Environmental Impact 

Statement for the 

Moore Ranch ISR Project 

in Campbell County, 

Wyoming 

Supplement to the 

Generic Environmental 

Impact Statement for 

In-Situ Leach Uranium 

Milling Facilities 

Final Report 

U.S. Nuclear Regulatory Commission 

Office of Federal and State Materials and 

Environmental Management Programs 

Q

NUREG-1910 

Supplement 1

H 

Environmental Impact 

Statement for the 

Moore Ranch ISR Project 

in Campbell County, 

Wyoming 

Supplement to the 

Generic Environmental 

Impact Statement for 

In-Situ Leach Uranium 

Milling Facilities 

Final Report 

Manuscript Completed: August 2010 

Date Published: August 2010 

Prepared by: 

U.S. Nuclear Regulatory Commission 

Office of Federal and State Materials and 

Environmental Management Programs 

NUREG-1910 

Supplement 1 

iii 

ABSTRACT 

The U.S Nuclear Regulatory Commission (NRC) issues licenses for the possession and use of 

source material provided that proposed facilities meet NRC regulatory requirements and would 

be operated in a manner that is protective of public health and safety and the environment. 

Under the NRC environmental protection regulations in the Code of Federal Regulations (CFR), 

Title 10, Part 51, which implement the National Environmental Policy Act (NEPA) of 1969, 

issuance of a license to possess and use source material for uranium milling requires an 

environmental impact statement (EIS) or a supplement to an EIS. 

In May 2009, NRC issued NUREG–1910, “Generic Environmental Impact Statement for In-Situ 

Leach Uranium Milling Facilities” (the GEIS). In the GEIS, NRC assessed the potential 

environmental impacts from the construction, operation, aquifer restoration, and 

decommissioning of an in-situ leach uranium recovery facility [also known as an in-situ recovery 

(ISR) facility] located in four specified geographic regions of the western United States. As part 

of that assessment, NRC determined which potential impacts would be essentially the same for 

all ISR facilities and which would result in varying levels of impacts for different facilities, thus 

requiring further site-specific information to determine potential impacts. The GEIS provides a 

starting point for the NRC NEPA analyses for site-specific license applications for new ISR 

facilities, as well as for applications to amend or renew existing ISR licenses. 

By letter dated October 2, 2007, Energy Metals Corporation submitted a license application to 

the NRC for a new source material license for the Moore Ranch Project, to be located in 

Campbell County, Wyoming, which is in the Wyoming East Uranium Milling Region identified in 

the GEIS. In October 2009, the name of Energy Metals Corporation U.S. was changed to 

Uranium One Americas, Inc. (Uranium One). The NRC staff prepared this SEIS to evaluate the 

potential environmental impacts from Uranium One’s proposal to construct, operate, conduct 

aquifer restoration, and decommission an ISR facility at the proposed Moore Ranch Project. 

This SEIS describes the environment potentially affected by the proposed site activities, 

presents the potential environmental impacts resulting from reasonable alternatives to the 

proposed action, and describes Uranium One’s environmental monitoring program and 

proposed mitigation measures. In conducting its analysis in this SEIS, the NRC staff evaluated 

site-specific data and information to determine whether the applicant-proposed activities and 

site characteristics were consistent with those evaluated in the GEIS. The NRC staff then 

determined relevant sections, findings, and conclusions in the GEIS that could be incorporated 

by reference in this SEIS, and areas that required additional analysis. Based on its 

environmental review, the NRC staff recommends that, unless safety issues mandate otherwise, 

that the source material license be issued as requested. 

Paperwork Reduction Act Statement 

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

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

approved by the Office of Management and Budget, approval numbers 3150-0014, 3150-0020, 

3150-0021, and 3150-0008. 

Public Protection Notification 

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

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

currently valid OMB control number. 
 
 v 

CONTENTS 

Section Page 

ABSTRACT ................................................................................................................................... iii 

FIGURES .................................................................................................................................... xiv 

TABLES ...................................................................................................................................... xv 

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

ABBREVIATIONS/ACRONYMS ............................................................................................... xxxi 

SI (MODERN METRIC) CONVERSION FACTORS ................................................................ xxxv 

1 INTRODUCTION ............................................................................................................ 1-1

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

 1.2 Proposed Action ................................................................................................. 1-1 

 1.3 Purpose of and Need for the Proposed Action ................................................... 1-1 

 1.4 Scope of the Supplemental Environmental Analysis .......................................... 1-3 

 1.4.1 Relationship to the GEIS ............................................................. 1-3 

 1.4.2 Public Participation Activities ...................................................... 1-4 

 1.4.3 Issues Studied in Detail .............................................................. 1-5 

 1.4.4 Issues Outside the Scope of the SEIS ........................................ 1-6 

 1.4.5 Related NEPA Reviews and Other Related Documents ............. 1-6 

 1.5 Applicable Regulatory Requirements ................................................................. 1-7 

 1.6 Licensing and Permitting .................................................................................... 1-7 

 1.6.1 NRC Licensing Process .............................................................. 1-8 

 1.6.2 Status of Permitting with Other Federal, Tribal, and 

 State Agencies ............................................................................ 1-8 

 1.7 Consultations .................................................................................................. 1-10 

 1.7.1 Endangered Species Act of 1973 Consultation ........................ 1-10 

 1.7.2 National Historic Preservation Act of 1966 Consultation .......... 1-10 

 1.7.3 Coordination with Other Federal, Tribal, State, and 

 Local Agencies .......................................................................... 1-11 

 1.7.3.1 Coordination with the Bureau of Land Management ................. 1-11 

 1.7.3.2 Coordination with the Bureau of Indian Affairs .......................... 1-11 

 1.7.3.3 Interactions with Tribal Governments ....................................... 1-12 

 1.7.3.4 Coordination with the Wyoming Department of 

 Environmental Quality ............................................................... 1-12 

 1.7.3.5 Coordination with the Wyoming Game and 

 Fish Department ....................................................................... 1-13 

 1.7.3.6 Coordination with the Wyoming State Engineer’s Office .......... 1-13 

 1.7.3.7 Coordination with the Wyoming Governor’s Planning Office .... 1-13 

 1.7.3.8 Coordination with the Wyoming Community 

 Development Authority .............................................................. 1-14 

 1.7.3.9 Coordination with Localities ...................................................... 1-14 

 1.8 Structure of the SEIS ........................................................................................ 1-14 

 1.9 References .................................................................................................. 1-14 

2 IN-SITU URANIUM RECOVERY AND ALTERNATIVES ............................................... 2-1 

 2.1 Alternatives Considered for Detailed Analysis.................................................... 2-1 

 2.1.1 The Proposed Action (Alternative 1) ........................................... 2-1 

 2.1.1.1 Disposal Via Class I Injection Well .............................................. 2-1 

 2.1.1.1.1 Site Description ........................................................................... 2-1 
Table of Contents 

 vi

CONTENTS (CONTINUED) 

Section Page 

 2.1.1.1.2 Construction Activities ................................................................. 2-2 

 2.1.1.1.2.1 Central Plant ............................................................................... 2-4 

 2.1.1.1.2.2 Access Roads ............................................................................. 2-7 

 2.1.1.1.2.3 Wellfields ..................................................................................... 2-7 

 2.1.1.1.2.3.1 Injection and Production Wells .................................................... 2-8 

 2.1.1.1.2.3.2 Monitoring Wells ......................................................................... 2-9 

 2.1.1.1.2.3.3 Well Construction and Testing .................................................... 2-9 

 2.1.1.1.2.3.4 Pipelines ................................................................................... 2-10 

 2.1.1.1.2.4 Other Structures and Systems .................................................. 2-10 

 2.1.1.1.2.5 Schedule ................................................................................... 2-10 

 2.1.1.1.3 Operation Activities ................................................................... 2-10 

 2.1.1.1.3.1 Uranium Mobilization ................................................................ 2-11 

 2.1.1.1.3.2 Lixiviant Chemistry .................................................................... 2-11 

 2.1.1.1.3.3 Lixiviant Injection and Production ............................................. 2-11 

 2.1.1.1.3.4 Excursion Monitoring ................................................................ 2-13 

 2.1.1.1.3.5 Uranium Processing .................................................................. 2-13 

 2.1.1.1.3.5.1 Ion Exchange ............................................................................ 2-14 

 2.1.1.1.3.5.2 Elution ....................................................................................... 2-14 

 2.1.1.1.3.5.3 Precipitation, Drying, and Packaging ........................................ 2-14 

 2.1.1.1.3.6 Management of Production Bleed and Other 

 Liquid Effluents ......................................................................... 2-15 

 2.1.1.1.3.7 Schedule ................................................................................... 2-15 

 2.1.1.1.4 Aquifer Restoration Activities .................................................... 2-15 

 2.1.1.1.4.1 Groundwater Restoration Methods ........................................... 2-16 

 2.1.1.1.4.1.1 Groundwater Transfer ............................................................... 2-17 

 2.1.1.1.4.1.2 Groundwater Treatment ............................................................ 2-18 

 2.1.1.1.4.2 Schedule ................................................................................... 2-19 

 2.1.1.1.5 Decontamination, Decommissioning, and 

 Reclamation Activities ............................................................... 2-19 

 2.1.1.1.5.1 Wellfield Decommissioning ....................................................... 2-19 

 2.1.1.1.5.2 Topsoil Handling and Replacement .......................................... 2-20 

 2.1.1.1.5.3 Final Contouring and Revegetation .......................................... 2-20 

 2.1.1.1.5.4 Procedures for Removing and Disposing of Structures 

 and Equipment .......................................................................... 2-21 

 2.1.1.1.5.4.1 Preliminary Radiological Surveys and 

 Contamination Control .............................................................. 2-21 

 2.1.1.1.5.4.2 Removal of Process Buildings and Equipment ......................... 2-21 

 2.1.1.1.5.4.3 Building Materials, Equipment, and Piping Released for 

 Unrestricted Use ....................................................................... 2-21 

 2.1.1.1.5.5 Schedule ................................................................................... 2-22 

 2.1.1.1.6 Effluents and Waste Management ............................................ 2-22 

 2.1.1.1.6.1 Gaseous and Airborne Particulate Emissions ........................... 2-22 

 2.1.1.1.6.2 Liquid Effluents ......................................................................... 2-24 

 2.1.1.1.6.3 Solid Wastes ............................................................................. 2-26 

 2.1.1.1.7 Transportation ........................................................................... 2-27 

 2.1.1.1.8 Financial Surety ........................................................................ 2-28 

 2.1.1.2 Alternative Wastewater Disposal Options ................................. 2-28 

 2.1.1.2.1 Evaporation Ponds .................................................................... 2-32 
Table of Contents 

 vii 

CONTENTS (CONTINUED) 

Section Page 

 2.1.1.2.2 Land Application ....................................................................... 2-33 

 2.1.1.2.3 Surface Water Discharge .......................................................... 2-34 

 2.1.1.2.4 Class V Injection Well ............................................................... 2-35 

 2.1.2 No-Action (Alternative 2) ........................................................... 2-35 

 2.2 Alternatives Eliminated from Detailed Analysis ................................................ 2-35 

 2.2.1 Conventional Mining and Milling ............................................... 2-36 

 2.2.2 Conventional Mining and Heap Leaching ................................. 2-37 

 2.2.3 Alternate Site Location .............................................................. 2-38 

 2.2.4 Alternate Lixiviants .................................................................... 2-38 

 2.2.5 Alternate Wastewater Treatment Methods ............................... 2-38 

 2.2.6 Comparison of the Predicted Environmental Impacts ............... 2-39 

 2.3 Final Recommendation .................................................................................... 2-44 

 2.4 References ....................................................................................................... 2-44 

3 AFFECTED ENVIRONMENT ......................................................................................... 3-1 

 3.1 Introduction .................................................................................................... 3-1 

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

 3.2.1.1 Existing Uses .............................................................................. 3-4 

 3.2.1.2 Rangeland and Pastureland ....................................................... 3-4 

 3.2.1.3 Minerals and Energy ................................................................... 3-4 

 3.3 Transportation .................................................................................................... 3-4 

 3.4 Geology and Soils .............................................................................................. 3-6 

 3.4.1 Geology ....................................................................................... 3-8 

 3.4.2 Soils .......................................................................................... 3-13 

 3.5 Water Resources .............................................................................................. 3-14 

 3.5.1 Surface Waters and Wetlands .................................................. 3-14 

 3.5.1.1 Drainage Basins ........................................................................ 3-14 

 3.5.1.2 Surface Water Features ............................................................ 3-14 

 3.5.1.2.1 Intermittent Streams .................................................................. 3-17 

 3.5.1.2.2 Ponds ........................................................................................ 3-17 

 3.5.1.3 Surface Water Flow .................................................................. 3-18 

 3.5.1.4 Surface Water Quality ............................................................... 3-18 

 3.5.1.5 Wetlands ................................................................................... 3-19 

 3.5.2 Groundwater ............................................................................. 3-24 

 3.5.2.1 Regional Groundwater Resources ............................................ 3-24 

 3.5.2.2 Local Groundwater Resources ................................................. 3-24 

 3.5.2.3 Uranium-Bearing Aquifers ......................................................... 3-25 

 3.5.2.3.1 Hydrogeologic Characteristics .................................................. 3-25 

 3.5.2.3.2 Level of Confinement ................................................................ 3-25 

 3.5.2.3.3 Groundwater Quality ................................................................. 3-26 

 3.5.2.3.4 Current Groundwater Uses ....................................................... 3-28 

 3.5.2.4 Surrounding Aquifers ................................................................ 3-29 

 3.6 Ecology ............................................................................................................. 3-29

 3.6.1 Terrestrial Ecology .................................................................... 3-30 

 3.6.1.1 Vegetation ................................................................................. 3-30 

 3.6.1.2 Wildlife ...................................................................................... 3-32 

 3.6.1.2.1 Big Game. ................................................................................. 3-32 
Table of Contents 

 viii

CONTENTS (CONTINUED) 

Section Page 

 3.6.1.2.2 Avian Species ........................................................................... 3-33 

 3.6.1.2.3 Other Mammals, Reptiles, and Amphibians .............................. 3-34 

 3.6.2 Aquatic Ecology ........................................................................ 3-34 

 3.6.3 Protected Species ..................................................................... 3-35 

 3.7 Meteorology, Climatology, and Air Quality ....................................................... 3-40 

 3.7.1 Meteorology and Climatology ................................................... 3-40 

 3.7.1.1 Temperature ............................................................................. 3-41 

 3.7.1.2 Wind .......................................................................................... 3-41 

 3.7.1.3 Precipitation .............................................................................. 3-42 

 3.7.1.4 Evaporation ............................................................................... 3-42 

 3.7.1.5 Climate Change and Greenhouse Gases ................................. 3-42 

 3.7.2 Air Quality ................................................................................. 3-45 

 3.8 Noise ................................................................................................................ 3-46 

 3.9 Historical and Cultural Resources .................................................................... 3-48 

 3.9.1 Cultural History ......................................................................... 3-49 

 3.9.1.1 Prehistoric Era .......................................................................... 3-49 

 3.9.1.2 Protohistoric/Historic Era .......................................................... 3-50 

 3.9.2 Historic and Cultural Resources Identified and Places of 

 Cultural Significance ................................................................. 3-50 

 3.9.2.1 Previous Cultural Resources Investigations ............................. 3-50 

 3.9.2.1.1 Archaeology–Identification and Evaluation ............................... 3-50 

 3.9.2.1.2 Ethnology–Identification and Evaluation ................................... 3-52 

 3.9.3 Historic Properties Listed in the National Register of 

 Historic Places .......................................................................... 3-52 

 3.9.4 Tribal Consultation and Places of Cultural Significance ........... 3-53 

 3.10 Visual and Scenic Resources ........................................................................... 3-53 

 3.11 Socioeconomics ............................................................................................... 3-54 

 3.11.1 Demographics ........................................................................... 3-55 

 3.11.2 Income ...................................................................................... 3-57 

 3.11.3 Housing ..................................................................................... 3-57 

 3.11.4 Employment Structure .............................................................. 3-57 

 3.11.5 Local Finance ............................................................................ 3-57 

 3.11.6 Education .................................................................................. 3-58 

 3.11.7 Health and Social Services ....................................................... 3-58 

 3.12 Public and Occupational Health and Safety ..................................................... 3-58 

 3.12.1 Background Radiological Conditions ........................................ 3-59 

 3.12.2 Public Health and Safety ........................................................... 3-62 

 3.12.3 Occupational Health and Safety ............................................... 3-62 

 3.13 Waste Management ......................................................................................... 3-63 

 3.13.1 Liquid Waste Disposal .............................................................. 3-63 

 3.13.2 Solid Waste Disposal ................................................................ 3-63 

 3.14 References ....................................................................................................... 3-64 

4 ENVIRONMENTAL IMPACTS AND MITIGATIVE ACTIONS ........................................ 4-1 

 4.1 Introduction .................................................................................................... 4-1 

 4.2 Land Use Impacts .............................................................................................. 4-1 
Table of Contents 

 ix 

CONTENTS (CONTINUED) 

Section Page 

 4.2.1 Proposed Action (Alternative 1) .................................................. 4-2 

 4.2.1.1 Construction Impacts .................................................................. 4-2 

 4.2.1.2 Operation Impacts ....................................................................... 4-3 

 4.2.1.3 Aquifer Restoration Impacts ........................................................ 4-3 

 4.2.1.4 Decommissioning Impacts .......................................................... 4-4 

 4.2.2 No-Action (Alternative 2) ............................................................. 4-4 

 4.3 Transportation Impacts ....................................................................................... 4-5 

 4.3.1 Proposed Action (Alternative 1) .................................................. 4-5 

 4.3.1.1 Construction Impacts .................................................................. 4-5 

 4.3.1.2 Operation Impacts ....................................................................... 4-7 

 4.3.1.3 Aquifer Restoration Impacts ...................................................... 4-10 

 4.3.1.4 Decommissioning Impacts ........................................................ 4-11 

 4.3.2 No-Action (Alternative 2) ........................................................... 4-12 

 4.4 Geology and Soils Impacts ............................................................................... 4-12 

 4.4.1 Proposed Action (Alternative 1) ................................................ 4-12 

 4.4.1.1 Construction Impacts ................................................................ 4-12 

 4.4.1.2 Operation Impacts ..................................................................... 4-14 

 4.4.1.3 Aquifer Restoration Impacts ...................................................... 4-15 

 4.4.1.4 Decommissioning Impacts ........................................................ 4-16 

 4.4.2 No-Action (Alternative 2) ........................................................... 4-17 

 4.5 Water Resources Impacts ................................................................................ 4-17 

 4.5.1 Surface Water and Wetlands Impacts ...................................... 4-17 

 4.5.1.1 Proposed Action (Alternative 1) ................................................ 4-17 

 4.5.1.1.1 Construction Impacts ................................................................ 4-18 

 4.5.1.1.2 Operation Impacts ..................................................................... 4-19 

 4.5.1.1.3 Aquifer Restoration Impacts ...................................................... 4-20 

 4.5.1.1.4 Decommissioning Impacts ........................................................ 4-21 

 4.5.1.2 No-Action (Alternative 2) ........................................................... 4-21 

 4.5.2 Groundwater Impacts ................................................................ 4-22 

 4.5.2.1 Proposed Action (Alternative 1) ................................................ 4-22 

 4.5.2.1.1 Construction Impacts ................................................................ 4-22 

 4.5.2.1.2 Operations Impacts ................................................................... 4-23 

 4.5.2.1.2.1 Operations Impacts to Shallow (Near-Surface) Aquifers .......... 4-24 

 4.5.2.1.2.2 Operations Impacts to Production and Surrounding Aquifers ... 4-25 

 4.5.2.1.2.3 Operations Impacts to Deep Aquifers Below the 

Production Aquifers ................................................................... 4-31 

 4.5.2.1.3 Aquifer Restoration Impacts ...................................................... 4-32 

 4.5.2.1.4 Decommissioning Impacts ........................................................ 4-33 

 4.5.2.2 No-Action (Alternative 2) ........................................................... 4-34 

 4.6 Ecological Resources Impacts ......................................................................... 4-34 

 4.6.1 Proposed Action (Alternative 1) ................................................ 4-34 

 4.6.1.1 Construction Impacts ................................................................ 4-35 

 4.6.1.1.1 Impacts to Vegetation 4-35 

 4.6.1.1.2 Impacts to Wildlife ..................................................................... 4-36 

 4.6.1.1.2.1 Impacts to Big Game ................................................................ 4-37 
Table of Contents 

 x

CONTENTS (CONTINUED) 

Section Page 

 4.6.1.1.2.2 Impacts to Other Mammals ....................................................... 4-38 

 4.6.1.1.2.3 Impacts to Avian Species .......................................................... 4-38 

 4.6.1.1.2.4 Impacts to Reptiles and Amphibians ......................................... 4-39 

 4.6.1.1.3 Impacts to Aquatic Resources .................................................. 4-39 

 4.6.1.1.4 Impacts to Threatened and Endangered Species ..................... 4-39 

 4.6.1.1.4.1 Impacts to Species of Concern ................................................. 4-40 

 4.6.1.2 Operations Impacts ................................................................... 4-40 

 4.6.1.2.1 Impacts to Vegetation ............................................................... 4-41 

 4.6.1.2.2 Impacts to Wildlife ..................................................................... 4-41 

 4.6.1.2.2.1 Impacts to Big Game ................................................................ 4-41 

 4.6.1.2.2.2 Impacts to Other Mammals ....................................................... 4-41 

 4.6.1.2.2.3 Impacts to Avian Species .......................................................... 4-42 

 4.6.1.2.2.4 Impacts to Reptiles and Amphibians ......................................... 4-42 

 4.6.1.2.3 Impacts to Aquatic Resources .................................................. 4-42 

 4.6.1.2.4 Impacts to Threatened and Endangered Species ..................... 4-42 

 4.6.1.2.4.1 Impacts to Species of Concern ................................................. 4-42 

 4.6.1.3 Aquifer Restoration Impacts ...................................................... 4-43 

 4.6.1.4 Decommissioning Impacts ........................................................ 4-43 

 4.6.2 No-Action (Alternative 2) ........................................................... 4-44 

 4.7 Air Quality Impacts ........................................................................................... 4-44 

 4.7.1 Proposed Action (Alternative 1) ................................................ 4-46 

 4.7.1.1 Construction Impacts ................................................................ 4-46 

 4.7.1.2 Operation Impacts ..................................................................... 4-48 

 4.7.1.3 Aquifer Restoration Impacts ...................................................... 4-48 

 4.7.1.4 Decommissioning Impacts ........................................................ 4-49 

 4.7.2 No-Action (Alternative 2) ........................................................... 4-49 

 4.8 Noise Impacts .................................................................................................. 4-50 

