporation) basins that do not meet New Mexico Water Quality Control Commission surface 

water standards for wildlife usage; 

• Use animal friendly fencing within the Site so that wildlife cannot be injured or entangled; 

• Minimize the amount of open trenches at any given time; and 

• Treat or recycle of process air-scrubbers system liquids. 

In addition to proposed wildlife management practices above, IIFP will consider recommendations from 

appropriate state and federal agencies, including the United States Fish and Wildlife Service and the New 

Mexico Department of Game and Fish. 

5.2.13 Waste Management (Revised 3rd paragraph only.) 

IIFP will implement a spill control program for accidental oil spills. A Spill Prevention Control and 

Countermeasure (SPCC) Plan will be prepared prior to the start of operation construction of the facility or 

prior to the storage of oil on site in excess of de minimis quantities and will contain the following 

information: 

• Identification of potential significant sources of spills and a prediction of the direction and 

quantity of flow that would result from a spill from each source. 

• Identification of the use of containment-type or diversionary structures such as dikes, berms, 

culverts, booms, sumps, and diversion basins used at the facility to prevent discharged oil from 

reaching the surrounding environment. 

• Procedures for inspection of potential sources of spills and spill containment/diversion structures. 

• Assigned responsibilities for implementing the plan, inspections, and reporting. 

• As part of the SPCC Plan, other measures will include control of drainage of rain water from dike 

areas, containment of oil and diesel fuel in bulk storage tanks, above-ground tank integrity 

testing, and oil and diesel fuel transfer operational safeguards. 
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Environmental Report Request for Additional Information Page 184 of 186

RAI 24 

Verify the distance to the nearest residence from the proposed IIFP facility. 

The ER (IIFP, 2009a) in Section 1.3.3, “The Proposed Site,” states that the nearest residence is 8.5 km 

(5.3 mi) from the northern boundary of the site. Local maps appear to indicate the nearest residence 

could be approximately 1 mi from the northwest corner of the site (see attached map). Accurate 

information about the distance to residences is needed to fully assess potential impacts to those 

residences. 

RESPONSE: 

The nearest residence is indeed closer than that indicated in Rev. A of the ER. The nearest neighbor is 1.6 

miles west northwest of the site. The various sections of the ER will be revised to reflect the correct 

distance of the nearest residence. Those sections showing exposure data to the nearest resident were also 

revised to reflect the corrected distance. 

Environmental Report Documentation Impact: Exposure data to the nearest resident are shown in 

Section 4.12.2.2, Public and Occupational Exposure Impacts.” Various sections of the ER will be revised 

to show that the nearest neighbor at 1.6 miles from the site and the impact from that distance as shown 

below: 

3.1.2 Description of Off-site Areas (Revised 5th paragraph.) 

The nearest known residence to IIFP is situated west northwesteast of the site 2.68.5 km (1.65.3 mi) from 

the northern boundary fence. There are no known public recreational areas within 8 km (5 mi) of the site. 

Transportation corridors are discussed in ER Section 3.2, “Transportation.” A discussion of schools and 

hospitals is included in ER Section 3.10, “Socioeconomic.” 

4.7.1.2 Operational Impacts (Revised 3rd paragraph.)

Since the nearest residence is located west northwesteast of the IIFP Ssite at a distance of approximately 

2.68.5 km (1.65.3 mi), the resultant sound level exposure will be below the perception of the human ear. 

This is because a noise source over such a great distance will be dispersed in air and absorbed by natural 

landscape, vegetation, and buildings to the point of being masked by background ambient noise at the 

receptor. Noise impacts from the Phase 1 or Phase 2 operation of the IIFP facility are anticipated to be 

SMALL. 

4.7.4.1 Impacts to the Community (Revised 2nd paragraph.)

Potential impacts to local schools, churches, hospitals, and residences are not expected to be significant, 

as supported by the information presented in ER Section 4.7.1. The nearest ranch residence is located 

west northeastwest of the site at a distance of approximately 8.52.6 km (5.31.6 mi) and due to its 

proximity is not expected to perceive an increase in noise levels due to construction or operations. The 

nearest school, hospital, church and other sensitive noise receptors are beyond this distance, thereby 

allowing the noise to dissipate and be absorbed, helping decrease the sound levels even further. Xcel 

Energy Cunningham Station is located on NM 483 and Colorado Energy Station is located east northeast 

of the site. Xcel Energy Maddox Station is located east of the facility. DCP Midstream gas processing 

facility is located southeast of the facility. At the Arkansas Junction, tThere are no two homes and a café 
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Environmental Report Request for Additional Information Page 185 of 186

located near .2.9 km (1.8 mi) past the construction traffic off NM 483 nor at the intersection of U.S. 