 4.8.1 Proposed Action (Alternative 1) ................................................ 4-50 

 4.8.1.1 Construction Impacts ................................................................ 4-50 

 4.8.1.2 Operation Impacts ..................................................................... 4-51 

 4.8.1.3 Aquifer Restoration Impacts ...................................................... 4-51 

 4.8.1.4 Decommissioning Impacts ........................................................ 4-52 

 4.8.2 No-Action (Alternative 2) ........................................................... 4-52 

 4.9 Impacts to Historical and Cultural Resources................................................... 4-53 

 4.9.1 Proposed Action (Alternative 1) ................................................ 4-53 

 4.9.1.1 Construction Impacts ................................................................ 4-53 

 4.9.1.2 Operation Impacts ..................................................................... 4-54 

 4.9.1.3 Aquifer Restoration Impacts ...................................................... 4-55 

 4.9.1.4 Decommissioning Impacts ........................................................ 4-55 

 4.9.2 No-Action (Alternative 2) ........................................................... 4-55 

 4.10 Visual and Scenic Resources Impacts ............................................................. 4-56 

 4.10.1 Proposed Action (Alternative 1) ................................................ 4-56 

 4.10.1.1 Construction Impacts ................................................................ 4-56 

 4.10.1.2 Operation Impacts ..................................................................... 4-57 

 4.10.1.3 Aquifer Restoration Impacts ...................................................... 4-58 

 4.10.1.4 Decommissioning Impacts ........................................................ 4-58 

 4.10.2 No-Action (Alternative 2) ........................................................... 4-59 
Table of Contents 

 xi 

CONTENTS (CONTINUED) 

Section Page 

 4.11 Socioeconomic Impacts ................................................................................... 4-59 

 4.11.1 Proposed Action (Alternative 1) ................................................ 4-60 

 4.11.1.1 Construction Impacts ................................................................ 4-60 

 4.11.1.1.1 Demographics ........................................................................... 4-60 

 4.11.1.1.2 Income ...................................................................................... 4-60 

 4.11.1.1.3 Housing ..................................................................................... 4-60 

 4.11.1.1.4 Employment Structure .............................................................. 4-61 

 4.11.1.1.5 Local Finance ............................................................................ 4-61 

 4.11.1.1.6 Education .................................................................................. 4-61 

 4.11.1.1.7 Health and Social Services ....................................................... 4-61 

 4.11.1.2 Operation Impacts ..................................................................... 4-61 

 4.11.1.2.1 Demographics ........................................................................... 4-62 

 4.11.1.2.2 Income ...................................................................................... 4-62 

 4.11.1.2.3 Housing ..................................................................................... 4-62 

 4.11.1.2.4 Employment Structure .............................................................. 4-62 

 4.11.1.2.5 Local Finance ............................................................................ 4-62 

 4.11.1.2.6 Education .................................................................................. 4-63 

 4.11.1.2.7 Health and Social Services ....................................................... 4-63 

 4.11.1.3 Aquifer Restoration Impacts ...................................................... 4-63 

 4.11.1.4 Decommissioning Impacts ........................................................ 4-64 

 4.11.2 No-Action (Alternative 2) ........................................................... 4-64 

 4.12 Environmental Justice Impacts ......................................................................... 4-64 

 4.12.1 Methodology ............................................................................. 4-65 

 4.12.2 Proposed Action (Alternative 1) ................................................ 4-67 

 4.12.3 No-Action (Alternative 2) ........................................................... 4-68 

 4.13 Public and Occupational Health and Safety Impacts ........................................ 4-68 

 4.13.1 Proposed Action (Alternative 1) ................................................ 4-68 

 4.13.1.1 Construction Impacts ................................................................ 4-68 

 4.13.1.2 Operation Impacts ..................................................................... 4-69 

 4.13.1.2.1 Radiological Impacts to Public and Occupational Health 

 and Safety From Normal Operations ........................................ 4-69 

 4.13.1.2.2 Radiological Impacts to Public and Occupational Health 

 and Safety from Accidents ........................................................ 4-72 

 4.13.1.2.3 Nonradiological Impacts to Public and Occupational Health 

 and Safety From Normal Operations ........................................ 4-74 

 4.13.1.2.4 Nonradiological Impacts to Public and Occupational Health 

 and Safety From Accidents ....................................................... 4-76 

 4.13.1.3 Aquifer Restoration Impacts ...................................................... 4-77 

 4.13.1.4 Decommissioning Impacts ....................................................... 4-77 

 4.13.2 No-Action (Alternative 2) ........................................................... 4-78 

 4.14 Waste Management Impacts .................................................... 4-78 

 4.14.1 Proposed Action (Alternative 1) ................................................ 4-79 

 4.14.1.1 Disposal Via Class I Injection Well ............................................ 4-79 

 4.14.1.1.1 Construction Impacts ................................................................ 4-79 

 4.14.1.1.2 Operation Impacts ..................................................................... 4-79 

 4.14.1.1.3 Aquifer Restoration Impacts ...................................................... 4-81 

 4.14.1.1.4 Decommissioning Impacts ........................................................ 4-81 
Table of Contents 

 xii

CONTENTS (CONTINUED) 

Section Page 

 4.14.1.2 Alternative Wastewater Disposal Options ................................. 4-83 

 4.14.1.2.1 Evaporation Ponds .................................................................... 4-83 

 4.14.1.2.2 Land Application ....................................................................... 4-84 

 4.14.1.2.3 Surface Water Discharge .......................................................... 4-86 

 4.14.1.2.4 Class V Injection Well ............................................................... 4-88 

 4.14.2 No-Action (Alternative 2) ........................................................... 4-89 

 4.15 REFERENCES ................................................................................................. 4-89 

5 CUMULATIVE IMPACTS ............................................................................................... 5-1 

 5.1 Introduction .................................................................................................... 5-1 

 5.1.1 Other Past, Present, and Reasonably Foreseeable 

 Future Actions ............................................................................. 5-1 

 5.1.1.1 Uranium Recovery Sites ............................................................. 5-2 

 5.1.1.2 Coal Mining ................................................................................. 5-5 

 5.1.1.3 Oil and Gas Production ............................................................... 5-5 

 5.1.1.4 Coal Bed Methane Development Projects .................................. 5-5 

 5.1.1.5 Other Mining ............................................................................... 5-7 

 5.1.1.6 EISs as Indicators of Past, Present, and Reasonably 

 Foreseeable Actions ................................................................... 5-7 

 5.1.2 Methodology ............................................................................... 5-7 

 5.2 Land Use .......................................................................................................... 5-11 

 5.3 Transportation .................................................................................................. 5-15 

 5.4 Geology and Soils ............................................................................................ 5-16 

 5.5 Water Resources .............................................................................................. 5-17 

 5.5.1 Surface Waters and Wetlands .................................................. 5-17 

 5.5.2 Groundwater ............................................................................. 5-20 

 5.6 Ecological Resources ....................................................................................... 5-22 

 5.6.1 Terrestrial Ecology .................................................................... 5-22 

 5.6.2 Aquatic Resources .................................................................... 5-24 

 5.6.3 Threatened and Endangered Species ...................................... 5-24 

 5.7 Air Quality ......................................................................................................... 5-24

 5.7.1 Global Climate Change and Greenhouse Gas Emissions ........ 5-27 

 5.7.1.1 Greenhouse Gas (GHG) Emissions in the Region ................... 5-28 

 5.7.1.2 GHG Emissions from the Proposed Moore Ranch Project ....... 5-29 

 5.7.1.3 Moore Ranch ISR Facility GHG Emissions Impact ................... 5-30 

 5.7.1.4 Effect of Climate Change on the Moore Ranch ISR Facility ..... 5-30 

 5.7.1.5 GHG Mitigation Measures ......................................................... 5-31 

 5.7.1.6 Other Mining Activities in the Powder River Basin .................... 5-31 

 5.8 Noise ................................................................................................................ 5-33 

 5.9 Historical and Cultural Resources .................................................................... 5-34 

 5.10 Visual and Scenic Resources ........................................................................... 5-34 

 5.11 Socioeconomics ............................................................................................... 5-35 

 5.12 Environmental Justice ...................................................................................... 5-38 

 5.13 Public and Occupational Health and Safety ..................................................... 5-39 

 5.14 Waste Management ......................................................................................... 5-40 
Table of Contents 

 xiii 

CONTENTS (CONTINUED) 

Section Page 

 5.15 References .................................................................................................. 5-42 

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

 6.1 Introduction .................................................................................................... 6-1 

 6.2 Radiological Monitoring ...................................................................................... 6-1 

 6.2.1 Airborne Radiation Monitoring .................................................... 6-2 

 6.2.2 Soils and Sediment Monitoring ................................................... 6-3 

 6.2.3 Vegetation, Food, and Fish Monitoring ....................................... 6-3 

 6.2.4 Surface Water Monitoring ........................................................... 6-3 

 6.2.5 Groundwater Monitoring ............................................................. 6-3 

 6.3 Physiochemical Monitoring ......................................................... 6-3 

 6.3.1 Wellfield Groundwater Monitoring ............................................... 6-4 

 6.3.1.1 Preoperational Groundwater Sampling ....................................... 6-4 

 6.3.1.2 Groundwater Quality Monitoring ................................................. 6-5 

 6.3.2 Wellfield and Pipeline Flow and Pressure Monitoring ................. 6-7 

 6.3.3 Surface Water Monitoring ........................................................... 6-7 

 6.3.4 Meteorological Monitoring ........................................................... 6-7 

 6.4 Ecological Monitoring ......................................................................................... 6-8 

 6.4.1 Vegetation Monitoring ................................................................. 6-8 

 6.4.2 Wildlife Monitoring ....................................................................... 6-8 

 6.5 References ......................................................................................................... 6-8 

7 COST-BENEFIT ANALYSIS .......................................................................................... 7-1 

 7.1 No-Action Alternative .......................................................................................... 7-1 

 7.2 Benefits from Proposed Action in Campbell County ........................................... 7-1 

 7.2.1 Benefits From Potential Production ............................................ 7-2 

 7.2.2 Costs to the Local Communities ................................................. 7-3 

 7.3 Evaluation Findings of the Proposed Moore Ranch Project ............................... 7-4 

 7.4 References ......................................................................................................... 7-4 

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

 8.1 Proposed Action (Alternative 1) .......................................................................... 8-2 

 8.2 No-Action (Alternative 2) .................................................................................... 8-2 

 8.3 Reference ........................................................................................................... 8-3 

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

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

 9.2 Center for Nuclear Waste Regulatory Analyses (CNWRA®) 

 Contractor Contributors ...................................................................................... 9-2 

 9.3 CNWRA Consultants and Subcontractors .......................................................... 9-4 

10 DISTRIBUTION LIST .................................................................................................. 10-1 

 10.1 Federal Agency Officials .................................................................................. 10-1 

 10.2 Tribal Government Officials .............................................................................. 10-2 

 10.3 State Agency Officials ...................................................................................... 10-3 

 10.4 Local Agency Officials ...................................................................................... 10-3 

 10.5 Other Organizations and Individuals ................................................................ 10-4 
Table of Contents 

 xiv

CONTENTS (CONTINUED) 

Section Page 

APPENDIX A CONSULTATION CORRESPONDENCE .......................................................... A-1 

APPENDIX B PUBLIC COMMENTS ON THE DRAFT ENVIRONMENTAL 

 IMPACT STATEMENT FOR THE MOORE RANCH IN-SITU 

 RECOVERY PROJECT IN CAMPBELL COUNTY, WYOMING 

 AND U.S. NUCLEAR REGULATORY COMMISSION RESPONSES ............... B-1 

APPENDIX C ALTERNATE CONCENTRATION LIMITS ........................................................ C-1 

APPENDIX D NONROAD COMBUSTION ENGINE EMISSIONS ESTIMATES ...................... D-1 

FIGURES 

Figure Page 

1-1 Location of the Proposed Moore Ranch Project ............................................................ 1-2 

2-1 Site Layout at the Proposed Moore Ranch Project ........................................................ 2-3 

2-2 Wellfield Patterns and Infrastructure for the Proposed Moore Ranch Project ................ 2-5 

2-3 Layout of the Central Plant ............................................................................................. 2-6 

2-4 Water Balance for the Proposed Moore Ranch Project ............................................... 2-12 

3-1 Surface Ownership at the Proposed Moore Ranch Project ........................................... 3-2 

3-2 Mineral Rights Ownership at the Proposed Moore Ranch Site ...................................... 3-3 

3-3 Land Use in the Vicinity of the Proposed Moore Ranch Project..................................... 3-5 

3-4 Generalized Stratigraphy Sequence Showing the 70 Sand Ore Production in the 

Wasatch Formation ........................................................................................................ 3-9 

3-5 Isopach Map Showing the Thickness of the 70 Sand .................................................. 3-10 

3-6 West-East Stratigraphic Cross Section of Wellfield 1 .................................................. 3-11 

3-7 West-East Stratigraphic Cross Section of Wellfield 2 .................................................. 3-12 

3-8 Drainage Basin and Sub-Watersheds at the Proposed Moore Ranch Project ............. 3-15 

3-9 CBM Production Near the Proposed Moore Ranch Project ......................................... 3-16 

3-10 Wetlands Located on the Proposed Moore Ranch Project .......................................... 3-23 

3-11 Vegetation Communities on the Proposed Moore Ranch Project ................................ 3-31 

3-12 Seasonal Wind Roses for the Antelope Coal Company ............................................... 3-44 

4-1 Difference in Size and Type of Drawdown in an Unconfined Aquifer and Confined 

Aquifer from an Extraction Well Operating at a Same Rate ......................................... 4-26 

5-1 Conventional and ISR Uranium Facilities, BLM Pasture Allotments and 

 Croplands Near the Proposed Moore Ranch ISR Facility ............................................ 5-12 

5-2 Oilfields, Coalfields, CBM Project Areas, Uranium Occurrences, and Uranium 

 Facilities near the Proposed Moore Ranch ISR Facility ............................................... 5-14 

5-3 Energy Developments Within 50-Mile Radius of Proposed Moore Ranch 

 ISR Project ................................................................................................................... 5-18 

 
Table of Contents 

 xv 

FIGURES (CONTINUED) 

Figure Page 

5-4 Wyoming, Campbell Country, Johnson Country, and Natrona County 

 Population, 1970–2020 ................................................................................................ 5-36 

5-5 Projected Campbell County Population and Employment to 2020............................... 5-37 

6-1 Proposed Moore Ranch Project Operational Environmental Monitoring Locations ....... 6-2 

TABLES 

Table Page 

1-1 ISL GEIS Range of Expected Impacts in the Wyoming East Uranium Milling Region ... 1-4 

1-2 Environmental Approvals for the Moore Ranch Uranium Project ................................... 1-9 

2-1 Soil Cleanup Criteria and Goals ................................................................................... 2-20 

2-2 Summary of Anticipated Liquid 11e.(2) Water Quality Parameters .............................. 2-25 

2-3 Comparison of Different Liquid Wastewater Disposal Options..................................... 2-30 

2-4 Comparison of Predicted Environmental Impacts ........................................................ 2-40 

3-1 Annual Average Daily Traffic Counts ............................................................................. 3-7 

3-2 Surface Water Quality at the Proposed Moore Ranch Project ..................................... 3-20 

3-3 Average Preoperational Baseline Groundwater Quality for Site Aquifers .................... 3-26 

3-4 Areal Distribution of Vegetation Communities within the Proposed License Area ....... 3-32 

3-5 Migratory Bird Species of Management Concern Observed on the Proposed 

 Moore Ranch Project ................................................................................................... 3-37 

3-6 Federally- and State-Listed Species ............................................................................ 3-38 

3-7 Climate Data for Midwest, Wyoming, Climate Station .................................................. 3-43 

3-8 Existing Conditions—2007 Ambient Air Quality Monitoring Data ................................. 3-46 

3-9 Noise Abatement Criteria: One Hour, A-Weighted Sound 

 Levels in Decibels (dBA) .............................................................................................. 3-47 

3-10 Newly Identified and Relocated Archaeological Sites by Location and 

 Site Characteristics ...................................................................................................... 3-51 

3-11 Population and Percent Growth in Campbell County, Wyoming, 

 From 1980 to 2050 ....................................................................................................... 3-55

3-12 Demographic Profile of the Population in Campbell County in 2000............................ 3-56 

3-13 Demographic Profile of the Population in Campbell County, 2006–2008 

 Three-Year Estimate .................................................................................................... 3-56 

3-14 Income Information for the Region of Influence 2006–2008 American 

 Community Survey 3-Year Estimates .......................................................................... 3-57 

3-15 Housing in Campbell County, Wyoming ....................................................................... 3-58 

4-1 Estimated Annual Average Daily Traffic on State Highway 387 for the Construction 

Phase of the Proposed Moore Ranch Project ................................................................ 4-6 

4-2 Estimated Annual Average Daily Traffic on State Highway 387 for the Operations 

Phase of the Proposed Moore Ranch Project ................................................................ 4-8 
Table of Contents 

 xvi

TABLES (CONTINUED) 

Table Page 

4-3 Estimated Annual Average Daily Traffic on State Highway 387 for the Aquifer 

Restoration Phase of the Proposed Moore Ranch Project........................................... 4-10 

4-4 Estimated Annual Average Daily Traffic on State Highway 387 for the 

Decommissioning Phase of the Proposed Moore Ranch Project................................. 4-11 

4-5 Percent Living in Poverty and Percent Minority in 2000 ............................................... 4-67 

4-6 Estimated Radon-222 Releases (Ci yr-1)* from the Proposed Moore Ranch .............. 4-71 

4-7 Generic Accident Dose Analysis for ISR Operations ................................................... 4-72 

5-1 Uranium Mining and Milling Projects—Distance and Direction From the Proposed 

Moore Ranch Project ..................................................................................................... 5-3 

5-2 Coal Mining and Milling Projects—Distance and Direction From the Proposed 

Moore Ranch Project ..................................................................................................... 5-6 

5-3 Cumulative Impacts on Environmental Resources ........................................................ 5-9 

5-4 Comparison of Carbon Dioxide Emissions by Source.................................................. 5-28 

5-5 Wyoming Historical and Reference Case GHG Emissions .......................................... 5-28 

5-6 Annual Greenhouse Gas Emissions at the West Antelope II Mine .............................. 5-32 

5-7 Estimated Annual Equivalent CO2 Emissions at the Black Thunder, Jacobs 

 Ranch, and North Antelope Rochelle Mines ................................................................ 5-33 

7-1 Towns Near to the Proposed Moore Ranch Project ....................................................... 7-3 

7-2 Summary of Costs and Benefits of the Proposed Moore Ranch Project ........................ 7-4 

8-1 Summary of Environmental Consequences ................................................................... 8-4 
 xvii

EXECUTIVE SUMMARY 

BACKGROUND 

By letter dated October 2, 2007, Energy Metals Corporation (EMC), a wholly-owned subsidiary 

of Uranium One Americas, submitted an application to the U.S. Nuclear Regulatory Commission 

(NRC) for a new source material license for the Moore Ranch Uranium Project (Moore Ranch 

Project), located in Campbell County, Wyoming. As of August 10, 2007, Energy Metals 

Corporation was acquired by Uranium One, Inc., therefore, the applicant for the proposed 

Moore Ranch Facility is Uranium One Americas, Inc. (Uranium One). Uranium One is 

proposing to recover uranium using the in-situ leach (ISL) recovery process [also known as the 

in-situ recovery (ISR)]. The proposed Moore Ranch Project includes a central processing plant, 

two wellfields, two to four deep disposal wells for liquid effluents, and the attendant 

infrastructure (e.g., pipelines). 

The Atomic Energy Act of 1954, as amended by the Uranium Mill Tailings Radiation Control Act 

of 1978, authorizes the NRC to issue licenses for the possession and use of source material 

and byproduct material. The NRC must license facilities, including ISR operations, in 

accordance with NRC regulatory requirements to protect public health and safety from 

radiological hazards. Under the NRC environmental protection regulations in the Code of 

Federal Regulations, Title 10, Part 51 (10 CFR Part 51), that implement the National 

Environmental Policy Act of 1969 (NEPA), preparation of an environmental impact statement 

(EIS) or supplement to an EIS is required to issue a license to possess and use source material 

for uranium milling [see 10 CFR 51.20(b)(8)]. 

In May 2009, the NRC staff issued NUREG–1910, “Generic Environmental Impact Statement for 

In-Situ Leach Uranium Milling Facilities” (herein after referred to as the GEIS). In the GEIS, 

NRC assessed the potential environmental impacts from the construction, operation, aquifer 

restoration, and decommissioning of an ISR facility located in four specified geographic regions 

of the western United States. The proposed Moore Ranch Project is located within the 

Wyoming East Uranium Milling Region identified in the GEIS. The GEIS provides a starting 

point for the NRC NEPA analysis for site-specific license applications for new ISR facilities, as 

well as for applications to amend or renew existing ISR licenses. This supplemental 

environmental impact statement (SEIS) incorporates by reference from the GEIS and uses 

information from the applicant’s license application and other independent sources to fulfill the 

requirements in 10 CFR 51.20(b)(8). 

This SEIS includes the NRC staff analysis that considers and weighs the environmental effects 

of the proposed action, the environmental impacts of alternatives to the proposed action, and 

mitigation measures to either reduce or avoid adverse effects. It also includes the NRC staff’s 

recommendation regarding the proposed action. 

PURPOSE AND NEED OF THE PROPOSED ACTION 

NRC regulates uranium milling, including the ISR process, under 10 CFR Part 40, “Domestic 

Licensing of Source Material.” Uranium One is seeking an NRC source material license to 

authorize commercial-scale ISR uranium recovery at the Moore Ranch site. The purpose and 

need for the proposed federal action is to either grant or deny the Uranium One license 

application to use ISR technology to recover uranium and produce yellowcake at the proposed 

Moore Ranch Project. Yellowcake is the uranium oxide product of the ISR milling process that 

is used to produce fuel for commercially-operated nuclear power reactors. Based on the 
Executive Summary 

 xviii

application, the NRC’s federal action is the decision whether to issue the license to 

Uranium One. 

This definition of purpose and need reflects the Commission’s recognition that, unless there are 

findings in the safety review required by the Atomic Energy Act or findings in the NEPA 

environmental analysis that would lead the NRC to reject a license application, the NRC has no 

role in a company’s business decision to submit a license application to operate an ISR facility 

at a particular location. 

THE PROJECT AREA 

The Moore Ranch Project is located in southwest Campbell County, in south-central Wyoming, 

about halfway between the Towns of Wright, located 40 km [25 mi] to the northeast, and 

Midwest-Edgerton, located 39 km [24 mi] to the southwest, with populations of 1,604 and 439 

people. The City of Gillette is located approximately 80 km [50 mi] to the northeast; the City of 

Casper is located approximately 85 km [53 mi] to the southwest. Planned facilities associated 

with the proposed project include a central plant with processing capabilities; two wellfields with 

injection, production, and monitor wells, header houses, and pipeline to connect the wellfields 

with the central plant; and an access road network. 

The proposed license area consists of approximately 2,879 ha [7,110 ac] and is remotely 

located on private land with about 14 percent of the surface rights being administered by the 

State of Wyoming. The U.S. Department of the Interior, U.S. Bureau of Land Management does 

not administer surface rights within the proposed Moore Ranch license area. 

IN-SITU RECOVERY PROCESS 

During the ISR process, an oxidant-charged solution, called a lixiviant, is injected into the 

production zone aquifer (uranium ore body) through injection wells. Typically, a lixiviant uses 

native groundwater (from the production zone aquifer), carbon dioxide, and sodium 

carbonate/bicarbonate, with an oxygen or hydrogen peroxide oxidant. As the lixiviant circulates 

through the production zone, it oxidizes and dissolves the mineralized uranium, which is present 

in a reduced chemical state. The resulting uranium-rich solution is drawn to recovery wells by 

pumping, and then transferred to a processing facility via a network of pipes, which may be 

buried just below the ground surface. At the processing facility, the uranium is removed from 

the solution. The resulting barren solution is then recharged with the oxidant and reinjected to 

recover more uranium from the wellfield. 

During production, the uranium recovery solution continually moves through the aquifer from 

outlying injection wells to internal recovery wells. These wells can be arranged in a variety of 

geometric patterns depending on the ore body configuration, aquifer permeability, and operator 

preference. Wellfields are often designed in a five-spot or seven-spot pattern, with each 

recovery (i.e., production) well being located inside a ring of injection wells. In the case of the 

Moore Ranch Project, the applicant has proposed a design based on a five-spot pattern. 

Monitoring wells completed in the production zone aquifer surround the wellfield pattern area; 

monitoring wells are also completed in the overlying and underlying aquifers. These monitoring 

wells are screened in the appropriate stratigraphic horizons to detect lixiviant in case it migrates 

out of the production zone. The uranium that is recovered from the solution would be 

processed, dried into yellowcake and packaged into NRC- and U.S. Department of 

Transportation (USDOT)-approved 205-L [55-gal] steel drums, and trucked offsite to a licensed 

conversion facility. 
Executive Summary 

 xix 

ALTERNATIVES 

The NRC environmental review regulations in 10 CFR Part 51 require NRC to consider 

reasonable alternatives, including the No-Action alternative, before acting on a proposal. The 

NRC staff considered a range of alternatives that could fulfill the underlying purpose and need 

for the proposed action. Based on this screening analysis, a set of reasonable alternatives was 

developed, and the impacts of the proposed action were compared with the impacts that would 

result if a given alternative were implemented. This SEIS evaluates the potential environmental 

and public health and safety impacts of the proposed action, the No-Action alternative, and 

considers alternative wastewater disposal options. Under the No-Action alternative, Uranium 

One would not be issued a license to construct and operate an ISR facility at the proposed site. 

Alternatives considered but eliminated from detailed analysis include conventional mining and 

milling, conventional mining and heap leach processing, alternate site location, alternate 

lixiviants, and alternate wastewater treatment methods. 

SUMMARY OF THE ENVIRONMENTAL IMPACTS 

This SEIS includes the NRC staff analysis that considers and weighs the environmental impacts 

resulting from the proposed construction, operation, aquifer restoration, and decommissioning of 

an ISR facility at the proposed Moore Ranch Project site and the No-Action alternative. This 

SEIS also provides mitigation measures to either reduce or avoid potential adverse impacts 

from the proposed action. This SEIS uses the assessments and conclusions reached in the 

GEIS, combined with site-specific information to assess and categorize impacts. 

As discussed in the GEIS and consistent with NUREG–1748 (NRC, 2003), the significance of 

potential environmental impacts is categorized as follows: 

 SMALL: The environmental effects are not detectable or are so minor that they will 

neither destabilize nor noticeably alter any important attribute of the 

resource. 

 MODERATE: The environmental effects are sufficient to alter noticeably but not 

destabilize important attributes of the resource. 

 LARGE: The environmental effects are clearly noticeable and are sufficient to 

destabilize important attributes of the resource. 

Chapter 4 provides the NRC evaluation of the potential environmental impacts of the 

construction, operation, aquifer restoration, and decommissioning of the proposed Moore Ranch 

Project. A list of the significance level of impacts by phase of the ISR facility lifecycle is 

provided next, followed by a brief summary of impacts by environmental resource area and ISR 

facility lifecycle phase. 

Impacts by Resource Area and ISR Facility Phase 

Land Use 

Construction: Impacts would be SMALL. Approximately 60 ha [150 ac] of the 2,879 ha 

[7,110 ac] or 2 percent of the proposed license area would be disturbed by the construction 

phase of the proposed Moore Ranch Project. Topsoil would be stripped and stockpiled to build 

the central plant, develop two wellfields and the attendant infrastructure, and to construct 
Executive Summary 

 xx

access roads. Livestock grazing and natural resources extraction (e.g., coal-bed methane 

development) would be excluded from the fenced areas surrounding the wellfields and the 

central plant during the life of the project. 

Operation: Impacts would be SMALL. Livestock grazing and natural resources extraction 

would continue to be limited from the wellfields and the central plant during the ISR lifecycle, 

limiting access to approximately 2 percent of the proposed license area for the life 

(approximately 12 years) of the project. As all facilities would be constructed, the direct impacts 

to land from earthmoving activities would be less than that during the construction phase. 

Aquifer Restoration: Impacts would be SMALL. The impact to land use would either be similar 

to, or less than that described for the operations phase. Access to wellfields would continue to 

be restricted from other uses as described for the operations phase. 

Decommissioning: Impacts would be SMALL. The impact on land use from decontaminating 

and decommissioning the proposed Moore Ranch Project would be similar to that experienced 

during the construction phase. Decommissioning the buildings, wellfields, access roads, and 

removing potentially contaminated soil would result in a temporary increase in land-disturbing 

activities. Upon completion of the plugging and abandonment of wells, soil would be reseeded 

and reclaimed in areas where it had been removed. At the completion of decommissioning 

activities, because the reclaimed land would be released for other uses and no longer restricted, 

the land use impacts for disturbed areas would be MODERATE until vegetation in seeded areas 

becomes established. Once vegetation is established in reclaimed areas, the land would be 

returned to a condition that would support a variety of land uses; therefore, the impact would 

be SMALL. 

Transportation 

Construction: Impacts would be SMALL. Truck traffic during construction activities would result 

in about a 9 percent increase in local traffic. Localized fugitive dust emissions, noise from 

traffic, and incidental wildlife or livestock kills could potentially occur but would be limited by the 

short access road distance. 

Operation: Impacts would be SMALL. Transportation impacts would be less than those during 

the construction phase because fewer trucks would be on the road. The probability of an 

accident was determined to be low. To minimize the risk of an accident, materials would be 

packed and shipped in accordance with NRC and the U.S. Department of Transportation 

regulations, and the applicant would develop emergency response plans. 

Aquifer Restoration: Impacts would be SMALL. Transportation impacts would be less than 

those during the construction phase and comparable to that during the operations phase. The 

need to transport hazardous materials and uranium-loaded resins would decrease as aquifer 

restoration proceeded; therefore, the potential for accidents resulting in spills or leaks would 

also decrease. 

Decommissioning: Impacts would be SMALL. Transportation impacts would be less than those 

during the construction and operations phases. Transport of hazardous materials would cease 

during decommissioning, and access roads would either be reclaimed or left in place for 

future use. 
Executive Summary 

 xxi 

Geology and Soils 

Construction: Impacts would be SMALL. Within the 61 ha [150 ac] that would be directly 

affected by ISR activities, most earthmoving activities would be limited to the construction of the 

central plant facilities and access roads, drilling of wells and installation of well header houses, 

and excavation of trenches to lay and bury pipelines. Topsoils removed during these activities 

would be saved and reused later to restore disturbed areas. Implementation of best 

management practices, the short duration of the construction phase, and mitigative measures 

such as reestablishing temporary native vegetation as soon as possible after implementation, 

would further minimize the potential impact on soils. 

Operation: Impacts would be SMALL. The removal of uranium mineral coatings on sediment 

grains in the target sandstones during ISR operations would result in a small permanent change 

to the mineralogical composition of the uranium-producing formations. However, the rock matrix 

of sediment grains would continue to form the support structure for the rock layers, and no 

significant matrix compression or ground subsidence would be expected to occur. The potential 

for spills during transfer of uranium-bearing lixiviant to and from the central plant would be 

further mitigated by implementing onsite standard operating procedures and complying with 

NRC and WDEQ requirements for spill response and reporting of surface releases. 

Aquifer Restoration: Impacts would be SMALL. During aquifer restoration, the process of 

groundwater transfer would not remove rock matrix or structure. The formation pressure would 

be decreased during restoration to ensure that the direction of groundwater flow was into 

wellfields to reduce the potential for lateral migration of constituents; however, the change in 

pressure would not result in collapse of overlying rock strata into the extraction zone of the 

aquifer. The potential for and response to spills would be comparable to that described for the 

operations phase. 

Decommissioning: Impacts would be SMALL. Disruption or displacement of soils would occur 

during dismantling of the facilities and reclamation of the land; however, the disturbed lands 

would be restored to their preextraction land use. Topsoil would be reclaimed and regraded to 

the original topography. 

Surface Waters and Wetlands 

Construction: Impacts would be SMALL. The occurrence of surface water at the Moore Ranch 

Project is limited, and surface water flow in channels is intermittent. Although the proposed 

construction activities such as laying pipeline and drilling wells could generate surface water 

runoff, implementation of best management practices and mitigative measures such as working 

in channels when they were dry would further minimize potential impacts. Well construction 

would avoid channels whenever possible. Temporary disturbances to the soil from traffic during 

construction could result in surface water runoff and sediment transport during periods of 

surface flow. Wetland areas would be avoided. 

Operation: Impacts would be SMALL. The applicant would construct the central plant and 

support facilities landward of intermittent channels and above peak flood elevations. 

Furthermore, the central plant and chemical and fuel storage tanks would also have secondary 

containment. Spills and leaks could potentially impact surface waters, but the implementation of 

best management practices would minimize the potential impact. A storm water management 

plan would detain or treat runoff. Routine maintenance of Wellfield 2 would require vehicular 

crossing of an intermittent channel; however, the applicant would implement sedimentation and 
Executive Summary 

 xxii

erosion control measures to further minimize surface water runoff from such temporary 

disturbances. 

Aquifer Restoration: Impacts would be SMALL. There would be no impact to surface water or 

groundwater during aquifer restoration because waste water generated during this ISR phase 

would be disposed of via deep well injection. Automated sensors would monitor the injection 

pressure of the deep disposal wells to detect potential leaks or pipeline/well ruptures that could 

result in a discharge. 

Decommissioning: Impacts would be SMALL. The impact from decommissioning would be 

similar to that during the construction phase. Land recontouring would restore areas to their 

preexisting condition to minimize the long-term impact to intermittent streams that were 

traversed during well maintenance. 

Groundwater 

Construction: Impacts would be SMALL. The primary impact to groundwater during the 

construction phase of the proposed Moore Ranch Project would be from the consumptive use of 

groundwater, injection of drilling fluids and muds during well installation, and from surface spills 

that could potentially migrate to groundwater. Groundwater for consumptive use would be from 

an aquifer located deeper than the proposed uranium recovery zone and the volume would be 

small and temporary relative to the water supply in the affected aquifer. The introduction of 

drilling or production fluid into a wellbore could impact the groundwater quality in the aquifers 

that would be penetrated; however, the use of drilling muds designed to seal the wellbore to set 

the casing would mitigate this impact. The applicant would use best management practices 

during facility construction and wellfield installation, including the implementation of a spill 

prevention and cleanup program, to prevent soil contamination that would require an immediate 

cleanup response to prevent soil contamination or infiltration to groundwater. 

Operation: Impacts on water levels in local wells and on groundwater quality would be SMALL. 

The operations phase of the proposed Moore Ranch Project could impact shallow (nearsurface) aquifers, the aquifer containing the ore body and surrounding aquifers, and deep 

aquifers below the ore production zone that are used for the disposal of liquid effluent. One 

domestic well, two stock wells, and one miscellaneous water well drilled by EMC occur within 

the proposed license area. The stock wells are not permitted through the State Engineers 

Office. No irrigation groundwater wells occur within the proposed license area. If the domestic 

well is completed in the exempted portion of the ore-bearing aquifer, the well cannot be used as 

a source of drinking water, in compliance with 40 CFR 146. If industrial or livestock wells are 

completed in the exempted portion of the aquifer, these wells are required to be properly 

plugged and abandoned to both avoid potential negative impacts on targeted bleed rates during 

ISR operations and to minimize potential adverse impacts on the environment. Domestic wells 

outside the proposed license area would be protected through the excursion monitoring and 

remediation requirements in 40 CFR 144.54 and 40 CFR 144.55 during ISR operation. 

Therefore, the potential impacts to the surficial aquifer would be SMALL. The potential impact 

to groundwater supplies in the ore production zone and surrounding aquifers is related to the 

consumptive use of groundwater and groundwater quality. Groundwater modeling, performed 

by the applicant and verified by the NRC staff, of the ore production zone predicted that the 

potential drawdown in private wells located within 3.2-km [2-mi] radius surrounding the 

proposed license area would experience a nominal drawdown in their private wells, but well 

yield would not be impacted. ISR operations would degrade groundwater quality in the ore 

production zone. However, the establishment of an inward hydraulic gradient, as well as the 
Executive Summary 

 xxiii 

applicant-installed groundwater monitoring network by the applicant to detect potential vertical 

and horizontal excursions, would limit the potential for undetected groundwater excursions that 

could degrade groundwater quality. Because the ore production zone is overlain and underlain 

by impermeable shale layers, this further ensures hydraulic isolation of the ore production zone 

to minimize potential groundwater contamination above and below the production zone. 

Liquid effluent generated from operation of the proposed Moore Ranch Project would be 

disposed of via deep well injection into Class I disposal wells permitted by the Wyoming 

Department of Environmental Quality (WDEQ). The groundwater in the formations being 

considered for deep well disposal must not be a potential underground source of drinking water 

and must comply with the WDEQ Water Quality and Regulations for Underground Management 

of Hazardous or Toxic Waste (Chapter 8, Section 6). 

Aquifer Restoration: Impacts would be SMALL. Groundwater restoration activities occur when 

a wellfield is no longer used to produce uranium. During aquifer restoration, there are potential 

impacts to groundwater quality and water levels. Groundwater modeling performed by the 

applicant and verified by NRC estimated groundwater drawdown in the ore production zone in 

Wellfields 1 and 2. The results of this modeling showed that the potential drawdown at the 

boundary of the proposed license area could range from 1 to 9 ft and from 1 to 6 ft at Wellfields 

1 and 2, from aquifer restoration activities. A drawdown contour of 1 ft extended from 1 to 4 mi 

from the proposed license area to the north, northwest, west and southwest. Only one private 

well was identified that could potentially be affected by the drawdown; however, the predicted 

drawdown would have a negligible impact on well yield. 

Because the ore production zone coalesces with an underlying aquifer in a portion of 

Wellfield 2, the applicant performed groundwater modeling to estimate the impact of aquifer 

restoration activities on water levels in the underlying aquifer and to surrounding users. The 

results of this analysis showed that private wells within a 3.2-km [2-mi] radius surrounding the 

proposed license area would experience a nominal 0.012 to 0.4-m [0.04- to 1.2]-ft drawdown, 

which would not be expected to impact well yields. Therefore, the impact on groundwater levels 

would be SMALL. Furthermore, the hydrologic test package for Wellfield 2 will be reviewed and 

approved by the NRC because of the more complex geology at that location. 

Impacts on groundwater quality would be SMALL. Postrestoration groundwater quality would 

be protective of the public and the environment. The goal of aquifer restoration is to restore 

groundwater quality in the ore production zone to preextraction baseline conditions. If the 

aquifer cannot be restored to baseline conditions, then NRC requires that either the production 

zone be returned to maximum contaminant levels in Table 5C of 10 CFR Part 40, Appendix A, 

or to NRC-approved alternate concentration limits. 

Decommissioning: Impacts would be SMALL. The potential impact to groundwater quality 

during decommissioning and reclamation would be comparable to that described previously for 

the construction phase of the proposed Moore Ranch Project. 

Ecological Resources 

Construction: Impacts would be SMALL. The impact would be further reduced by implementing 

the mitigative measures discussed in Section 4.6 of this SEIS. An estimated 61 ha [150 ac] of 

land would be disturbed during construction activities to build the central plant, develop 

wellfields, and lay pipeline, which would result in some habitat loss or alteration, displacement of 

wildlife, and injury or mortality from encounters with vehicles or heavy equipment, although 
Executive Summary 

 xxiv

wildlife species would generally be expected to disperse from the area when construction 

activities begin. The applicant could mitigate these impacts by observing Wyoming Fish and 

Game Department (WFGD) guidelines regarding noise, vehicular traffic, and human proximity 

during the construction phase. No threatened or endangered species are known to occur within 

the proposed license area. 

Operation: Impacts would be SMALL. The impact could be further reduced by implementing 

the mitigative measures discussed in Section 4.6 of this SEIS. Impacts would be similar to but 

less than those experienced during the construction phase because fewer earthmoving activities 

would occur. The applicant would reseed disturbed areas with WDEQ-approved seed mixtures. 

Aquifer Restoration: Impacts would be SMALL. Impacts would be similar to those experienced 

during the operations phase with no major differences in type or degree of impact. 

Decommissioning: Impacts would be SMALL. Temporary disturbances to land and soils could 

displace vegetation and wildlife species that recolonized the proposed license area after the 

construction phase. Revegetation and recontouring would restore habitat previously altered 

during construction and operations. 

Meteorology, Climatology, and Air Quality 

Construction: Impacts would be SMALL. Combustion engine exhausts from non-road mobile 

diesel equipment used during construction would generate air emissions. The magnitude of 

these emissions would be well below Clean Air Act thresholds for major stationary sources of air 

pollution. Considered along with meteorological conditions that are often favorable for 

dispersion, the emissions would be unlikely to change the present status of attainment with the 

National Ambient Air Quality Standards (NAAQS) nor impact the air quality of the nearest Class 

I Prevention of Significant Deterioration area. Fugitive dust emissions from road travel would be 

mitigated by the applicant’s plans for wetting and stabilizing unpaved roads. 

Operation: Impacts would be SMALL. Impacts would be similar to, but less than those 

experienced during construction. Operating ISR facilities are not major point source emitters of 

regulated nonradiological pollutants and emissions would be well below Clean Air Act 

thresholds for major sources of air pollution and therefore would be unlikely to change the 

present status of attainment with the National Ambient Air Quality Standards (NAAQS). 

Aquifer Restoration: Impacts would be SMALL. Impacts would be similar in type and degree as 

those experienced during the operations phase. Less vehicular traffic would be required during 

the aquifer restoration phase than during operations because there would be fewer yellowcake 

shipments than during operations. The use of existing infrastructure and reduced traffic volume 

would reduce fugitive dust and road vehicle exhaust emissions. Fugitive dust emissions from 

road travel would be further mitigated by the applicant plans for wetting and stabilizing 

unpaved roads. 

Decommissioning: Impacts would be SMALL. Impacts to air quality would be similar to that 

experienced during construction since the same type of activities would occur (e.g., earthmoving 

activities that generate fugitive dust and combustion engine emissions). The emissions would 

decrease as decommissioning progressed. 
Executive Summary 

 xxv 

Noise 

Construction: Impacts would be SMALL. Increased traffic and the use of drill rigs, heavy trucks, 

bulldozers, and other heavy equipment to construct and operate the wellfields, drill wells, 

construct access roads, and build the central plant would generate noise audible above the 

undisturbed background levels. The sound from construction activities would return to 

preexisting conditions at a distance of approximately 300 m [1,000 ft]. Therefore, there would 

be no audible noise at the location of the nearest resident approximately 4.5 km [2.8 mi] east of 

the center of the proposed Moore Ranch licensed area. 

Operation: Impacts would be SMALL. Traffic would be the primary noise-generating activity 

that could be heard offsite. The central plant and other processing activities would generate 

indoor noise audible to workers. The nearest resident would not notice a change in noise at 

their location approximately 4.5 km [2.8 mi] east of the center of the proposed project. 

Aquifer Restoration: Impacts would be SMALL. Noise impacts would be similar to, or less than, 

those experienced during the operations phase. Pumps and other wellfield equipment 

contained in buildings would reduce the potential sound impact to an offsite individual. Because 

the location of the nearest resident is approximately 4.5 km [2.8 mi] east of the center of the 

proposed project, there would be no change in background noise. 

Decommissioning: Impacts would be SMALL. Noise impacts would either be similar to, or less 

than, those experienced during the construction phase. Noise during this phase would be 

temporary, and when decommissioning and reclamation activities were complete, the noise 

level would return to baseline. At the location of the nearest resident approximately 4.5 km 

[2.8 mi] east of the center of the proposed project, there would be no change in 

background noise. 

Historical and Cultural Resources 

Construction: Impacts would be SMALL. No National Register of Historic Places (NRHP) 

eligible properties would be affected by construction, and any potentially eligible archaeological 

sites would be avoided. Should historical or cultural resources be encountered during 

construction, work would stop and appropriate federal and state officials would be notified. 

Operation: Impacts would be SMALL. No properties recommended eligible for listing to the 

NRHP would be affected by facility operations. None of the potentially eligible sites are located 

in areas affected by operations. As noted above, should historical or cultural resources be 

encountered during the plant operations, work would stop, and appropriate federal and state 

officials would be notified per the license condition. 

Aquifer Restoration: Impacts would be SMALL. Impacts to historical and cultural resources 

during the aquifer restoration phase would be similar to operations. Should historical or cultural 

resources be encountered during aquifer restoration, work would stop and the appropriate 

federal and state officials would be notified. 

Decommissioning: Impacts would be SMALL. No properties recommended eligible for listing to 

the NRHP would be affected during the decommissioning phase. Should historical or cultural 

resources be encountered during decommissioning, work would stop and appropriate federal 

and state officials would be notified. 
Executive Summary 

 xxvi

Visual and Scenic Resources 

Construction: Impacts would be SMALL. The existing land use surrounding the proposed 

Moore Ranch Project has pipelines, wellfields for CBM production, and utility lines that disturb 

the landscape; implementing the proposed action would not change the character of the 

landscape. Temporary and short-term visual impacts during the construction period in each 

wellfield would result from header house construction, well drilling, and construction of access 

roads and electrical distribution lines. 

Operation: Impacts would be SMALL. The wellfields would operate for approximately 3.25 

years, and they would be similar in visual impact to the CBM installations that occur in the area. 

The central plant would remain operational for approximately 12 years. The proposed 

operations are consistent with the BLM visual classification for this area. 

Aquifer Restoration: Impacts would be SMALL. The visual impact would be the same as 

described for the operations phase. No modifications to either scenery or topography would 

occur during aquifer restoration, which is estimated to last from 3.5 to 5 years. There would 

also be less vehicular traffic during aquifer restoration, creating less of a visual impact. 

Decommissioning: Impacts would be SMALL. Temporary impacts to the visual landscape 

would be comparable to those during the construction phase. Reclamation would return the 

visual landscape to baseline contours and would reduce the visual impact by removing buildings 

and the associated infrastructure. 