62/180 and NM 483 from the site to be affected by the vehicle noise; but due to existing heavy tractor 

trailer vehicle traffic, the change will be minimal. No schools or hospitals are located at this intersection. 

4.9.4.2 Structure Obstructing Existing Views (Revised section.)

The tallest proposed on-site building is projected to be approximately 21.3 m (70 ft). However, relatively 

small-diameter emission stacks will be approximately 30.5 m (100 ft) tall. Due to the relative flatness of 

the site and vicinity, the structures will be observable from U.S. 62/180 and NM 483 and from the nearest 

neighbor at approximately 2.68.5 km (1.65.3 mi) from the site. The IIFP buildings will partially obstruct 

views of existing landscape. However, considering that there are no high quality viewing areas (see ER 

Section 3.9.7, “High Quality View Areas”) and the many existing, manmade structures (pump jacks, high 

power lines, industrial buildings, above-ground tanks) near the IIFP facility, the obstruction of existing 

views due to proposed structures will not degrade current conditions. (Refer to ER Figures in Section 

3.9.2.) 

5.1.7 Noise (Revised section.) 

The potential impacts related to noise generated during the preconstruction-licensing and general 

construction, operation, and decommissioning by the facility have been characterized in ER Section 4.7, 

“Noise Impacts.” SMALL impacts exist as related to the following activities: 

• Traffic noise; 

• Predicted noise levels at surrounding industrial facilities; and 

• Impacts to sensitive receptors (i.e., residences and wildlife). 

Noise levels will increase during the construction phases stages and due to operation of the IIFP plant, but 

not to a level that will cause significant impact to nearby sensitive receptors. The nearest residence is 

approximately 2.68.5 km (1.65.3 mi) from the site. Mitigation measures associated with noise impacts are 

listed in ER Section 5.2.7, “Noise.” 

5.2.7 Noise (Revised 1st paragraph.) 

Noise from construction activities will have the highest sounds levels, but the nearest home is located 

approximately 2.68.5 km (1.65.3 mi) from the site. Due to this distance, those residents will not perceive 

an increase in noise levels. There are no sensitive receptors (hospitals, or schools, residences) located 

near to the intersection of U.S. 62/180 and NM 483 at Arkansas Junction who would have been the most 

aware of the increase in traffic due to proximity to the source. However for mitigation measures, heavy 

truck and earth moving equipment usage will be restricted after twilight and during early morning hours. 

Noise suppression systems on construction vehicles will be kept in proper operation. 

8.3.7 Noise Impacts (Revised 2nd, 5th, and 6th paragraph.) 

The predicted noise level ranges from the construction of the IIFP Ffacility fall within acceptable sound 

pressure levels as determined by the U.S. Department of Housing and Urban Development. U.S. 62/180 is 

a main trucking thoroughfare for local industry on the south boundary and that there are no other sensitive 

receptors at the IIFP south boundary. In addition, noise levels in the predicted ranges at the south 

boundary and the west boundary would only be for a short duration and only during construction of the 

facilities. Xcel Energy Cunningham Generating Station is located on NM 483 on the western boundary of 
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Environmental Report Request for Additional Information Page 186 of 186

the IIFP Ssite, while Xcel Energy Maddox Generation Station and Colorado Energy Hobbs Generatingon

Station are located east and east northeast of the site, respectively. The DCP Midstream Linam Ranch 

Plant gas facility is located on U.S. 62/180 southeast of the IIFP Ssite. Due to the temporary and episodic 

nature of construction, and because of the significant distance to the nearest residence approximately 

2.68.5 km (1.65.3 mi) to the west northwesteast of the site, and since construction activities largely would 

be during weekday daylight hours, actual construction noise at the site is not expected to have a 

significant effect on nearby residents. 

Since the nearest known residence is located west northwesteast of the IIFP Ssite at a distance of 

approximately 2.68.5 km (1.65.3 mi), the resultant sound level exposure will be below the perception of 

the human ear. This is because a noise source over such a great distance will be dispersed in air and 

absorbed by natural landscape, vegetation, and buildings to the point of being masked by background 

ambient noise at the receptor. 

For operational noise exposure to the nearest residence located west northwesteast of the IIFP Ssite at a 

distance of approximately 2.68.5 km (1.65.3 mi), the resultant sound level exposure would will generally 

be below the perception of the human ear. Certain phases of operation, weather, time of day, wind 

direction, traffic patterns, season, and the location of the receptor will all impact perceived operational 

noise levels. Although the noise from the plant facility and the additional traffic would generally be 

noticeable, the operational noise is not expected to have a significant impact on nearby traffic or the 

surrounding industries. Thus, noise impacts from the operation of the IIFP Ffacility are SMALL.