Socioeconomics 

Construction: Overall impacts would be SMALL. Most of the construction work force is 

expected to be found locally, so the short-term increased demand for housing would be a 

SMALL impact. Housing construction workers in nearby towns would have no demographic 

impacts. Workers would be paid the regional rates typical of the area; therefore income impacts 

would be SMALL. Local workers and contractors would be employed whenever possible, which 

would have a SMALL impact on employment rates. The local economy could experience a 

SMALL beneficial impact from the purchasing of local goods and services and an increase in 

sales and income tax revenues, however an increased short-term demand for social services 

would have a SMALL impact on these resources. 

Operation: Impacts could range from SMALL to MODERATE. The in-migration of workers and 

their families to nearby towns would have a SMALL impact on demographics. Workers would 

be paid similar rates to the average income in Wyoming; therefore income impacts would be 

SMALL. Housing demand would increase in local areas with low vacancy rates. The impact on 

housing could range from SMALL to MODERATE because of limited housing in the immediate 

area around the proposed ISR facility. Operation of the ISR facility at Moore Ranch would 

create new jobs, but because of the small size of the workforce, impacts on employment would 

be SMALL. The local economy would experience a SMALL beneficial impact from the 

purchasing of local goods and services and an increase in sales and income tax revenues. An 

increased demand for schools would have a SMALL impact on education because the current 

school system is not at full capacity. Increased demand for education and social services would 

have a SMALL impact. 
Executive Summary 

 xxvii 

Aquifer Restoration: Impacts would be SMALL. Impacts would be similar to, but less than, 

those during the operations. Fewer workers would be required, thus reducing the potential 

pressure on housing, education, and health and social services. 

Decommissioning: Impacts would be SMALL. Impacts would be similar to those during the 

construction phase. By this stage of the project, local governments would have adapted to the 

changes brought on by the project years earlier, and thus, housing, education, and health and 

social services demand would be more likely to be met. 

Environmental Justice 

All Phases: No minority or low-income block groups were identified in the vicinity of the 

proposed Moore Ranch Project. Therefore, there would be no disproportionately high and 

adverse impacts to minority and low-income populations from the construction, operation, and 

decommissioning of the proposed ISR facility at Moore Ranch. 

Public and Occupational Health and Safety 

Construction: Impacts would be SMALL. Construction activities, including the use of 

construction equipment and vehicles, could disturb the topsoil and create fugitive dust 

emissions. Radiological environmental monitoring data indicate that radioactivity levels in the 

topsoil at the proposed Moore Ranch Project are at background levels. Therefore, the 

inhalation of these concentrations of residual radioactivity would pose a radiological dose 

comparable to that from natural background exposure. 

Operation: The radiological impacts from normal operations would be SMALL. Public and 

occupational exposure rates at ISR facilities during normal operations have historically been 

well below regulatory limits. The remote location of the proposed Moore Ranch Project, in 

addition to the proposed technology coupled with the procedures to be implemented by the 

applicant, indicate that public and occupational health impacts from the operation of the facility 

would be consistent with historic observations. The radiological impacts from accidents would 

be SMALL for workers if the applicant’s radiation safety and incident response procedures in its 

NRC-approved radiation protection plan are followed, and SMALL for the public due to the 

facility’s remote location. The nonradiological public and occupational health impacts from 

normal operations and accidents, due primarily to risk of chemical exposure, would be SMALL if 

handling and storage procedures were followed. 

Aquifer Restoration: Impacts would be SMALL. Impacts would be similar to, but less than, 

those during the operations phase. The reduction or elimination of some operational activities 

further limits the relative magnitude of potential worker and public health and safety hazards. 

Decommissioning: Impacts would be SMALL. Impacts would be similar to, but less than, those 

experienced during construction. Soil and facility structures are decontaminated and lands are 

restored to preoperational conditions. 

Waste Management 

Construction: Impacts would be SMALL. Small-scale and incremental wellfield development 

would generate low volumes of construction waste consisting primarily of building materials, 

piping, and other solid wastes. No byproduct material would be generated during construction. 

Nonhazardous solid waste would be disposed of at a nearby municipal solid waste landfill. 
Executive Summary 

 xxviii

Hazardous construction wastes, such as organic solvents, paints, used oil and paint thinners 

would be disposed of in accordance with the requirements in the Resource Conservation and 

Recovery Act (RCRA). The nearby landfill and associated construction and demolition pit are 

not at capacity and would be able to continue receiving municipal solid waste and construction 

and demolition waste. 

Operation: Impacts would be SMALL. Liquid waste, including process bleed, restoration water, 

resin-transfer wash, filter washing, brine, and plant washdown, would be disposed of according 

to applicable NRC, federal, and state permits. Applicable permit requirements would mitigate 

potential adverse impacts from liquid waste management. From two to four Class 1 deep 

disposal wells permitted by the WDEQ and reviewed by the NRC would be drilled onsite for 

disposal of liquid effluent. Solids classified as Atomic Energy Act section 11e.(2) byproduct 

material (herein called “byproduct material”) would be sent to a licensed disposal facility. Some 

contaminated materials would be decontaminated and disposed of in accordance with 

applicable NRC regulations. 

Aquifer Restoration: Impacts would be SMALL. Waste decontamination and disposal 

procedures would be the same as those during the operation phase, resulting in similar impacts. 

Wastewater generated may increase but would be offset by the reduction in production capacity 

from the removal of wellfields. 

Decommissioning: Impacts would be SMALL. All process or potentially contaminated 

equipment and materials including tanks, filters, pumps, and piping would be inventoried and 

designated for removal to a new location for future use; removed to another licensed facility; 

disposal as byproduct material at a licensed facility; or decontaminated to meet unrestricted 

release criteria. The process building would be decontaminated, dismantled, and released for 

use at another location. Safe handling, storage, and disposal of decommissioning wastes would 

be addressed in a decommissioning plan, which would be approved by the NRC prior to 

initiating decommissioning activities. A preoperational agreement with a licensed disposal 

facility to accept radioactive wastes would ensure that sufficient disposal capacity would be 

available for byproduct material generated by decommissioning activities. 

Cumulative Impacts 

The cumulative impact on the environment that results from the incremental impact of the 

proposed licensing action when added to other past, present, and reasonably foreseeable future 

actions was also considered, regardless of what agency (Federal or non-Federal) or person 

undertakes such other actions. The NRC staff determined that the SMALL to MODERATE 

impacts from the proposed Moore Ranch Project are not expected to contribute perceptible 

increases to the MODERATE cumulative impacts, due primarily to; concurrent CBM activities at 

the proposed Moore Ranch Project in conjunction with other oil and gas exploration and mining 

activities occurring throughout the Powder River Basin. 

Summary of the Costs and Benefits of the Proposed Action 

The implementation of the proposed action would generate primarily regional and local costs 

and benefits. The regional benefits of building the proposed project would be increased 

employment, economic activity, and tax revenues in the region around the proposed site. Costs 

associated with the proposed Moore Ranch ISR Project are, for the most part, limited to the 

immediate area surrounding the site. 
Executive Summary 

 xxix 

Comparison of Alternatives 

Under the No-Action alternative, NRC would not issue a license to Uranium One to construct, 

operate, restore the aquifer, or decommission the proposed Moore Ranch Project. The land 

would be available for other uses. There would be no incremental increase in traffic on local 

roads attributable to the proposed action. No land disturbance from earthmoving activities that 

could disrupt vegetation or current grazing patterns would occur nor would increased surface 

water runoff result from such activities. CBM operations in the area would continue, resulting in 

surface water discharges to the local intermittent drainages. There would neither be an impact 

on groundwater quality nor to the water levels in surrounding private wells from operating the 

ISR facility. There would be no noise-generating activity nor increased fugitive dust or exhaust 

emissions from either earthmoving activities or increased commuter traffic to the site. If the NoAction alternative were implemented, no new jobs would be created from the proposed action 

nor would additional tax revenue accrue to the local economy. There would be no affect on 

housing availability, the education system, or public services. There would be no 

disproportionate high and adverse impacts to minority or low-income populations under either 

alternative, nor would there be any generation of byproduct material requiring disposition. 

Final Recommendation 

After weighing the impacts of the proposed action and comparing the alternatives, the NRC 

staff, in accordance with 10 CFR 51.91(d), sets forth its NEPA recommendation regarding the 

proposed action. Unless safety issues mandate otherwise, the NRC staff’s recommendation to 

the Commission related to the environmental aspects of the proposed action is that the source 

material license be issued as requested. This recommendation is based upon (1) the license 

application, including the environmental report submitted by Uranium One and the applicant 

supplemental letters and responses to the staff requests for additional information; 

(2) consultation with federal, state, tribal, and local agencies; (3) the NRC staff’s independent 

review; (4) the NRC staff’s consideration of comments received on the draft SEISs; and (5) the 

assessments summarized in this SEIS. 
 
 xxxi 

ABBREVIATIONS/ACRONYMS 

AADT annual average daily traffic count 

ADAMS Agency Wide Documents Access and Management System 

ACL alternate concentration limit 

AEA Atomic Energy Act 

ALARA as low as reasonably achievable 

AMSL above mean sea level 

APE area of potential effect 

APLIC Avian Power Line Interaction Committee 

AQD Air Quality Division 

ARPA Archaeological Resources Protection Act of 1979 

bgs below ground surface 

BIA Bureau of Indian Affairs 

BLM U.S. Bureau of Land Management 

BMP best management practice 

B.P. before present 

CAA Clean Air Act 

CBM coal bed methane 

CCESC Campbell County Educational Services Center 

CCS Center for Climate Strategies 

CDNR Colorado Department of Natural Resources 

CEQ Council on Environmental Quality 

CERCLA Comprehensive Environmental Response, Compensation, and 

Liability Act 

CESQG Conditionally Exempt Small Quantity Generator 

CFR Code of Federal Regulations 

CO carbon monoxide 

CWA Clean Water Act 

dBA decibels 

DOC U.S. Department of Commerce 

DOE U.S. Department of Energy 

EMC Energy Metals Corporation 

EA Environmental Assessment 

EIS Environmental Impact Statement 

ENSR ENSR Corporation 

E.O. Executive Order 

EPA U.S. Environmental Protection Agency 

ER Environmental Report 

ERP emergency response plan 

ESA Endangered Species Act of 1973 

FCR fire-cracked rock 

FHWA Federal Highway Administration 

FONSI finding of no significant impact 

FR Federal Register 
Abbreviations/Acronyms 

 xxxii 

FSME Office of Federal and State Materials and Environmental 

Management Programs 

FWS U.S. Fish and Wildlife Service 

GCRP U.S. Global Change Research Program 

GHG greenhouse gas 

GEIS Generic Environmental Impact Statement 

gpm gallons per minute 

HDPE high-density polyethylene 

HKM HKM Engineering, Inc. 

I Interstate 

ISL in-situ leach 

ISR in-situ recovery 

IX ion exchange 

JCSD Johnson County School District 

LQD Land Quality Division 

Lpm liters per minute 

MBHFI Migratory Birds of High Federal Interest 

MCL maximum contaminant level 

MIT mechanical integrity test 

MOA Memorandum of Agreement 

MOU Memorandum of Understanding 

MSDS material safety data sheets 

NAAQS National Ambient Air Quality Standards 

NCDC National Climatic Data Center 

NCRP National Council for Radiation Protection 

NCTHPO Northern Cheyenne Tribal Historic Preservation Office 

NEPA National Environmental Policy Act 

NHPA National Historic Preservation Act of 1966, as amended 

NMSS Nuclear Materials Safety and Safeguards 

NOAA National Oceanographic and Atmospheric Association 

NOI Notice of Intent 

NPDES National Pollutant Discharge Elimination System 

NRC U.S. Nuclear Regulatory Commission 

NRCS Natural Resource Conservation Service 

NRHP National Register of Historic Places 

NWI National Wetlands Inventory 

OSHA Occupational Safety and Health Administration 

PA Programmatic Agreement 

PDR Public Document Room 

PM particulate matter 

PRI Power Resources Inc. 

PRRCT Powder River Regional Coal Team 
Abbreviations/Acronyms 

 xxxiii 

PSD Prevention of Significant Deterioration 

psig pounds per square inch gauge 

PSM Process Safety Management 

PVC plastic polyvinyl chloride 

RAI Request for Additional Information 

RCRA Resource Conservation and Recovery Act 

RFFA reasonably feasible future action 

RO reverse osmosis 

ROD Record of Decision 

ROI region of influence 

RQ Reportable Quantity 

RTV Restoration Target Value 

SDWA Safe Drinking Water Act 

SEIS Supplemental Environmental Impact Statement 

SER Safety Evaluation Report 

SHPO State Historic Preservation Office 

SR State Highway 

TCP traditional cultural property 

TEDE total effective dose equivalent 

TDS total dissolved solids 

THPO Tribal Historic Preservation Office 

TNM Traffic Noise Model Version 2.5 

TPQ Threshold Planning Quantity 

TQ Threshold Quantity 

TR Technical Report 

TSCA Toxic Substances Control Act 

TSS total suspended solids 

UCL upper control limits 

UIC underground injection control 

UMTRCA Uranium Mill Tailings Radiation Control Act 

U.S. United States (or) United States Highway 

USACE U.S. Army Corps of Engineers 

USDA U.S. Department of Agriculture 

USDOT U.S. Department of Transportation 

USFS U.S. Forest Service 

USC United States Code 

USCB U.S. Census Bureau 

USDW Underground Source of Drinking Water 

USGS U.S. Geological Survey 

VRM Visual Resource Management 

WBC Wyoming Business Council 

WDE Wyoming Department of Education 

WDEQ Wyoming Department of Environmental Quality 

WDOE Wyoming Department of Employment, Research, and Planning 

WDOR Wyoming Department of Revenue 
Abbreviations/Acronyms 

 xxxiv 

WGFD Wyoming Game and Fish Department 

WLS Western Land Services 

WNDD Wyoming Natural Diversity Database 

WQD Water Quality Division 

W.S. Wyoming Statute 

WSEO Wyoming State Engineer’s Office 

WYDOT Wyoming Department of Transportation 

WYNDD Wyoming Natural Diversity Database 

WYPDES Wyoming Pollutant Discharge Elimination System
 xxxv 

SI* (MODERN METRIC) CONVERSION FACTORS 

Approximate Conversions From SI Units 

Symbol When You Know Multiply By To Find Symbol 

Length 

cm centimeters 0.39 inches In 

m meters 3.28 feet ft 

m meters 1.09 yards yd 

km kilometers 0.621 miles mi 

Area 

mm2 square 

millimeters 

0.0016 square inches in2

m2 square meters 10.764 square feet ft2

m2 square meters 1.195 square yards yd2

Ha hectares 2.47 acres ac 

km2 square kilometers 0.386 square miles mi2

Volume 

mL milliliters 0.034 fluid ounces fl oz 

L liters 0.264 gallons gal 

m3 cubic meters 35.314 cubic feet ft3

m3 cubic meters 1.307 cubic yards yd3

m3 cubic meters 0.0008107 acre-feet acre-feet 

Mass 

G grams 0.035 ounces oz 

Kg kilograms 2.202 pounds lb 

Mg (or “t”) megagrams 

(or “metric ton”) 

1.103 short tons 

(2,000 lb) 

T 

Temperature (Exact Degrees) 

°C Celsius 1.8C + 35 Fahrenheit °F 

*SI is the symbol for the International System of Units. Appropriate rounding should be 

performed to comply with Section 4 of ASTM E380 (ASTM International. “Standard for Metric 

Practice Guide.” West Conshohocken, Pennsylvania: ASTM International. (Revised 2003). 

1-1 

1 INTRODUCTION 

1.1 Background 

The U.S. Nuclear Regulatory Commission (NRC) prepared this Supplemental Environmental 

Impact Statement (SEIS) in response to an application submitted by Energy Metals Corporation 

(EMC) on October 2, 2007, to develop and operate the Moore Ranch Uranium Project (referred 

to herein as the proposed Moore Ranch Project), located in Campbell County, Wyoming, by 

in-situ recovery (ISR) methods (EMC, 2007) (Figure 1-1). EMC is a wholly owned subsidiary of 

Uranium One, Inc. as of August 10, 2007, Energy Metals Corporation was acquired by Uranium 

One, Inc, therefore, the applicant for the proposed Moore Ranch Facility is Uranium One 

Americas, Inc. (Uranium One). This site-specific SEIS supplements the Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities (referred to herein as the GEIS) in 

accordance with the process described in Section 1.8 of the GEIS (NRC, 2009a) and as 

detailed in Section 1.4.1 of this chapter. The NRC’s Office of Federal and State Materials and 

Environmental Management Programs prepared this SEIS as required by Title 10, “Energy,” of 

the U.S. Code of Federal Regulations (10 CFR) Part 51. These regulations implement the 

requirements of the National Environmental Policy Act of 1969 (NEPA), as amended (Public 

Law 91-190) which requires the Federal Government to assess the potential environmental 

impacts of major federal actions that may significantly affect the human environment. 

The GEIS used the terms “in-situ leach (ISL) process” and “11e.(2) byproduct material” to 

describe this uranium milling technology and the wastestream generated by this process. The 

SEIS replaces the term “in-situ leach (ISL)” with “in-situ uranium recovery (ISR)” to be 

consistent with the terminology used by the mining industry. The SEIS also uses the term 

“byproduct material” instead of “11e.(2) byproduct material” to describe the wastestream 

generated by this milling process to be consistent with the definition in 10 CFR 40.4. 

1.2 Proposed Action 

On October 2, 2007, EMC initiated the proposed federal action by submitting an application for 

an NRC source material license to construct and operate an ISR facility at the proposed Moore 

Ranch Project, and to conduct the consequent aquifer restoration and site decommissioning 

and reclamation activities. Based on the application, the NRC’s federal action is the decision 

whether to either grant or deny the license to Uranium One. Uranium One’s proposal is 

discussed in detail in Section 2.1.1 of the SEIS. 

1.3 Purpose of and Need for the Proposed Action 

NRC regulates uranium milling, including the ISR process, under 10 CFR Part 40, “Domestic 

Licensing of Source Material.” Uranium One is seeking an NRC source material license to 

authorize commercial-scale ISR uranium recovery at the proposed Moore Ranch Project. The 

purpose and need for the proposed Federal action is to either grant or deny Uranium One’s 

license application to use ISR technology to recover uranium and produce yellowcake at the 

proposed Moore Ranch Project. Yellowcake is the uranium oxide product of the ISR milling 

process that is used to produce fuel for commercially-operated nuclear power reactors. 

This definition of purpose and need reflects the Commission’s recognition that, unless there are 

either findings in the safety review required by the Atomic Energy Act or findings in the NEPA 
Introduction 

 1-2 

Figure 1-1. Location of the Proposed Moore Ranch Project 
Introduction 

 1-3 

environmental analysis that would lead the NRC to reject a license application, the NRC has no 

role in a company's business decision to submit a license application to operate an ISR facility 

at a particular location. 

1.4 Scope of the Supplemental Environmental Analysis 

The NRC prepared this SEIS to analyze the potential environmental impacts (i.e., direct, 

indirect, and cumulative impacts) of the proposed action and of reasonable alternatives to the 

proposed action. The scope of this SEIS considers both radiological and nonradiological 

(including chemical) impacts associated with the proposed action and its alternatives. This 

SEIS also considers unavoidable adverse environmental impacts, the relationship between 

short-term uses of the environment and long-term productivity, and irreversible and irretrievable 

commitments of resources. 

1.4.1 Relationship to the GEIS 

As discussed previously, this SEIS supplements the GEIS, published as a final report in 

May 2009 (NRC, 2009a). The GEIS assessed the potential environmental impacts associated 

with the construction, operation, aquifer restoration, and decommissioning of an ISR facility 

located in four specific geographic regions of the western United States. The proposed Moore 

Ranch Project is located in the Wyoming East Uranium Milling Region. Table 1-1 summarizes 

the expected environmental impacts by resource area in the Wyoming East Uranium Milling 

Region based on the GEIS analyses. 

The NRC staff considers the scope of the GEIS to be sufficient for the purposes of defining the 

scope of this SEIS. NRC accepted public comments on the scope of the GEIS from July 24 to 

November 30, 2007, and held three public scoping meetings, one of which was in the State of 

Wyoming. Additionally, NRC held eight public meetings to receive comments on the draft 

GEIS, published in July 2008. Three of these meetings were held in the State of Wyoming. 

Comments on the draft GEIS were accepted between July 28 and November 8, 2008. 

Comments received during scoping and on the draft GEIS are available through NRC’s 

Agencywide Documents Access and Management System (ADAMS) database on the 

NRC’s website (http://www.nrc.gov/reading-rm/adams.html). Transcripts of the 

scoping meeting and draft GEIS comment meetings in Wyoming are available at 

http://www.nrc.gov/materials/uranium-recovery/geis/pub-involve-process.html. A scoping 

summary report is provided as Appendix A to the GEIS (NRC, 2009a). 

This SEIS was prepared to fulfill the requirement at 10 CFR 51.20(b)(8) to prepare either an EIS 

or supplement to an EIS for the issuance of a source material license for an ISR uranium 

recovery facility (NRC, 2009a). The GEIS provides a starting point for NRC’s NEPA analyses 

for site-specific license applications for new ISR facilities, as well as for applications to amend or 

renew existing ISR licenses. As discussed in the GEIS, the GEIS provides criteria for each 

environmental resource area to help determine the significance level for potential impacts 

(e.g., SMALL, MODERATE, or LARGE). The NRC staff applied these criteria to the site-specific 

conditions at the proposed Moore Ranch Project. 

This SEIS tiers and incorporates by reference from the GEIS relevant information, findings and 

conclusions concerning potential environmental impacts. The extent to which NRC incorporates 

GEIS impact conclusions depends on the consistency between Uranium One’s proposed facility 

and activities and conditions at the proposed Moore Ranch Project and the reference facility 
Introduction 

 1-4 

Table 1-1. ISL GEIS Range of Expected Impacts in the 

Wyoming East Uranium Milling Region 

Resource Area Construction Operation

Aquifer 

Restoration Decommissioning

Land Use S to L S S S to M 

Transportation S to M S to M S to M S 

Geology and soils S S S S 

Surface Water S S to M S to M S to M 

Groundwater S S to L S to M S 

Terrestrial Ecology S to M S S S 

Aquatic Ecology S S S S 

Threatened and 

Endangered Species 

S to L S S S 

Air Quality S S S S 

Noise S to M S to M S to M S to M 

Historical and Cultural 

Resources 

S to L S S S 

Visual and Scenic 

Resources 

S S S S 

Socioeconomics S to M S to M S S to M 

Public Health and Safety S S to M S S 

Waste Management S S S S 

S: SMALL impact M: MODERATE impact L: LARGE impact 

Source: NRC, 2009a 

description and activities and information or conclusions in the GEIS. NRC’s determinations 

regarding potential environmental impacts and the extent to which GEIS impact conclusions 

were incorporated by reference are discussed in Chapter 4 of this SEIS. Section 1.8.3 of the 

GEIS describes in detail the relationship between the GEIS and the conduct of site-specific 

reviews as documented in this SEIS (NRC, 2009a). 

1.4.2 Public Participation Activities 

As part of the preparation of this SEIS, NRC staff met with federal, state, and local agencies and 

authorities during the course of an expanded visit to the proposed Moore Ranch Project and site 

vicinity in January 2009. The purpose of these meetings was to gather additional site-specific 

information to assist in the NRC staff’s environmental review and to aid the staff in its 

determination of the consistency between site and local information and similar information in 

the GEIS. As part of this effort to gather additional site-specific information, the NRC staff also 
Introduction 

 1-5 

contacted potentially interested Native American tribes and local authorities, entities, and public 

interest groups in person and via email and telephone. 

NRC published a Notice of Opportunity for Hearing in the Federal Register on January 25, 2008 

(see 73 FR 4642) related to the Moore Ranch license application (NRC, 2008a). No hearing 

requests were received. NRC also published a Notice of Intent to prepare this SEIS on August 

21, 2009 (see 74 FR 42332) (NRC, 2009b). 

1.4.3 Issues Studied in Detail 

To meet its NEPA obligations related to its review of the Moore Ranch license application, the 

NRC staff has conducted an independent, comprehensive evaluation of the potential 

environmental impacts from construction, operation, aquifer restoration, and decommissioning 

of an ISR facility at the proposed Moore Ranch Project. As discussed in Section 1.8.3 of the 

GEIS, the GEIS (1) evaluated the types of environmental impacts that may occur from ISL 

uranium milling facilities, (2) identified and assessed impacts that are expected to be generic 

(the same or similar) at all ISR facilities (or those with specified facility or site characteristics), 

and (3) identified the scope of environmental impacts that needed to be addressed in 

site-specific environmental reviews. Therefore, although all of the environmental resource 

areas identified in the GEIS will be addressed in site-specific reviews, certain resource areas 

would require a more detailed analysis, because the GEIS analysis concluded there could be a 

range in potential impacts (e.g., SMALL to MODERATE, SMALL to LARGE) depending upon 

site-specific conditions (see Table 1-1). Based on the results of the GEIS analyses, this SEIS 

provides a more detailed analysis of the following resource areas: 

• Land Use 

• Transportation 

• Geology and Soils 

• Surface Water 

• Groundwater 

• Terrestrial Ecology 

• Threatened and Endangered Species 

• Meteorology, Climatology, and Air Quality 

• Noise 

• Historical and Cultural Resources 

• Visual and Scenic Resources 

• Socioeconomics 

• Public Health and Safety 

• Waste Management 

Furthermore, certain site-specific analyses not conducted in the GEIS (e.g., assessment of 

cumulative impacts, analysis of environmental justice) were considered in this SEIS. 

Additionally, the NRC also includes a brief discussion about the effect of global climate change 

on the potential impacts from the proposed action based on a 10 year licensing period and the 

effect of the facility on global climate change. 
Introduction 

 1-6 

1.4.4 Issues Outside the Scope of the SEIS 

Some issues and concerns raised during the scoping process on the GEIS (NRC, 2009a; 

Appendix A) were determined to be outside the scope of the GEIS. These issues and concerns, 

(e.g., general support or opposition for uranium milling, potential impacts associated with 

conventional uranium milling, comments regarding the alternative sources of uranium feed 

material, comments regarding energy sources, requests for compensation for past mining 

impacts, and comments regarding the credibility of NRC) were also determined to be outside 

the scope of this SEIS. 

1.4.5 Related NEPA Reviews and Other Related Documents 

The following NEPA and other related documents were reviewed as part of the development of 

this SEIS to obtain information relevant to the issues raised: 

NUREG–1910, Generic Environmental Impact Statement for In-Situ Leach Uranium Milling 

Facilities, Final Report (NRC, 2009a). As discussed previously, the GEIS was prepared to 

assess the potential environmental impacts from the construction, operation, aquifer restoration, 

and decommissioning of an ISR facility located in four different geographic regions of the 

western United States, including the Wyoming East Uranium Milling Region where the Moore 

Ranch Project is located. The environmental analysis in this SEIS both tiers from and 

incorporates by reference the GEIS. 

NUREG–0706, Final Generic Environmental Impact Statement on Uranium Milling 

(NRC, 1980). This EIS provided a detailed evaluation of the impacts and effects of anticipated 

conventional milling operations in the U.S. through the year 2000 including analysis of tailings 

disposal programs. The environmental impacts of underground mining and conventional milling 

would be more severe than using ISR technology. As discussed in Section 2.2.1 of the final 

SEIS, conventional mining and milling were considered, but eliminated from detailed analysis at 

the proposed Moore Ranch Project. 

NUREG–1508, Final Environmental Impact Statement to Construct and Operate the 

Crownpoint Uranium Solution Mining Project, Crownpoint, New Mexico (NRC, 1997). This 

EIS evaluated the use of ISR technology at the Church Rock and Crownpoint sites at 

Crownpoint, New Mexico. Alternative uranium mining methods were not evaluated because the 

proposed sites were too deep to be extracted economically and underground mining would have 

more significant environmental impacts than ISR recovery. 

Final Environmental Impact Statement for the West Antelope II Coal Lease Application 

WYW163340 (BLM, 2008). The U.S. Bureau of Land Management (BLM) prepared this EIS for 

the West Antelope Coal Lease Application WYW163340, located approximately 24.6 km [15 mi] 

east of the Moore Ranch Project. The document evaluates the environmental impacts of 

leasing and mining coal on approximately 1,664 ha [4,109 ac]. 

NRC’s Safety Evaluation Report. The NRC staff is preparing a safety evaluation report (SER) 

for the Moore Ranch license application. In the SER, the NRC staff evaluates whether the 

licensee’s proposed action can be accomplished in accordance with the applicable provisions of 

10 CFR Part 20 and 10 CFR Part 40, Appendix A. The SER evaluates the licensee’s proposed 

facility design, operational procedures, and radiation protection program to ensure that the 

applicable requirements in 10 CFR Part 20 and 10 CFR Part 40 would be met by the applicant. 
Introduction 

 1-7 

The SER also provides the staff’s analysis of the initial estimate from the applicant of the 

funding needed to complete site decommissioning and reclamation. 

Final Environmental Impact Statement and Proposed Amendment of the Powder River 

Basin Oil and Gas Project, WY–070–02–065 (BLM, 2003). The BLM prepared this EIS to 

evaluate the potential effect from drilling, completing, operating and reclaiming 39,400 new 

natural gas wells and their associated infrastructure (roads, pipelines for gathering gas and 

produced water, electrical utilities, and compressors). This EIS evaluated potential effects to 

subwatersheds within the proposed Moore Ranch Project as well as to the aquifer that would be 

mined as part of the proposed action being considered in this SEIS. 

NUREG–0889, Draft Environmental Statement related to the operation of Sand Rock Mill 

Project, Docket No. 40-8743, Conoco, Inc. (NRC, 1982). NRC evaluated the potential 

environmental impact from issuing a license to Conoco, Inc. to construct and operate a uranium 

mill, associated with an open-pit mine in the same geographic area now being considered for 

in-situ recovery of uranium. This environmental statement evaluated alternatives for tailings 

management including the use of evaporation ponds, which were considered but eliminated 

from detailed analysis in this SEIS. 

NRC’s Environmental Review for the Nichols Ranch ISR Project. The NRC is reviewing a 

license application from Uranerz Energy Corporation for an ISR project located on about 

1,365 ha [3,371 ac] about 32 km [20 mi] northwest of the proposed Moore Ranch Project. 

NRC’s Environmental Review for the Irigaray and Christensen Ranch ISR Project License 

Renewal. The NRC is reviewing a license application from COGEMA Mining, Inc. for the 

renewal of Source Material License SUA–1341, which is located in Campbell and Johnson 

Counties about 30 km [19 mi] north-northwest of the proposed Moore Ranch Project. The 

Irigaray project was commercially licensed for ISR operations in 1978. The license was 

amended in 1987 to include the Christensen Ranch satellite facility. In June 2000, production 

ended and the site has been undergoing wellfield restoration and site decommissioning. 

1.5 Applicable Regulatory Requirements 

NEPA establishes national environmental policy and goals to protect, maintain, and enhance 

the environment. NEPA provides a process for implementing these specific goals for those 

Federal agencies responsible for an action. This SEIS was prepared in accordance with NEPA 

requirements and NRC’s implementing regulations in 10 CFR Part 51, and consistent with other 

regulations that were in effect at the time of writing. Appendix B of the GEIS summarizes other 

Federal statutes and implementing regulations and Executive Orders that are potentially 

applicable to environmental reviews for the construction, operation, aquifer restoration, and 

decommissioning of an ISR facility. 

Sections 1.6.3.1 and 1.7.5.1 of the GEIS provide a summary of the State of Wyoming’s statutory 

authority pursuant to the ISR process, relevant state agencies that are involved in the permitting 

of an ISR facility, and the range of state permits that would be required (NRC, 2009a). 

1.6 Licensing and Permitting 

NRC has statutory authority through the Atomic Energy Act as amended by the Uranium Mill 

Tailings Radiation Control Act (UMTRCA) to regulate uranium ISR facilities. In addition to 

obtaining an NRC license, uranium ISR facilities must also obtain the necessary permits from 
Introduction 

 1-8 

the appropriate federal, state, local and tribal governmental agencies. The NRC licensing 

process for ISR facilities was described in Section 1.7.1 of the GEIS. Sections 1.7.2 through 

1.7.5 of the GEIS describe the role of the other Federal, tribal, and state agencies in the ISR 

permitting process. 

This section of the SEIS summarizes the status of the NRC licensing process at the proposed 

Moore Ranch Project site and the status of Uranium One’s permitting with respect to other 

applicable Federal, tribal, and state requirements. 

1.6.1 NRC Licensing Process 

By letter dated October 2, 2007, Uranium One submitted a final license application to NRC for 

the Moore Ranch Project (EMC, 2007). As discussed in Section 1.7.1 of the GEIS, NRC 

initially conducts an acceptance review of a license application to determine whether the 

application is complete enough to support a detailed technical review. The NRC staff 

accepted the Moore Ranch license application for detailed technical review by letter dated 

December 20, 2007 (NRC, 2007). 

The NRC’s detailed technical review of the Moore Ranch license application is comprised of 

both a safety review and an environmental review. These two reviews are conducted in parallel 

(see Figure 1.7-1 of the GEIS). The focus of the safety review is to assess compliance with the 

applicable regulatory requirements in 10 CFR Part 20, 10 CFR Part 40, and Part 40, 

Appendix A. The environmental review is conducted in accordance with the regulations in 

10 CFR Part 51. 

The NRC hearing process (10 CFR Part 2) applies to proposed licensing actions and offers 

stakeholders a separate opportunity to raise concerns associated with the proposed action. 

NRC published a Notice of Opportunity for Hearing in the Federal Register on January 25, 2008 

(see 73 FR 4642) related to the Moore Ranch license application (NRC, 2008a). No request for 

a hearing was received on the Moore Ranch license application. 

1.6.2 Status of Permitting with Other Federal, Tribal, and State Agencies 

In addition to obtaining a source material license from NRC prior to conducting ISR operations 

at the Moore Ranch Project, Uranium One is also required to obtain necessary permits and 

approvals from other federal, tribal, and state agencies. These permits and approvals would 

address issues such as (1) the underground injection of solutions and wastewater associated 

with the ISR process; (2) the exemption of all or a portion of the extraction zone aquifer from 

regulation under the Safe Drinking Water Act; and (3) the discharge of stormwater during 

construction and operation of the ISR facility. 

Table 1-2 provides the permit status for Uranium One’s proposed Moore Ranch Project. 
Introduction 

 1-9 

Table 1-2. Environmental Approvals for the Moore Ranch Uranium Project

Issuing Agency Description Status 

Wyoming Department of Environmental 

Quality (WDEQ) 

Underground Injection 

Control Class III Permit 

(WDEQ Title 35-11) 

Class III UIC Permit application 

under review; anticipated 

approval by WDEQ in June 2010 

Aquifer Exemption 

(WDEQ Title 35-11) 

Aquifer exemption application 

under preparation; anticipated 

WDEQ review complete in June 

2010 

Underground Injection 

Control Class I 

(WDEQ Title 35-11) 

Class I UIC Permit application 

under review; anticipated 

approval by WDEQ in second 

quarter 2010 

Industrial Stormwater 

NPDES Permit 

(WDEQ Title 35-11) 

An Industrial Stormwater NPDES 

will be required for the Central 

Plant area. Expected submittal in 

second quarter 2011 

Construction Stormwater 

NPDES Permit 

(WDEQ Title 35-11) 

Construction Stormwater NPDES 

authorizations are applied for and 

issued annually under a general 

permit based on projected 

construction activities. The 

Notice of Intent will be filed at 

least 30 days before construction 

activities begin in accordance 

with WDEQ regulations. 

Mineral Exploration 

Permit 

(WDEQ Title 35-11) 

Mineral Exploration Permit 

342DN 

Approved: August 22, 2006 

Underground Injection 

Control Class V 

(WDEQ Title 35-11) 

The Class V UIC permit will be 

applied for following installation of 

an approved site septic system 

during facility construction 

Air Quality Permit 

Air Quality Permit Application 

(AP-10490) submitted March 

2010, under technical review 

U.S. Nuclear Regulatory Commission Source Materials License 

(10 CFR Part 40) Application under review 

U.S. Environmental Protection Agency 

(EPA) Aquifer Exemption 

(40 CFR 144, 146) 

Aquifer exemption application will 

be forwarded to EPA following 

WDEQ action 

U.S. Army Corps of Engineers Nationwide Permit (NP) 

#12 Authorization 

Activities authorized on May 10, 

2010 per NP #12 as defined in 

Part II of the Federal Register

(Vol. 72 No. 47, March 12, 2007). 

Source: Winter, 2010 
Introduction 

 1-10 

1.7 Consultations 

As a Federal agency, the NRC is required to comply with consultation requirements in Section 7 

of the Endangered Species Act of 1973 (ESA), as amended, and Section 106 of the National 

Historic Preservation Act of 1966 (NHPA), as amended. The GEIS took a programmatic look at 

the environmental impacts of ISR uranium recovery within four distinct geographic regions and 

acknowledged that each site-specific review would include its own consultation process with 

relevant agencies. Section 7 and Section 106 consultation conducted for the proposed 

Moore Ranch Project is summarized in Sections 1.7.1 and 1.7.2 below. Copies of the 

correspondence for this consultation are provided in Appendix A of this SEIS. Section 1.7.3 

discusses NRC coordination with other federal, state, and local agencies that was conducted 

during the development of the SEIS. 

1.7.1 Endangered Species Act of 1973 Consultation 

The ESA was enacted to prevent the further decline of endangered and threatened species and 

to restore those species and their critical habitats. Section 7 of the Act requires consultation 

with the U.S. Fish and Wildlife Service (FWS) to ensure that actions they authorize, permit or 

otherwise carry out will not jeopardize the continued existence of any listed species or adversely 

modify designated critical habitats. 

By letter dated April 9, 2008, NRC staff initiated consultation with the FWS, requesting 

information on endangered or threatened species or critical habitat on the Moore Ranch Project 

area (NRC, 2008b). NRC received a response from the Ecological Services Wyoming Field 

Office of the FWS, dated May 7, 2008, that (1) provided a list of the threatened or endangered 

species that may occur in the project area; (2) discussed obligations to protect migratory birds; 

(3) noted the negative impacts that can result from the land application of ISR wastewater; and 

(4) recommended avoidance of wetland and riparian areas and protection of sensitive species, 

such as the mountain plover and sage grouse (FWS, 2008). 

NRC staff also met with the FWS Buffalo office on January 14, 2009 to discuss site-specific 

issues. The main concern expressed by the Buffalo office was potential impacts to sage grouse 

and typical mitigation measures were discussed (NRC, 2009c). 

1.7.2 National Historic Preservation Act of 1966 Consultation 

Section 106 of the NHPA requires that federal agencies take into account the effects of their 

undertakings on historic properties and allow the Wyoming State Historic Preservation Office 

(SHPO) to comment on such undertakings. 

NRC initiated consultation with the Wyoming SHPO via a letter dated April 9, 2008 

(NRC, 2008c), requesting information from the SHPO to facilitate the identification of historic 

and cultural resources that could be affected by the proposed project. NRC staff also met with 

members of the SHPO’s office on January 12, 2009 (NRC, 2009c), to discuss site-specific 

issues, including Wyoming SHPO’s review process, cumulative impacts to historic sites, and 

best management practices. 

By letter dated October 22, 2009, the NRC solicited comment from the Wyoming SHPO 

regarding Uranium One’s cultural resources survey reports and related documentation 

(NRC, 2009d). In a letter dated November 3, 2009, the Wyoming SHPO concurred that the 

sites located within the proposed Moore Ranch project area are ineligible for listing on the 
Introduction 

 1-11 

National Register of Historic Places. In addition, the letter states: “We recommend the 

U.S. Nuclear Regulatory Commission allow the project to proceed in accordance with state and 

federal laws subject to the following stipulation: If any cultural materials are discovered during 

construction, work in the area shall halt immediately, the federal agency and SHPO staff be 

contacted, and the materials be evaluated by an archaeologist or historian meeting the 

Secretary of the Interior’s Professional Qualification Standards (48 FR 22716, September 1983). 

Additionally, if any future disturbance is planned at the locations of sites 48CA964, 48CA6694 

or 48CA6696 that evaluative testing be completed and submitted to our office with a 

determination of site eligibility and project effect. If eligible and adversely affected, a 

Memorandum of Agreement implementing appropriate mitigative measures will be required.” 

(Wyoming SHPO, 2010). The applicant has agreed to condition the license, if issued, to include 

a stop-work provision. 

The NRC staff has consulted with the Wyoming SHPO throughout the environmental 

review process. 

Section 1.7.3.3 Interactions with Tribal Governments provides a listing of the nine tribes 

consulted to solicit their comments or concerns regarding cultural resources and the proposed 

Moore Ranch Project. 

1.7.3 Coordination with Other Federal, Tribal, State, and Local Agencies 

The NRC staff interacted with multiple federal, tribal, state, and local agencies and/or entities 

during preparation of this SEIS to gather information on potential issues, concerns, and 

environmental impacts related to the proposed ISR facility at the Moore Ranch site. The 

consultation and coordination process included, but was not limited to, discussions with the 

BLM, the Bureau of Indian Affairs (BIA), tribal governments, the WDEQ, the Wyoming State 

Engineer’s Office (WSEO), and local organizations. 

1.7.3.1 Coordination with the Bureau of Land Management 

The BLM is responsible for administering the National System of Public Lands and the federal 

minerals underlying these lands. The BLM also manages split estate situations where federal 

minerals underlie a surface that is privately held or owned by state or local government. The 

proposed Moore Ranch Project contains no BLM surface-administered lands, but there are 

mineral rights administered by the BLM, which have been leased to the applicant. 

While the BLM was not a cooperating agency for this SEIS, NRC staff coordinated with the BLM 

during its preparation. During the review, NRC staff met with personnel from BLM’s Buffalo 

Field Office and the State Office in Cheyenne, Wyoming. BLM provided NRC staff with 

guidance documents; clarification regarding mineral leases administered on BLM lands; and 

expressed concerns related to water quality and hydrology, cumulative effects, and 

socioeconomic impacts. 

1.7.3.2 Coordination with the Bureau of Indian Affairs 

The U.S. Department of the Interior, Bureau of Indian Affairs’ (BIA) mission is to enhance the 

quality of life, to promote economic opportunity, and to carry out the responsibility to protect and 

improve the trust assets of American Indians, Indian tribes, and Alaska Natives. BIA is 

responsible for the administration and management of 66 million acres of land held in trust by 

the United States for American Indian, Indian tribes, and Alaska Natives. 
Introduction 

 1-12 

The NRC staff met with staff from the BIA in Fort Washakie, Wyoming on January 15, 2009 

(NRC, 2009c). The NRC staff briefed the BIA on proposed ISR facilities in Wyoming, and the 

involvement of BIA and Indian tribes in the environmental review process was discussed. The 

BIA stated that tribal governments should be consulted for any projects in the state. BIA also 

recommended that tribal elders be involved in cultural and historic surveys. 

1.7.3.3 Interactions with Tribal Governments 

In response to guidance from the Wyoming SHPO and to carry out Executive Order 13175, 

‘Consultations and Coordination with Indian Tribal Governments,’ the NRC staff initiated 

discussions with tribes that possess heritage and cultural interest and ties to the Moore Ranch 

project area. Letters dated February 23, 2009 (NRC, 2009e), were sent to the following nine 

tribes to solicit their comments or concerns regarding cultural resources and the Moore 

Ranch Project: 

• Eastern Shoshone 

• Northern Arapaho 

• Northern Cheyenne 

• Blackfeet 

• Three Affiliated Tribes 

• Ft. Peck Assinboine/Sioux 

• Oglala Sioux 

• Crow 

• Cheyenne River Sioux 

To date, no responses from these Tribes have been received. 

1.7.3.4 Coordination with the Wyoming Department of Environmental Quality 

NRC staff met with the WDEQ in Cheyenne on January 12, 2009 (NRC, 2009c) to discuss the 

WDEQ’s role in NRC’s environmental review process for the Moore Ranch project (see NRC 

Trip Report in Appendix A). Issues that were brought up during the meeting included the 

WDEQ storm water program, air quality review and permitting, and noise quality. The WDEQ 

also clarified the injection well classification system. The WDEQ noted that groundwater quality 

should be restored to class of use conditions per statute and State regulations. Under NRC 

regulations, as a license condition, the ISR operator would be required to return the aquifer to 

baseline conditions or to the maximum contaminant levels provided in Table 5C of 

10 CFR Part 40, Appendix A or to alternate concentration limits approved by NRC. The WDEQ 

requested early involvement in the NRC’s review of applications for proposed ISR projects in 

the State and emphasized coordination with the BLM when ISR projects are located on BLM 

lands. NRC staff met with the WDEQ in both June and September 2009 to coordinate review of 

this SEIS and to ensure that NRC’s assessment included issues of interest to the WDEQ. 

NRC staff also met with the WDEQ staff in Sheridan and Lander, Wyoming on January 14, 2009 

(NRC, 2009c). The WDEQ-Land Quality Division (LQD) explained the UIC Class III well 

application process, and noted that the WDEQ would require wellfield packages and 

groundwater restoration standards for future ISR operations. They expressed concern about 

potential excursions and unconfined aquifers. WDEQ-LQD staff also stated that groundwater 

parameters affected by ISR operations need to be restored to original background levels. They 

supported the use of solar evaporation ponds for wastewater disposal, but stated that ISR 

applicants, Native Americans, and the FWS have expressed concerns regarding the use of 

evaporation ponds. NRC has communicated with the WDEQ via teleconference and periodic 
Introduction 

 1-13 

meetings to discuss regulatory jurisdiction, the Wyoming permitting process, and the status of 

various issues. 

1.7.3.5 Coordination with the Wyoming Game and Fish Department 

The Wyoming Game and Fish Department (WGFD) is responsible for controlling, propagating, 

managing, protecting, and regulating all game and nongame fish and wildlife in Wyoming under 

Wyoming Statute (W.S.) 23-1-301-303 and 23-1-401. Regulatory authority given to WGFD 

allows for the establishment of hunting, fishing, and trapping seasons, as well as the 

enforcement of rules protecting nongame and state-listed species. 

The proposed license area includes habitat for a variety of big game animals, raptors, migratory 

birds, and small mammals that may be affected by the proposed project. The WGFD has an 

interest in potential impacts to migratory behavior patterns, long-term population sustainability, 

and the effects of local hunting on big game; impacts to nesting raptors; and the loss of nesting 

habitat for the greater sage-grouse. 

Based on a FWS recommendation, NRC staff sought information from the WGFD regarding 

sage grouse habitat within the proposed license area and appropriate mitigative measures to 

minimize potential impacts to the sage grouse. WGFD responded that there was no known 

sage grouse habitat on the proposed Moore Ranch site (WGFD, 2009). Discussions via 

conference calls have also been held to pinpoint specific project-related concerns regarding 

impacts to other fish and wildlife populations. Those concerns have been noted and addressed 

in project planning. 

The WGFD also provided input on several terrestrial and aquatic habitats which have been 

considered in the discussion of the affected environment (Chapter 3) and in the impacts 

analysis (Chapter 4) of this draft SEIS. NRC staff has also informally consulted with WGFD. 

1.7.3.6 Coordination with the Wyoming State Engineer’s Office 

NRC staff met with the WSEO on January 12, 2009 (NRC 2009c) to discuss well permitting. 

The WSEO was primarily concerned that proposed ISR facilities do not degrade the water 

quality, and that potential groundwater contamination be maintained onsite. They also 

expressed the need for applicants to ensure that there was close, professional supervision of 

well construction. 

1.7.3.7 Coordination with the Wyoming Governor’s Planning Office 

NRC staff met with the Wyoming Governor’s Planning Office on January 13, 2009 (NRC 2009c) 

and again on June 25, 2009. The Wyoming Governor’s Planning Office briefed the NRC on the 

BLM Resource Management Plan for the Buffalo region. They stated that they are a 

cooperating agency with the BLM and are involved with anything related to natural resources, 

particularly BLM resource management plans, and with the Wyoming SHPO and WDEQ. They 

informed NRC of the statewide conservation and management efforts for sage grouse and 

noted that the governor has created a management plan for the protection of sage grouse. 

They emphasized that potential ISR facilities need to be geographically flexible to protect the 

core sage grouse areas. 
Introduction 

 1-14 

1.7.3.8 Coordination with the Wyoming Community Development Authority 

NRC staff met with the Wyoming Community Development Authority on January 13, 2009 

(NRC, 2009c) to discuss housing availability for employees of future potential ISR facilities. 

They noted that employees would typically look for housing in the surrounding communities and 

this might include hotels, apartments, or single-family homes. 

1.7.3.9 Coordination with Localities 

The NRC staff interacted with several local county and city entities in the vicinity of the proposed 

license area which has included teleconferences and face-to-face meetings. NRC met with 

several local county and city entities on January 13 and 15, 2009 (NRC 2009c) to discuss 

site-specific issues for the proposed Moore Ranch Project. Meetings were held with the 

following local entities: Douglas and Converse County Office, City of Casper Planning Office, 

City of Gillette and Campbell County Office, Converse Area New Development Organization, 

and the Town of Wright. Meetings with the local county and city entities focused on local 

economies, housing availability, and community services. 

1.8 Structure of the SEIS 

As noted in Section 1.4.1 of this document, the GEIS (NRC, 2009a) evaluated the broad 

impacts of ISR projects in a four-state region where such projects are common, but did not 

reach site-specific decisions for new ISR projects. In this SEIS, the NRC staff evaluated the 

extent to which information and conclusions in the GEIS could be incorporated by reference. 

The NRC staff also determined whether any new and significant information existed that would 

change the expected environmental impact beyond that discussed in the GEIS. 

Chapter 2 of this SEIS describes the proposed action and reasonable alternatives considered 

for the proposed Moore Ranch Project, Chapter 3 describes the affected environment for the 

Moore Ranch site, and Chapter 4 evaluates the environmental impacts from implementing the 

proposed action and alternatives. Cumulative impacts are discussed in Chapter 5; Chapter 6 

describes the environmental measurement and monitoring programs proposed for the 

Moore Ranch Project. A cost-benefit analysis is provided in Chapter 7, and a summary of 

environmental consequences from the proposed action and No-Action alternative is 

summarized in Chapter 8. 

1.9 References 

10 CFR Part 2. Code of Federal Regulations, Title 10, Energy, Part 2, “Rules of Practice for 

Domestic Licensing Proceedings and Issuance of Orders.” 

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

Protection Against Radiation.” 

10 CFR Part 40 Appendix A. Code of Federal Regulations, Title 10, Energy, Part 40 

Appendix A, “Criteria Relating to the Operation of Uranium Mills and to the Disposition of 

Tailings or Wastes Produced by the Extraction or Concentration of Source Material from Ores 

Processed Primarily from their Source Material Content.” 
Introduction 

 1-15 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

40 CFR Part 1508. Code of Federal Regulations, Title 40, Protection of Environment, 

Part 1508, “Terminology and Index.” 

Atomic Energy Act of 1954, as amended. 42 USC 2011 et seq. 

BLM, 2008. “Final Environmental Impact Statement for the West Antelope II Coal Lease 

Application.” WYW163340. 2008. 

BLM, 2003. “Final Environmental Impact Statement and Proposed Amendment for the Powder 

River Basin Oil and Gas Project (WY–070–02–065),” January 2003. 

Energy Metals Corporation (EMC), 2007. U.S. “Application for USNRC Source Material 

License, Moore Ranch Uranium Project, Campbell County, Wyoming, Environmental Report.” 

Casper, Wyoming: Uranium 1 Americas Corporation. ADAMS Accession Nos. ML072851222, 

ML072851229, ML072851239, ML07285249, ML07285253, ML07285255. October 2, 2007. 

Endangered Species Act of 1973. 16 USC 1531−1544. 

Executive Order 13175. 2000. Consultation and Coordination with Indian Tribal Governments. 

65 FR 67249. (November 9).

FWS (U.S. Fish and Wildlife Service), 2008. Response to Request for Additional Information 

Regarding Endangered or Threatened Species and Critical Habitat for the Proposed License 

Application for Energy Metals Corporation’s Moore Ranch Uranium Recovery Project. 

ADAMS Accession No. ML081420589. May 7, 2008. 

National Environmental Policy Act of 1969 (NEPA). 42 USC 4321 et seq.

National Historic Preservation Act of 1966, as amended (NHPA). 16 USC 470aa et seq. 

NRC (U.S. Nuclear Regulatory Commission), 2009a. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC. May. 

NRC, 2009b. “Notice of Intent to Prepare a Supplemental Environmental Impact Statement for 

Uranium One Incorporated, Moore Ranch In-Situ Recovery Project.” Federal Register, Vol. 74, 

No. 161, pp. 42,332–42,333. August 21, 2009. 

NRC, 2009c. Memo to A. Kock, Branch Chief, from I. Yu, B. Shroff, and A. Bjornsen, Project 

Managers, Office of Federal and State Materials and Environmental Management Programs. 

Subject: Informal Meetings with Local, State, and Federal Agencies in Wyoming Regarding the 

Environmental Reviews Being Conducted on the Moore Ranch, Nichols Ranch, and Lost Creek 

In-Situ Leach Applications for Source Material Licenses (Docket Nos. 040-09073, 040-09067, 

040-09068, Respectively). ADAMS Accession No. ML090500544. March 2, 2009. 

NRC, 2009d. Letter to Richard Currit, Wyoming State Historic Preservation Office, Uranium 

One Inc. Moore Ranch In-Situ Uranium Recovery Project—Section 106 Consultation. 

ADAMS Accession No. ML092790445. October 22, 2009. 
Introduction 

 1-16 

NRC, 2009e. Request for Information Regarding Tribal Historic and Cultural Resources 

Potentially Affected by the Proposed License Application for Uranium One Inc.’s Moore Ranch 

Uranium Recovery Project in Campbell County, Wyoming. ADAMS Accession No. 

ML090440139. February 23, 2009. 

NRC, 2008a. “Notice of License Application Request of Energy Metals Corporation, WY and 

Opportunity to Request a Hearing.” Federal Register. Vol 73, No 17, pp. 4,642–4,646. 

January 25, 2008. 

NRC, 2008b. Letter to Brian Kelly, U.S. Fish and Wildlife Service. Request for Information 

Regarding Endangered or Threatened Species and Critical Habitat for the Proposed License 

Application for Energy Metals Corporation’s Moore Ranch Uranium Recovery Project. 

ADAMS Accession No. ML080950201. April 9, 2008. 

NRC, 2008c. Letter to Mary Hopkins, Wyoming State Historic Preservation Office, Initiation of 

Section 106 Process for Energy Metals Corporation’s Moore Ranch Uranium Recovery Project 

License Request. ADAMS Accession No. ML080950161. April 9, 2008. 

NRC, 2007. Acceptance Review of License Amendment Request for Energy Metals Corp. 

Moore Ranch Uranium Enrichment Project, 20 December 2007. 

NRC, 2003. NUREG–1748, “Environmental Review Guidance for Licensing Actions Associated 

With NMSS Programs—Final Report.” Washington, DC: August 2003. 

NRC, 1997. NUREG–1508, “Final Environmental Impact Statement to Construct and Operate 

the Crownpoint Uranium Solution Mine Project, Crownpoint, New Mexico,” ADAMS Accession 

No. ML082170248. February. 

NRC, 1980. NUREG–0706, “Final Generic Environmental Impact Statement on Uranium Milling 

Project M-25.” ADAMS Accession Nos. ML032751663, ML0732751667, ML032751669. 

September. 

NRC, 1982. NUREG–0889, “Draft Environmental Statement Related to the Operation of Sand 

Rock Mill Project.” Washington, DC. March 1982. 

Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA). 42 USC 7901 et seq. 

Uranium One, 2010a. Email from J.F. Winter, Manager Environmental and Regulatory Affairs, 

Uranium One to B. Shroff, Project Manager, NRC. Subject: Re: Waste Issues. May 12, 2010. 

ADAMS Package No. ML101330411. 

Wyoming Statute (W.S.) 23-1-301-303 and 23-1-401. 

WGFD (Wyoming Game and Fish Department), 2009. Letter to NRC staff Regarding Request 

for Information Regarding Sage-Grouse Habitats for the Proposed License Application for 

Uranium One Inc.. ADAMS Accession No. ML092920276. September. 

Wyoming SHPO (Wyoming State Historic Preservation Office), 2008. Letter to NRC staff 

Regarding Energy Metals Corporation, Initiation of Section 106 Process for the Moore Ranch 

Recovery License Request. ADAMS Accession No. ML081850356. June 5. 
2-1 

2 IN-SITU URANIUM RECOVERY AND ALTERNATIVES 

Chapter 2 of the Generic Environmental Impact Statement for In-Situ Leach Uranium Milling 

Facilities (NUREG–1910, GEIS) provided information on uranium recovery using the in-situ

leach (ISL) process (NRC, 2009). This chapter describes the application of those processes 

and the alternatives considered for the issuance of a U.S. Nuclear Regulatory Commission 

(NRC) license to Uranium One for the construction, operation, aquifer restoration, and 

decommissioning of the proposed Moore Ranch Project. This chapter describes the proposed 

action and alternatives, which include a consideration of the No-Action alternative, as required 

by the National Environmental Policy Act (NEPA). Under the No-Action alternative, Uranium 

One would not construct, operate, restore the aquifer, or decommission the proposed Moore 

Ranch Project. The No-Action alternative is included to provide a basis for comparing and 

evaluating the potential impact of the proposed action. 

Section 2.1 describes the alternatives considered for detailed analysis in this SEIS, including the 

proposed action. Section 2.2 describes those alternatives that were considered but eliminated 

from detailed analysis. Section 2.3 sets forth the final NRC staff recommendation. Section 2.4 

provides the references cited for this chapter. 

2.1 Alternatives Considered for Detailed Analysis 

The NRC staff used a variety of sources to determine the range of alternatives to consider for 

detailed analysis in this draft Supplemental Environmental Impact Statement (SEIS). Those 

sources included the license application, including the Environmental Report (ER) submitted 

by Energy Metals Corporation, a wholly-owned subsidiary of Uranium One; the scoping and 

draft comments on NUREG–1910, “Generic Environmental Impact Statement for In-Situ Leach 

Uranium Milling Facilities;” the information gathered during the NRC staff site visit in January 

2009; and interdisciplinary discussions held between the NRC staff and various stakeholders. 

2.1.1 The Proposed Action (Alternative 1) 

Under the proposed action, Uranium One is seeking an NRC source material license for the 

construction, operation, aquifer restoration, and decommissioning of the in-situ recovery (ISR) 

facility at the proposed Moore Ranch ISR Project as described in the license application. The 

applicant’s proposed disposal method is via a Class I injection well discussed in Section 2.1.1.1; 

however, alternative wastewater disposal options for the proposed action are discussed in 

Section 2.1.1.2. 

2.1.1.1 Disposal Via Class I Injection Well 

The proposed Moore Ranch ISR Project includes a central processing plant and two wellfields, 

which are described in the following sections. The general ISR process is described in 

Chapter 2 of the GEIS. The information contained in the following sections was obtained 

either from the application (EMC, 2007a, b) or from the GEIS (NRC, 2009) unless 

otherwise stated. 

2.1.1.1.1 Site Description 

The license area for the proposed Moore Ranch Uranium Project (Moore Ranch Project) is 

comprised of about 2,879 ha [7,110 ac] in the Powder River Basin in Campbell County, 
In-Situ Uranium Recovery and Alternatives 

 2-2 

Wyoming. The actual surface area that would be affected by the proposed ISL operation would 

be less than 61 ha [150 ac] and would consist of the main processing area, the wellfields (and 

their associated infrastructure including pipelines and trunklines), extraction support facilities 

such as warehouses and chemical storage areas, and access roads. The location of the 

proposed license area is comprised of the following, or portions of the following, townships: 

Township 42 North, Range 74 West, Sections 25, 26, 27, 28, 33, 34, 35, 36; Township 41 North, 

Range 75 West, Sections 1, 2, 3, 4, 9 and 10; and Township 42 North, Range 74 West, 

Sections 30 and 31. The proposed main processing area (referred to herein as the central 

plant) would be in the northeast quarter of Section 34 of Township 42 North, Range 74 West 

(Figure 2-1). The proposed project site is located between the towns of Wright and Edgerton, 

which are approximately 40 km [25 mi] northeast and 39 km [24 mi] southwest from the 

proposed Moore Ranch Project. No occupied housing units exist in the proposed license area; 

it is primarily used for grazing. Numerous wells used for coal bed methane (CBM) production 

also exist in the proposed license area, as described in Section 3.2.1.3 of this SEIS. Under the 

proposed action, NRC would issue a license for the construction, operation, aquifer restoration, 

and decommissioning of facilities for ISR uranium milling and processing at the Moore Ranch 

Project. During the construction phase of the action, buildings, access roads, wellfields, and 

pipelines would be constructed, as described in Section 2.1.1.1.2 of this SEIS. Most of the 

significant surface and subsurface disturbance would occur within the construction area for the 

central plant (Figure 2-1) and result in the disturbance of approximately a 2.4 ha [6-ac] area. 

Wellfield 1 would cover an area of approximately 9.3 ha [23 ac] and Wellfield 2 would be 

developed over an approximate 13.7 [34 ac] area (Figure 2-1); wellfields development would 

entail laying pipeline and trunkline; and about 2 km [1.25 mi] of new gravel road would 

be constructed. 

In addition, under the proposed action, between two and four Underground Injection Control 

(UIC) Class I injection wells would also be drilled for disposal of liquid effluent generated from 

production bleed, restoration [reverse osmosis (RO) brine], and miscellaneous plant 

wastewater. The formations into which the wells would be drilled are thousands of feet below 

the proposed ore production zone at the Moore Ranch Project, and they are described in more 

detail in Chapter 3. Uranium One submitted a permit application to WDEQ for a UIC Class I 

injection permit for deep well disposal at the proposed Moore Ranch Site. Disposal of liquid 

byproduct material would be reviewed under the NRC 20.2002 criteria. The Wyoming 

Department of Environmental Quality (WDEQ) is currently reviewing this permit application. 

The proposed operations phase at the Moore Ranch Project would last approximately 12 years; 

however; each wellfield would be operational for about 3.25 years (Griffin, 2009). The central 

plant would operate at a maximum flow rate of approximately 11,364 L/min [3,000 gal/min] and 

the plant is expected to produce 2 to 3 million pounds of uranium per year. After uranium 

recovery has ended, the groundwater in the wellfield would contain constituents that were 

mobilized by the extraction process (the lixiviant). The applicant would initiate aquifer 

restoration in each wellfield after the uranium recovery operations end (NRC, 2008). NRC 

licensees are required to return water quality parameters to the standards in 10 CFR Part 40, 

Appendix A, Criterion 5B(5). Details associated with aquifer restoration and the establishment 

of alternate concentration limits (ACL) are detailed in Appendix C. 

2.1.1.1.2 Construction Activities 

General construction activities associated with ISR operations include drilling wells, as 

described in Section 2.4 of the GEIS, and include activities such as clearing and grading 
In-Situ Uranium Recovery and Alternatives 

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Figure 2-1. Site Layout at the Proposed Moore Ranch Project
In-Situ Uranium Recovery and Alternatives 

 2-4 

associated with road construction and building foundations, building assembly, trenching, well 

drilling, and laying pipelines (NRC, 2009). The proposed facilities would consist of the central 

plant and associated infrastructure, such as the wellfields, pipelines, and roads. This section 

describes the physical plant, composed of the central plant including ion exchange (IX) column, 

wellfields, a construction and maintenance shop, warehouse, water treatment equipment, resin 

transfer facilities, lixiviant injection pumps, a small laboratory, and an employee break room. 

Figure 2-2 shows the different facilities that would comprise the proposed Moore Ranch Project. 

2.1.1.1.2.1 Central Plant 

The central plant at the proposed Moore Ranch Project would be constructed to provide 

chemical makeup of recovery solutions, recovery of uranium by IX, resin loading/unloading, 

elution and precipitation circuits, yellowcake drying capabilities, and groundwater restoration 

capabilities. The proposed Moore Ranch central plant facilities would be housed in a building 

with dimensions of approximately 107 × 30 m [350 × 100 ft] located within a 2.4 ha [6-ac] fenced 

area in the NE1/4, Section 34, T42N, and R75W. As stated previously, it would be designed 

and constructed to produce approximately 2–3 million pounds of uranium per year (EMC, 

2007a). Uranium One has indicated that in the future they may process uranium-loaded resin 

from other potential Uranium One satellite projects in the area and would need to expand the 

central plant to accommodate an annual throughput of 4 million pounds of uranium per year. 

The NRC source material license, if granted, would have to be amended to permit the higher 

capacity and potentially the processing of off-site uranium-loaded resins. Section 2.1.1.1.3 of 

this SEIS describes the processing that would occur in the central plant. Figure 2-3 illustrates 

the central plant layout. 

The applicant has stated that a concrete curb would be built around the central processing 

plant. It would be designed to contain the entire contents of the largest tank within the building 

in the event of a rupture. It would also contain the operating volumes of the two largest tanks, in 

the unlikely event that their simultaneous failures were to occur. Any spill of plant fluids would 

be contained by this curb, drained to the sump system, and pumped to the liquid byproduct 

material disposal system. 

The design of the deep well pump houses and wellheads would be such that any release of 

liquids would be contained within the building or in a bermed containment area surrounding the 

facilities. Liquid inside the building would be contained and managed appropriately. Wells 

would be equipped with a high-level shutoff switch on the injection tubing to prevent operation of 

the pumps at pressures greater than the limiting surface injection pressure. In addition, the 

wells would be equipped with a low-pressure shutdown switch on the surface injection line that 

would deactivate the injection pump in the event of a surface leak. Lines leading to the deep 

well would be instrumented for leak detection and automatic shutoff. 

Chemical storage facilities at the proposed Moore Ranch Project would include both hazardous 

and nonhazardous material storage areas. Bulk hazardous materials, which have the potential 

to impact radiological safety, would be stored outside and segregated from areas where 

licensed materials would be processed and stored. Figure 2-2 shows the proposed location of 

the supporting structures, including the warehouse/shop, an office, a chemical storage facility, 

and the location of stored carbon dioxide and oxygen tanks. The hazardous chemical storage 

would include bulk storage within the central plant, a chemical storage facility located about 

30.5 m [100 ft] west of the central plant, and separate storage for carbon dioxide and oxygen 

tanks. Bulk sulfuric acid storage has been identified in a prior analysis because of its reactivity 
In-Situ Uranium Recovery and Alternatives 

 2-5 

Figure 2-2. Wellfield Patterns and Infrastructure for the Proposed Moore Ranch Project (Uranium One, 2009a)
In-Situ Uranium Recovery and Alternatives 

 2-6 

Figure 2-3. Layout of the Central Plant
In-Situ Uranium Recovery and Alternatives 

 2-7 

and potential to impact chemical and radiological safety (Mackin, et al., 2001). A 22,727 L 

[6,000 gal] tank for sulfuric acid storage and a 22,727 L [6,000 gal] tank for storage of hydrogen 

peroxide have been proposed for use in the chemical storage area. These tanks would be 

located outside and separately from each other to minimize the potential for chemical reactions 

and vented into a water trap to limit the amount of vapors released into the atmosphere. The 

oxygen supplier would design and install an oxygen storage facility meet applicable industry 

standards. It would be delivered to the site by truck and stored on site under pressure in a 

cryogenic tank in liquid form (EMC, 2007a). Bulk storage of other nonhazardous chemicals, 

such as carbon dioxide, sodium carbonate, and sodium chloride would be inside the central 

plant to provide full containment of released materials. 

The surface facilities would be designed and built using standard construction techniques, in 

accordance with appropriate building codes. Construction vehicles could include bulldozers, 

drilling rigs, water trucks, forklifts, pump hoist trucks, coil tubing trucks, pickup trucks, portable 

air compressors, and other support vehicles. 

2.1.1.1.2.2 Access Roads 

The primary method of transportation to the proposed Moore Ranch Project would be via U.S. 

or State highways. Access to the site from the east would be from State Highway (SR) 59 or 

SR 50 to SR 387; from the west, access would be from Interstate Highway (I)-25 to SR 259 to 

SR 387. Construction materials would be delivered to the Moore Ranch site via SR 87 

(Figure 2-1). Access to the site from the highway is available through gravel and two-track 

roads established from CBM development and agricultural activity. A gravel access road 

located in T42N, R75W, Section 27 connects to the general location proposed for construction 

of the central plant and would require minor improvements and completion of a short spur road 

to accommodate truck and heavy equipment access during the construction and operation 

phases of the alternatives. The access road runs south through Section 34 and forks to the 

east through Section 35; it also continues south through the project boundary. This existing 

road would provide the primary access to all currently planned wellfields and facilities. 

Construction of the spur road would disturb approximately 1.2 ha [2 ac] of land. There are 

approximately 43 km [27 mi] of existing two track roads (neither paved nor graveled) used by 

CBM and the landowners. Secondary roads for wellfield header houses and facility access 

would fork off from the existing primary access road (Figure 2-2). 

2.1.1.1.2.3 Wellfields 

The underground infrastructure, consisting of wells and pipelines, would be established to inject, 

produce, and monitor groundwater and to transfer fluids between the wells and other 

production facilities. The proposed area to be developed in the wellfields is approximately 23 ha 

[57 ac]. The target mineralized zone for ISR at the proposed Moore Ranch Project is a 

sandstone formation located approximately 55 to 76 m [180 to 250 ft] below the surface 

(EMC, 2007b), referred to as the “70-Sand,” which averages approximately 24 m [80 ft] thick in 

the proposed extraction areas. The geology and hydrology of this formation are described in 

greater detail in Sections 3.4.1 and 3.5.2 of this SEIS. The overall width of the mineralized area 

varies from 30 to 300 m [100 to 1,000 ft]. 

Two wellfields have been proposed for extraction at the Moore Ranch Project, as shown in 

Figure 2-2. Wellfield 1 would encompass approximately 9.3 ha [23 ac] in T42N, R47W in 

portions of Sections 27 and 34 and is located northwest of Wellfield 2. Wellfield 2 would 

encompass approximately 13.8 ha [34 ac] located in T42N, R47W, Section 34. 
In-Situ Uranium Recovery and Alternatives 

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2.1.1.1.2.3.1 Injection and Production Wells 

Injection wells would be used to introduce lixiviant into the uranium-bearing ore body; production 

wells would be used to extract uranium-rich solutions. Wells would be drilled using the rotary 

drilling technique and constructed so they could be used for either injection or recovery. By 

drilling dual-purposed injection and production wells, the applicant has the flexibility to change 

the wellfield flow patterns, as needed, to improve uranium recovery and restore groundwater 

more efficiently. 

Prior to being placed into service, all wells would be developed to remove any drilling fluids, 

restore flow of formation water into the well, and establish stable formation water chemistry in 

the well (EMC, 2007a; Uranium One, 2008). In addition, the operator would use pressure 

packing field tests to ensure the mechanical integrity of all wells. These field tests involve 

sealing and over-pressuring the well to about 120 percent of maximum operating pressure. The 

well is then monitored for any pressure loss over time. Any well that does not maintain at least 

90 percent of the pressure for 10 minutes would be taken out of service and either repaired and 

retested or plugged and abandoned (EMC, 2007a; Uranium One, 2008). 

The injection/production pattern that would be used at the proposed Moore Ranch Project would 

be based on a conventional five-spot pattern, which would be modified to fit the characteristics 

of the ore body at the site. The standard production cell, referred to as a pattern, would contain 

four injection wells surrounding a centrally located production well (Uranium One, 2009a). 

The initial number of wells to be installed at Wellfield 1 has been estimated as 245 injection 

wells, 160 production wells, and 63 monitoring wells. The initial number of wells to be installed 

at Wellfield 2 has been estimated as 227 injection wells, 195 production wells, and 81 

monitoring wells. The proposed wellfield patterns are shown in Figure 2-2. The monitoring 

wells would be established in the overlying and underlying aquifers on 4-acre spacings to detect 

vertical excursions (Uranium One, 2009a). The wellfields would be brought into operation and 

restored based on a phased approach with separate schedules for each wellfield. Operations 

would begin in a portion of Wellfield 2, then move to the remaining portion of Wellfield 2 and part 

of Wellfield 1, then finish with Wellfield 1. As Wellfield 1 was operating, Wellfield 2 would 

begin restoration. 

Injection and production wells would be connected to manifolds in a wellfield header house 

building. Header houses would be used to distribute injection fluid to injection wells and collect 

production solution from recovery wells. Each header house would be connected to two trunk 

lines, one for receiving injection fluid from the central plant and one for conveying recovery 

fluids to the central plant (Uranium One, 2008). The header house includes manifolds, valves, 

flow meters, pressure meters, booster pumps, and oxygen to incorporate into the lixiviant, as 

appropriate. Each header house would service approximately 40 to 60 wells (injection and 

production). Approximately five header houses have been proposed for Wellfield 1 and eight 

header houses have been proposed for Wellfield 2 (Uranium One, 2009a). The manifolds 

deliver the recovery solutions to the pipelines that transmit solutions to and from the IX facilities. 

Flow meters and control valves would be installed in the individual well lines to monitor and 

control flow rates and pressures. In addition to the injection and production wells, Class I 

disposal wells have been proposed for this project, as described in Section 2.1.1.1.6. 

Within each wellfield, more water would be withdrawn than injected to create an overall 

hydraulic cone of depression. Under this pressure gradient, the natural groundwater movement 

would be from the surrounding area to the wellfield providing primary control of the production 
In-Situ Uranium Recovery and Alternatives 

 2-9 

solution movement. The difference between the amount of water produced and injected is the 

wellfield “bleed.” Fluids would be injected at a maximum rate of approximately 11,364 L/min 

[3,000 gal/ min]. The average bleed rate at the proposed Moore Ranch Project has been 

estimated at 1 percent of the maximum injection rate or 114 L/min [30 gal/min]; it would be 

adjusted, as necessary, to maintain the wellfield cone of depression. 

Designing, constructing, testing, and operating injection wells are regulated by the UIC program 

administered by the WDEQ who has primacy for the program, as delegated by the 

U.S. Environmental Protection Agency (EPA). The proposed program would require a UIC 

permit from the WDEQ to use Class III injection wells. Before ISR operations can begin, the 

portion of the aquifer designated for uranium recovery must be exempted as an underground 

source of drinking water, in accordance with the Safe Drinking Water Act (SDWA). 

2.1.1.1.2.3.2 Monitoring Wells 

Horizontal and vertical excursion monitoring wells would be installed at each wellfield, as 

dictated by geologic and hydrogeologic parameters. The horizontal monitoring wells screened 

in the uranium recovery zone would be located in a ring around the wellfields. Vertical 

monitoring wells would be placed in the first water-bearing sand underlying and overlaying the 

extraction zone. Typical locations of the monitoring well rings for proposed Wellfield 1 and 

Wellfield 2 are shown in Figure 2-2. The proposed well locations may be adjusted as the project 

progresses, to account for improved understanding of the geometry of the ore body and to 

adjust for surface topography variations. 

2.1.1.1.2.3.3 Well Construction and Testing 

At the proposed Moore Ranch Project, injection, production, and monitoring well casings would 

be constructed using plastic polyvinyl chloride (PVC) with a Standard Dimension Ratio of 17 and 

a nominal 5-in outside diameter. If a larger pump size was required, nominal casing diameters 

up to a 6-in outside diameter may be used. Casings in injection, production, and monitoring 

wells would use centralizers to ensure that the casing is centered in the drill hole. Each well 

would be cemented to strengthen the casing and plug the annulus of the hole to prevent vertical 

migration of solutions. 

Each well would be tested for mechanical integrity before operation. As described in 

Section 2.3.1.1 of the GEIS, the purpose of this test is to verify that the well casing does not fail, 

causing water loss during injection or recovery operations. In a mechanical integrity test (MIT), 

the bottom and top of the casing are plugged (sealed) with a sealing device. The well is 

pressurized, and pressure gauges monitor pressure changes inside the casing. If the repaired 

well cannot be repaired after several tries, the well would be plugged and abandoned. Results 

of these MITs are maintained onsite and are available for NRC and WDEQ personnel 

inspection. Results of these MITs are also reported to the WDEQ on a quarterly basis. 

During mud pit excavation associated with well construction, exploration drilling, and delineation 

drilling activities, topsoil would be separated from subsoil with a backhoe. The applicant has 

stated that when mud pit use was completed, subsoil would be replaced and topsoil applied. 

Mud pits typically remain open for less than 30 days. The WDEQ Land Quality Division (LQD) 

has guidelines on topsoil and subsoil management at uranium ISR facilities (WDEQ, 2000) that 

the applicant would follow in developing the wellfields at the proposed Moore Ranch Project. 
In-Situ Uranium Recovery and Alternatives 

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2.1.1.1.2.3.4 Pipelines 

The development of the wellfields at the proposed Moore Ranch Project would require the 

installation of underground piping, as described in this section. The locations of proposed trunk 

lines installed to support operations at the proposed Moore Ranch Project are shown in 

Figure 2-2. Individual well lines leading to the injection and production wells would travel to the 

local header house and trunk lines would lead in and out of the central plant through a pipe vault 

located on the northwest side of the central plant (Uranium One, 2009a). 

In general, piping from the central plant, to and within the wellfield would be constructed of PVC 

or high-density polyethylene pipe with butt-welded joints or the equivalent. All pipelines would 

be pressure tested before final operation (EMC, 2007a). Wellfield piping would have an 

operating pressure of 150–300 psi. The network of process pipelines and cables would be 

buried to avoid freezing temperatures and to minimize the possibility of an accident. Burial 

trenches could be excavated as deep as 1.8 m [6 ft] below the ground surface to avoid any 

potential freezing issue. Trenches containing pipeline would typically be backfilled with native 

soil and graded to surrounding ground topography. The only exposed pipes would be at the 

central plant, at the wellheads, and in the wellfield header houses. Trunkline flows and manifold 

pressures would be monitored for process control (EMC, 2007a). 

2.1.1.1.2.4 Other Structures and Systems 

Liquid effluent wastes generated during uranium recovery operations would be disposed of in 

two to four Class I deep disposal wells. The applicant would have to obtain UIC permits for the 

construction and use of these deep disposal wells from the WDEQ, as previously described. 

These deep disposal wells would be completed in approved formations, and their exact 

locations would depend on field placement. The applicant estimates a maximum flow rate of 

170 L/min [45 gal/m] during operations and an additional 380 L/min [100 gpm] from restoration 

of liquid effluent wastewater requiring deep well disposal. 

Domestic liquid waste generated at the central processing facility would be disposed of in an 

on-site wastewater treatment (i.e., septic) system permitted by the County under the 

WDEQ-LQD Class V UIC Regulations. 

2.1.1.1.2.5 Schedule 

The applicant estimated that the construction phase of the proposed Moore Ranch Project 

would be approximately 9 months and would include the building of access roads, the central 

plant, and initiating development of Wellfield 2. As noted before the wellfields would be 

developed in phases along with the supporting infrastructure (i.e., header houses and 

pipelines). Wellfield 2 would be constructed first, followed by construction of Wellfield 1 within 

approximately 9 months (Griffin, 2009). 

2.1.1.1.3 Operation Activities 

As described in Section 2.4 of the GEIS, the ISL uranium recovery process involves two primary 

operations: uranium mobilization that occurs in underground aquifers when lixiviant is injected 

into the ore body and recovering the solutions when they are uranium laden (NRC, 2009). The 

uranium-laden solutions (referred to as pregnant lixiviant) would be pumped from the production 

wells to the central plant IX system. 
In-Situ Uranium Recovery and Alternatives 

 2-11 

Uranium recovery at the proposed Moore Ranch Project involves the following two processes. 

First is uranium mobilization, where solid uranium in subsurface ore bodies is dissolved and 

extracted from the ground. The second process is uranium processing, where the dissolved 

uranium is removed from and ultimately dried and packaged as yellowcake. 

The next section describes the proposed operations at the Moore Ranch Project. Additionally, 

Section 2.4 of the GEIS provides general background information on the operations phase of an 

ISR facility (NRC, 2009). 

2.1.1.1.3.1 Uranium Mobilization 

Uranium mobilization at the proposed Moore Ranch Project would use the following steps: 

(1) injection of lixiviant, (2) oxidation and complexation of the uranium underground, 

(3) extraction or production of the pregnant lixiviant from the subsurface, and (4) excursion 

monitoring (EMC, 2007b). This process is described in the following sections. 

2.1.1.1.3.2 Lixiviant Chemistry 

The selected lixiviant must leach uranium from the host rock and keep it in solution during 

groundwater pumping from the host aquifer. The composition of the lixiviant is designed to 

reverse the natural geochemical conditions that led to the original uranium deposition. At the 

proposed Moore Ranch Project, the lixiviant for uranium recovery operations would be alkaline 

and would consist of varying concentrations and combinations of sodium carbonate/bicarbonate 

and oxygen added to the native groundwater to promote dissolution of uranium as a uranyl 

carbonate complex. The amenability of uranium deposits to ISR at the proposed Moore Ranch 

site has been demonstrated by nearby ISR operations in similar ore bodies in the Powder River 

Basin, including the Smith Ranch/Highland and the Christensen Ranch/Irigaray projects (EMC, 

2007a). The lixiviant would be made up on a batch basis in the central plant and added 

continuously to the injection stream. Table 2.4-1 of the GEIS summarizes typical lixiviant 

chemistry (NRC, 2009). As noted in Section 2.4.1.1 of the GEIS, the principal geochemical 

reactions caused by the lixiviant are the oxidation and subsequent dissolution of uranium and 

other metals from the ore body and its subsequent extraction (NRC, 2009). 

2.1.1.1.3.3 Lixiviant Injection and Production 

At the proposed Moore Ranch Project, the lixiviant would be pumped down a total of 

approximately 472 injection wells in the two wellfields to the ore body, where it would 

oxidize and dissolve uranium from the formation. Solutions for milling would be injected at a 

maximum rate of approximately 11,364 L/min [3,000 gal/min] (EMC, 2007b). A water balance 

for the proposed project is shown in Figure 2-4. The liquid effluent generated at the central 

plant would be primarily production bleed containing liquid byproduct material that has been 

estimated at an average of 1 percent of the production flow, which would be 114 L/min 

[30 gal/min] at the maximum flow rate of 11,364 L/min [3,000 gal/min]. 

Downhole injection pressures would be maintained below the formation fracture pressure. A 

formation fracture pressure gradient of 1.0 psi for every 0.3 m [1 ft] of depth to the top of the 

 
In-Situ Uranium Recovery and Alternatives 

 2-12 

Figure 2-4. Water Balance for the Proposed Moore Ranch Project
In-Situ Uranium Recovery and Alternatives 

 2-13 

screened interval was used to determine the injection pressures at the proposed Moore Ranch 

Project. The depth to the top of the anticipated screened interval ranges from approximately 

49 m [160 ft] below land surface in Wellfield 2 to approximately 91.5 m [300 ft] in Wellfield 1. 

Therefore, injection pressures would range from 100 psi at the header houses located in 

shallower ore areas to no greater than 150 psi at header houses located in deeper ore areas 

(EMC, 2007b). 

The uranium-bearing solution would migrate through the pore spaces in the sandstone and be 

recovered by a total of approximately 355 production wells, inclusive of both Wellfields 1 and 2. 

This uranium-rich, pregnant lixiviant would be pumped to the central plant IX facility, where it 

would be extracted through the processes described in Section 2.1.1.1.3.5 of this SEIS. Once 

the uranium has been extracted from the lixiviant (referred to as barren lixiviant), it would be 

recharged with carbonate/bicarbonate and oxidant and the solution reinjected into the ore body 

to continue extraction. 

2.1.1.1.3.4 Excursion Monitoring 

ISR operations can potentially affect the groundwater quality near a site when lixiviant moves 

from the production zone away from the injection wells, resulting in either a vertical or lateral 

excursion. Excursion monitoring is performed to monitor water flow to avoid a potential 

excursion. Uranium One proposes to install monitoring wells around the wellfields to monitor for 

horizontal excursions. Monitoring wells would also be installed in the overlying and underlying 

aquifers at a density of one well per every 4 acres of pattern area to monitor for vertical 

excursions (Uranium One, 2008). The final location of these wells would be determined when 

the final wellfield design and the wellfield package are submitted to WDEQ-LQD. During the 

safety review, the staff identified issues that could only be resolved after wellfield testing is 

complete. These issues will require that NRC staff review the hydrologic package for Wellfield 1 

before ISR operations begin and for Wellfield 2, the NRC staff will review and approve the 

hydrologic package. The proposed monitoring program is described in more detail in Chapter 6 

of this SEIS. 

An excursion occurs when two or more excursion indicators in a monitoring well exceed their 

upper control limits (UCL) (NRC, 2003a). If an excursion is confirmed, the licensee notifies the 

NRC and takes several steps to confirm the excursion through additional sampling (NRC, 

2003a). As described in NRC guidance (NRC, 2003a, Section 5.7.8.3), licensees typically 

retrieve horizontal excursions back into the production zone by adjusting the flow rates of the 

nearby injection and production wells to increase process bleed in the area of the excursion. 

Vertical excursions are more difficult to retrieve. If an excursion is suspected in groundwater 

monitoring wells, then the applicant is required to notify WDEQ and NRC within 24 hours, and 

the suspect wells would be put on excursion monitoring, meaning they would be monitored 

every seven days until the excursion indicators returned to nonexcursion levels. If an excursion 

cannot be recovered, the licensee may be required to stop lixiviant injection (NRC, 2003a). 

NRC license conditions require that licensees conduct biweekly sampling to detect excursions. 

2.1.1.1.3.5 Uranium Processing 

The uranium processing at the proposed Moore Ranch Project would use the following steps: 

(1) loading of uranium complexes onto IX resin; (2) elution (recovery) of uranium complexes 

from the resin; and (3) precipitation, drying and packaging of uranium (EMC, 2007b). This 

process is described in the following text. 
In-Situ Uranium Recovery and Alternatives 

 2-14 

2.1.1.1.3.5.1 Ion Exchange 

The uranium-bearing solution, or pregnant lixiviant, pumped from the wellfield would be piped to 

the IX columns in the central plant to extract the uranium. The IX system would consist of eight 

fixed-bed IX vessels to be operated as three sets of two vessels in series with two vessels 

available for restoration. The IX system would be designed to process recovered solution at a 

rate of 11,364 L/min [3,000 gal/min] with each vessel sized for 14.2 m3

 [500 ft3] of resin 

operated in a pressurized down flow mode. As the solution passed through the IX resin in the 

vessels, the uranyldicarbonate and uranyltricarbonate would, preferentially, be removed from 

the solution. The barren solutions leaving the IX units would be expected to contain less than 

2 mg/l of uranium (EMC, 2007b). 

After the barren lixiviant has left the IX system, carbon dioxide and/or carbonate/bicarbonate 

would be added, as necessary, to return the carbonate/bicarbonate concentration to the desired 

operating level. The solution would then be pumped back to the wellfield, with the oxidant 

(O2 gas) added either as it left the central plant, or just before the solution was to be reinjected 

into the production zone. 

2.1.1.1.3.5.2 Elution 

A three-stage elution circuit has been proposed for use at the Moore Ranch Project, as 

illustrated in Figure 2-3. In a three-stage elution, the rich eluate would first pass through the 

elution vessels, which contain the IX resin. The rich eluate would strip approximately 84 percent 

of the uranyl carbonate ions from the resin and become pregnant eluate containing 

approximately 15,500 mg/l uranium. Then lean eluate would be contacted with resins and 

remove approximately 68 percent of the remaining uranyl carbonate to become rich eluate. 

Finally, fresh eluate would be passed through the resins in the elution vessels and remove 

approximately 35 percent of the remaining uranyl carbonate from the resins, resulting in lean 

eluate. At this stage, the resins would have a residual uranyl carbonate concentration of 

approximately 3.33 percent. The resins would be washed with freshwater or a sodium 

bicarbonate rinse, or both, and either transferred back to the appropriate vessel or to a resin 

transfer trailer, if the resins were to be shipped to an offsite extraction area. Each batch of 

eluate would be transferred from the respective eluate storage tank through the elution vessel at 

a rate of approximately 795.4 L/min [210 gal/min] (EMC, 2007a). 

Approximately 125,000 L [33,000 gal] of eluate would contact 14 m3

 [500 ft3] of resin. The first 

elution stage would generate approximately 1,500 ft3

 [11,220 gal] of pregnant eluate containing 

10 to 20 g/L uranium. About 1,500 ft3

 [11,220 gal] of fresh eluate would be required per elution 

batch. The fresh eluate would be prepared by mixing the proper quantities of a saturated 

sodium chloride (salt) solution and saturated sodium carbonate (soda ash) solution and water to 

form a solution that would be about 9 percent NaCl and 2 percent Na2CO3. The saturated salt 

solution would be generated in a brine generator, and the saturated soda ash solution would be 

prepared by passing warm water [>105 °F] through a bed of soda ash. The eluate would be 

passed through a bank of 10 micron bag filters to remove entrained particulates prior to 

contacting the resin beds in the elution vessels (EMC, 2007a). 

2.1.1.1.3.5.3 Precipitation, Drying, and Packaging 

Approximately 795 L [210 gal] of sulfuric acid would be added to the pregnant eluate to break 

the uranyl carbonate complex, thus liberating carbon dioxide and freeing uranyl ions to form a 

uranyl sulfate ion complex. The acidic, uranium-rich fluid would then be pumped to the first of 
In-Situ Uranium Recovery and Alternatives 

 2-15 

five agitated tanks arranged in series. The fluid would flow by gravity from one tank to the next. 

Hydrogen peroxide would be added to the first two tanks to form an insoluble uranyl peroxide 

compound. Sodium hydroxide would then be added to the solution in the third tank to raise the 

pH of the precipitate solution to near neutral for optimum crystal growth and settling. The 

uranium precipitate solution would then be pumped from the final precipitation tank to a 10.3 m 

[38-ft] diameter gravity thickener. 

The yellowcake would be dried at approximately 120 °C [250 °F]. The drying and packaging 

area would include the vacuum dryer system and the packaging area immediately below the 

vacuum dryer. When the yellowcake was dry, it would flow through an enclosed chute and be 

deposited directly into a sealed hood on the drum for packaging. The off gases generated 

during the drying cycle would be filtered through a baghouse. Two rotary vacuum dryers would 

be located in a separate building containing the dryers and associated equipment but attached 

to the central plant. 

The dried yellowcake would be removed from the rotary vacuum dryer by passing it through a 

rotary valve into 208-L [55-gal] steel drums. The dryer vacuum pump would be connected to 

the loading hood to minimize particulate emissions during drum loading. The dried yellowcake 

product would be stored in the steel drums in a restricted storage area, pending shipment by 

truck to other licensed facilities for further processing. An enclosed warehouse, adjacent to the 

yellowcake drying area, would be used to store yellowcake. The drummed yellowcake would be 

shipped by exclusive-use transport to a licensed conversion facility in Metropolis, Illinois. 

2.1.1.1.3.6 Management of Production Bleed and Other Liquid Effluents 

Uranium mobilization at the proposed Moore Ranch Project would produce excess water that 

must be properly managed. The production wells extract slightly more water than is reinjected 

into the host aquifer, which creates a net inward flow of groundwater into the wellfield. As 

mentioned earlier, during normal operations, production rates would be controlled by 

withdrawing a small portion of the barren solution from the IX circuit, which is then disposed of 

via the deep disposal wells. The estimated maximum flow rate of production bleed is 114 L/min 

[30 gal/min]. 

Other liquid effluents would be produced as part of the proposed Moore Ranch ISR Project. 

These include liquids from process drains, elution circuit bleed, and wash-down water. The 

maximum estimated flow rate of these other liquid effluents is 38 L/min [10 gal/min]. These 

waste streams would be handled in the same manner as the production bleed. 

2.1.1.1.3.7 Schedule 

The central plant at the proposed Moore Ranch Project would operate for approximately 

12 years; however, the individual wellfields would operate for approximately 3.25 years (Griffin, 

2009), although they would operate on separate schedules as described above in 

Section 2.1.1.1.2.3.1. 

2.1.1.1.4 Aquifer Restoration Activities 

Aquifer restoration within the wellfield ensures that the water quality and groundwater use in 

surrounding aquifers would not be adversely affected by the uranium recovery operation, as 

discussed in Section 2.5 of the GEIS (NRC, 2009). After uranium is recovered, the groundwater 

will contain constituents that were mobilized by the lixiviant. The process whereby groundwater 
In-Situ Uranium Recovery and Alternatives 

 2-16 

constituents are selected for monitoring throughout the life of the project is discussed in 

Section 6.3.1.2 of this SEIS. In compliance with 10 CFR Part, 40, Appendix A, Criterion 5B(5), 

groundwater quality in the exempted ore-bearing aquifer is required to be restored to 

(i) Commission-approved baseline; (ii) maximum concentration level of constituents (MCLs) 

listed in Table 5C, if the constituent is listed in Table 5C and if the baseline level of the 

constituent is below the value listed; or (iii) ACLs established by the Commission, if the baseline 

level of the constituents and the values listed in Table 5C are not reasonably achievable. The 

development of ACLs is described in Appendix C of this SEIS. These standards are 

implemented during aquifer restoration to ensure public health and safety. The applicant is 

required to provide financial sureties to cover planned and delayed restoration costs in 

compliance with 10 CFR Part 40, Appendix A, Criterion 9. NRC reviews the financial 

sureties annually. 

Under the Federal UIC program, the exempted production aquifer will no longer be protected 

under the SDWA as an Underground Source of Drinking Water (USDW). In compliance with 

40 CFR 146.4, the exempted aquifer does not currently serve as a source of drinking water and 

cannot now and will not in the future serve as a source of drinking water. Hence, groundwater 

in exempted aquifers cannot be considered as a source of drinking water after restoration. 

The applicant needs to establish baseline water quality prior to the submission of a license 

application. The excursion parameters and UCLs are determined based on the baseline water 

quality sampled from monitoring wells placed in the ore-bearing, underlying, and overlying 

aquifers, when applicable. Therefore, the UCLs should be established prior to ISR operations. 

UCLs are used for control and management of excursions, if they occur, during ISR operations 

and restoration. 

Aquifer restoration in each wellfield would begin as the uranium recovery operations end. By 

doing this, the period of groundwater contamination within the exempted aquifer is shortened. 

The preextraction class of use would be determined by the baseline water quality sampling 

program that would be performed for each wellfield compared to the use categories defined by 

the WDEQ, Water Quality Division. Restoration would be demonstrated to meet the 

requirements of the WDEQ, LQD Rules and Regulations (EMC, 2007b) and NRC requirements. 

Evaluation of the degree of groundwater restoration within the production zone would be based 

on the average baseline quality over the production zone. The applicant would collect baseline 

water quality data for each wellfield from the wells completed in the planned production zone. 

Restoration would be evaluated parameter-by-parameter, based on “Restoration Target Values” 

that would be established for a list of baseline water quality parameters. 

Prior to initiation of operations and during the aquifer restoration phase, the applicant would 

have established a groundwater monitoring program as described in Chapter 3 to assess the 

impacts from operations on local groundwater and its subsequent restoration. 

2.1.1.1.4.1 Groundwater Restoration Methods 

The groundwater restoration program at ISR sites typically consists of two stages: restoration 

stage and stability monitoring. The restoration stage typically consists of three phases 

groundwater transfer, groundwater sweep; and groundwater treatment, as described in 

Sections 2.5.1, 2.5.2, and 2.5.3 of the GEIS (NRC, 2009). These phases are designed to 

optimize restoration equipment used in treating groundwater and to minimize the volume of 

groundwater consumed during the restoration stage. The following sections describe the 

groundwater restoration methods proposed for use at the proposed Moore Ranch Project. 
In-Situ Uranium Recovery and Alternatives 

 2-17 

Based on aquifer testing at Moore Ranch, Uranium One determined that efficient groundwater 

movement during the operations and restoration phases could be accomplished by “pulsing” the 

extraction wells by cycling them on and off. The pulsing would be achieved by either switching 

groups of extraction wells on and off or by alternating between injection and extraction cycles 

within individual well patterns. By doing this, those portions of the aquifer that may have been 

temporarily dewatered by an extraction well could be effectively resaturated (EMC, 2007a). 

The sequence of groundwater restoration activities would be determined based on operating 

experience and wastewater system capacity. The specific mix of groundwater transfer and 

groundwater treatment would be determined as part of the groundwater restoration plan for 

each individual wellfield. A reductant, such as sulfide or sulfite, could also be added to the 

injection stream at any time during the restoration stage to lower the oxidation potential of the 

extraction zone. 

The applicant at the proposed Moore Ranch Project would monitor the quality of groundwater in 

selected wells, as needed during restoration, to determine the efficiency of the operations and to 

decide if additional or alternate techniques would be necessary, as described in Section 4.5.2 of 

this SEIS. The evaluation of groundwater restoration within the production zone would be 

based on the average baseline quality over the production zone (EMC, 2007a). Online 

production wells used in restoration would be sampled for uranium concentration and for 

conductivity amongst other constituents to determine the progress of restoration on a patternby-pattern basis. 

2.1.1.1.4.1.1 Groundwater Transfer 

During the groundwater transfer phase of groundwater restoration at the proposed Moore 

Ranch Project, water could be transferred between a wellfield commencing restoration and 

another commencing extraction operations. Groundwater transfer could also occur within the 

same wellfield, if one area of the wellfield is in a more advanced state of restoration 

than another. 

Baseline quality water from the wellfield commencing extraction would be pumped and injected 

into the wellfield in restoration. The higher total dissolved solids (TDS) water from the wellfield 

in restoration would be recovered and injected into the wellfield commencing extraction. The 

direct transfer of water would lower the TDS in the wellfield being restored by displacing 

affected groundwater with baseline quality water. 

The goal of the groundwater transfer phase is to blend the water in the two wellfields until they 

become similar in conductivity. The water recovered from the restoration wellfield could be 

passed through ion-exchange columns or filtered during this phase if there were a significant 

amount of suspended solids that could block injection well screens. 

For groundwater transfer between wellfields, a newly constructed wellfield must be ready to 

commence extraction. Therefore, this phase could be initiated any time during the restoration 

process. If a wellfield is not available to accept transferred water, groundwater sweep or some 

other activity could be the first phase of restoration. The groundwater transfer technique is 

advantageous to reduce the amount of disposed water. 
In-Situ Uranium Recovery and Alternatives 

 2-18 

2.1.1.1.4.1.2 Groundwater Treatment 

During the groundwater treatment phase, water is pumped from the extraction zone to the 

surface for treatment. IX, RO, and electro dialysis reversal treatment equipment have been 

proposed for use during the groundwater treatment phase of the proposed Moore 

Ranch Project. 

Groundwater recovered from the restoration field is passed through an IX unit prior to RO and 

electro dialysis reversal units. RO electro dialysis reversal units are used to separate clean 

water (permeate) from brine. Following treatment in the ion exchange unit, groundwater would 

either be reinjected into the wellfield or disposed. Prior to or following IX treatment, the 

groundwater could be passed through a decarbonation unit to remove residual carbon dioxide 

remaining in groundwater after uranium recovery. 

All or some portion of the restoration recovery water could be sent to the RO unit to reduce the 

total dissolved solids in the affected groundwater, reduce the quantity of water that must be 

removed from the aquifer to meet restoration limits, concentrate the dissolved constituents into 

a smaller brine volume to facilitate waste disposal, and enhance the exchange of ions from the 

formation due to the large difference in ion concentration. The RO unit passes a high 

percentage of the water through the membranes, leaving 60 to 90 percent of the dissolved salts 

in the brine water or concentrate. The clean water, called permeate, is reinjected into the 

wellfield or stored for use in the extraction process. The permeate could also be decarbonated 

prior to reinjection into the wellfield. The brine water contains the majority of dissolved salts in 

the affected groundwater and would be disposed of via deep well injection. Make-up water, 

which could come from water produced from a wellfield that is in a more advanced state of 

restoration, water being exchanged with a new extraction unit, the purge of an operating 

wellfield or a combination of these sources, could be added prior to the RO or wellfield injection 

stream to control the amount of bleed in the restoration area. 

At any time during the process, a chemical reductant, which would be used to create reducing 

conditions in the extraction zone, could be metered into the restoration wellfield injection stream. 

The concentration of reductant injected into the formation would be determined by how the 

extraction zone groundwater reacts with the reductant. The goal of reductant addition would be 

to decrease the concentrations of certain trace elements. Reductants are beneficial because 

several of the metals, which are solubilized during the leaching process, are known to form 

stable, insoluble compounds, primarily as sulfides. Dissolved metal compounds that are 

precipitated under reducing conditions include those of arsenic, molybdenum, selenium, 

uranium, and vanadium. 

The groundwater restoration phase at the proposed Moore Ranch Project has been estimated 

to consume about 65.5 million and 94.2 million gallons of water at Wellfields 1 and 2. The 

numerical modeling to support this calculation is provided in the Uranium One technical report 

(EMC, 2007a). Upon completion of restoration activities, a minimum 12-month groundwater 

stability monitoring period would be implemented to demonstrate that the restoration goal has 

been adequately maintained, in accordance with WDEQ guidelines. Chapter 6 of this SEIS 

describes the restoration stability monitoring that would be conducted. 
In-Situ Uranium Recovery and Alternatives 

 2-19 

2.1.1.1.4.2 Schedule 

The aquifer restoration phase of Wellfields 1 and 2 is estimated to last approximately 3.5 and 

5.25 years (Griffin, 2009). The stabilization monitoring following completion of aquifer 

restoration is estimated to last approximately one year. 

2.1.1.1.5 Decontamination, Decommissioning, and Reclamation Activities 

The decommissioning of an ISR facility would be based on an NRC-approved decommissioning 

plan. Section 2.6 of the GEIS describes the general process for decontamination, 

decommissioning, and reclamation of an ISL facility (NRC, 2009). The applicant would submit a 

decommissioning plan to the NRC for review and approval at least 12 months before the 

planned commencement of final decommissioning. When approved, this plan would amend the 

license, initiate the decommissioning process, and provide NRC the detailed information 

required for NRC to evaluate the proposed decommissioning plan. 

Prior to release of the property for unrestricted use, the applicant would conduct a 

comprehensive radiation survey to establish that any contamination is within the 

10 CFR Part 40, Appendix A limits. The applicant would return all lands to their previous land 

use, unless an alternative was justified and approved by both the state and the landowner. For 

example, a rancher could decide to retain access roads. The goal of the decommissioning and 

reclamation process would be to return disturbed lands to production capacity of equal or better 

than existed prior to uranium recovery. The following sections describe the proposed 

decommissioning and surface reclamation plans for the proposed Moore Ranch Project. As 

part of this process, wells would be plugged and abandoned, disturbed lands would be 

reclaimed, contaminated equipment and materials would be removed, appropriate cleanup 

criteria for structures would be determined, items to be released for unrestricted use would be 

decontaminated to meet NRC requirements, and surveys would be performed to determine if 

there was residual contamination in soils and structures. The following sections described the 

general decommissioning activities that would occur at the proposed Moore Ranch Project. 

2.1.1.1.5.1 Wellfield Decommissioning 

Wellfield plugging and surface reclamation would be initiated when the regulatory agencies 

concur that the groundwater in a wellfield has been adequately restored and that the water 

quality is stable. All production, injection, and monitoring wells and drill holes would be 

abandoned and plugged, in accordance with WS–35–11–404 and Chapter VIII, Section 8 of the 

WDEQ-LQD Rules and Regulations, to prevent adverse impacts to groundwater quality or 

quantity. This process would involve removing pumps and tubing from the wells, plugging them 

with either cement or clay, cutting off the casing three feet below the ground surface, placing a 

steel plate on top of the casing that identifies the well and the date of plugging, and emplacing a 

cement plug at the top of the casing. 

Reclamation in the wellfield production unit would involve removing surface and subsurface 

equipment. These would consist primarily of: injection and production feed lines; header 

houses; electrical and control distribution systems; well boxes and wellhead equipment; buried 

wellfield piping; recontouring, if necessary; and conducting a final background gamma survey 

over the wellfield to identify contaminated earthen materials requiring removal, final revegetation 

of the wellfield areas according to a revegetation plan; and surveying all piping, equipment, 

buildings, and wellhead machinery for contamination prior to release, in accordance with NRC 

decommissioning guidelines. 
In-Situ Uranium Recovery and Alternatives 

 2-20 

The applicant estimated that a significant portion of the equipment would meet radiological 

release limits, which would allow for disposal at an unrestricted landfill, as discussed in 

Section 2.1.1.1.6.3. Other materials would be decontaminated until they could be released. 

Equipment and materials that could not be decontaminated to meet release limits would be 

disposed of as byproduct material at a licensed facility. 

2.1.1.1.5.2 Topsoil Handling and Replacement 

Topsoil at Moore Ranch would be salvaged from building sites, permanent storage areas, main 

access roads, graveled wellfield access roads, and chemical storage sites, in accordance with 

WDEQ-LQD requirements. Conventional rubber-tired, scraper-type earth moving equipment is 

typically used to accomplish topsoil salvage operations. The exact location of topsoil salvage 

operations would be determined by wellfield pattern emplacement and designated access 

roads, which would be designated during final construction activities. 

The topsoil thickness within the licensed area varies from nonexistent to several feet. However, 

typical topsoil stripping depths are expected to range from 0.7 to 1.5 cm [3 to 6 in]. Salvaged 

topsoil would be stored in designated stockpiles, generally located on the leeward side of hills, 

to minimize wind erosion and avoid drainage channels. The perimeter of large stockpiles would 

be bermed to control sediment runoff. 

Surface soils would be cleaned up in accordance with the requirements in 10 CFR Part 40, 

Appendix A, considering ALARA goals for cleanup of soils. The methodologies for conducting 

postreclamation and decommissioning radiological surveys are discussed in Section 6.4 of the 

applicant technical report (EMC, 2007a). The cleanup goals for radium-226 and natural 

uranium are summarized in Table 2-1. 

2.1.1.1.5.3 Final Contouring and Revegetation 

The land surface would be recontoured, as necessary, to restore it to a surface configuration 

that would blend in with the natural terrain and would be consistent with the post-extraction 

land use. No major changes in the topography are anticipated for the proposed 

Moore Ranch Project. 

Revegetation practices would be conducted in accordance with WDEQ-LQD regulations and the 

mine permit. During extraction operations the topsoil stockpiles and the disturbed wellfield 

areas would be seeded, as much as practicable, to establish a vegetative cover to minimize 

wind and water erosion. The WDEQ-LQD would approve the selected seed mix. 

Table 2-1. Soil Cleanup Criteria and Goals* 

Radium-226 (pCi/gm) Natural Uranium (pCi/gm)

Layer Depth Limit Goal Limit Goal

Surface (0–15 cm) 5 5 225 150

Subsurface (15 cm) 15 15 225 225

*Consistent with NRC requirements in 10 CFR Part 40, Appendix A, Criterion 6(6), the applicant proposes to apply a 

unity rule when more than one radionuclide is present so that the sum of the ratios of each radionuclide 

concentration to its limit does not exceed one. 
In-Situ Uranium Recovery and Alternatives 

 2-21 

The success of permanent revegetation in meeting land use and reclamation standards would 

be assessed prior to application for bond release by utilizing the Extended Reference Area 

method, as detailed in WDEQ-LQD Guideline No. 2–Vegetation (WDEQ, 1986). This method 

compares, on a statistical basis, the reclaimed area to the adjacent, undisturbed areas of the 

same vegetation type. The Extended Reference Area would be selected in consultation with the 

WQED-LQD, to ensure the representativeness of the undisturbed chosen area to the reclaimed 

area being assessed. 

2.1.1.1.5.4 Procedures for Removing and Disposing of Structures and Equipment 

Upon completion of the uranium recovery process, buildings, equipment, pipelines and 

associated materials would be removed as discussed in the following section. 

2.1.1.1.5.4.1 Preliminary Radiological Surveys and Contamination Control 

Prior to decommissioning the central plant and associated structures, a preliminary radiological 

survey would be conducted to characterize the levels of contamination on structures and 

equipment, to identify any potential hazards, and to support the development of procedures for 

dealing with such hazards prior to commencement of decommissioning activities. Based on the 

results of preliminary radiological surveys, gross decontamination techniques would be 

employed to remove loose contamination before decommissioning activities were initiated. This 

gross decontamination would generally consist of washing all accessible surfaces with 

high-pressure water. In areas where contamination is not readily removed by high-pressure 

water, a decontamination solution (e.g., dilute acid) may be used. 

2.1.1.1.5.4.2 Removal of Process Buildings and Equipment 

The majority of equipment in the process building would be reusable, as well as the building 

itself. Alternatives for the disposition of buildings and equipment would also be evaluated, 

including removal to a new location for future use, removal to another licensed facility for either 

permanent use or disposal, or decontamination to meet unrestricted release criteria. All 

potentially contaminated equipment and materials at the central plant such as tanks, filters, 

pumps, and piping, would be inventoried, listed, and designated by the applicant as discussed 

previously. For the proposed Moore Ranch Project, the process building would be 

decontaminated, dismantled, and released for use at another location. Materials that could not 

be decontaminated to meet release criteria would be sent to a permanent licensed disposal 

facility. Cement foundation pads and footings would be broken up and trucked to a solid waste 

disposal site or to a licensed disposal facility, if the residual materials could not meet 

release criteria. 

2.1.1.1.5.4.3 Building Materials, Equipment, and Piping Released for Unrestricted Use 

Salvageable building materials, equipment, pipe, and structures would be surveyed for alpha 

contamination, in accordance with NRC guidance and alpha contamination limits. Surface 

decontamination would be conducted, in accordance with ALARA, to reduce surface 

contamination levels as far below the limit as practical. Decontamination would focus, in 

particular, on inaccessible portions of equipment and structures in which radiological materials 

could accumulate, such as piping, traps, junctions, and access points. Nonsalvageable, 

contaminated equipment, materials, and dismantled structural sections would be sent to a 
In-Situ Uranium Recovery and Alternatives 

 2-22 

licensed facility for disposal. In most cases, the byproduct material would be shipped as Low 

Specific Activity (LSA-I) material, UN2912, pursuant to 49 CFR 173.427. 

2.1.1.1.5.5 Schedule 

Wellfield and plant decommissioning is estimated to take approximately one year (Griffin, 2009). 

2.1.1.1.6 Effluents and Waste Management 

The operation of an ISR facility generates 

various types of effluents and waste. This 

section describes the types and volumes of 

effluents or wastes to be generated by 

operation of the proposed Moore Ranch 

Project. Also, the textbox below defines the 

different liquid and solid wastes that would be 

generated. The proposed disposal methods 

and locations for liquid and solid wastes are 

described in Section 3.13 and the impacts from 

generating and disposing these wastes are 

described in Section 4.14. Air quality and air 

emissions impacts are discussed in Section 3.7 

and 4.7. 

2.1.1.1.6.1 Gaseous and Airborne 

Particulate Emissions 

During the construction, operations, aquifer 

restoration, and decommissioning phases of the 

proposed Moore Ranch Project, airborne 

emissions would be generated from fugitive 

dust; combustion engine exhaust, and radon 

gas emissions from lixiviant circulation. 

Uranium airborne particulate emissions from 

yellowcake drying would be zero to near zero 

because of the use of the rotary vacuum drying 

process, which is designed to capture virtually 

all escaping particulate matter. With the 

prevailing wind direction out of the southsouthwest during the day time (EMC, 2007a), 

airborne emissions produced by the proposed 

Moore Ranch ISR Project would generally blow 

in the northeast direction. 

Fugitive dust would be generated primarily 

during construction, transportation, and 

decommissioning activities by travel on unpaved roads and from land disturbance associated 

with the construction of buildings, wellfields, roads, and support facilities. The applicant 

estimated the total dust from vehicular traffic on gravel roads at 14 t/yr [15.5 T/yr], based on 

proposed activities and emissions factors provided by WDEQ (EMC, 2007b). Traffic-generating 

activities addressed in the calculations included employee commuting, wellfield construction, 

The terms below define the various types of solid and 

liquid wastes generated at the Moore Ranch Project: 

Liquid wastes 

Liquid byproduct material (this term refers to all liquid 

wastes resulting from the proposed action except for 

sanitary wastewater and well development and testing 

wastewater) 

Sanitary Wastewater (ordinary sanitary (septic system) 

wastewater; this wastewater is nonhazardous, nonbyproduct material wastewater) 

Well development and testing wastewaters (wastewater 

generated during well development and pumping tests; 

this water is nonhazardous, non-byproduct material 

wastewater and would not require treatment before 

disposal) 

Solid wastes 

Solid byproduct material (this term refers to all solid 

wastes resulting from the proposed action that exceed 

NRC limits in 10 CFR Part 20 for unrestricted release) 

Solid waste (nonhazardous, solid waste, including 

domestic/municipal wastes (trash), construction/ 

demolition debris, septic solids, and solid byproduct 

material resulting from the proposed action (e.g., 

equipment, soils) that has been determined to meet 

NRC criteria in 10 CFR Part 20 for unrestricted release) 

Hazardous waste (Resource Conservation and 

Recovery Act or state-defined hazardous waste that is 

non-byproduct material and includes universal 

hazardous wastes and used oil)
In-Situ Uranium Recovery and Alternatives 

 2-23 

operations and maintenance, delivery of supplies and materials, and yellowcake product 

shipments. The close proximity of the site to SR 387 limits the distance of unpaved access 

roads and, therefore, the associated fugitive dust that would be generated from 

proposed activities. 

Combustion engine exhaust due to vehicular exhaust from workers commuting to the site; 

materials transport to the site; and diesel emissions from drilling rigs, diesel-powered water 

trucks, and other equipment used during the construction phase would also contribute to 

gaseous and particulate emissions. Emissions from diesel combustion engines in drilling rigs 

and construction equipment used predominantly during the construction and decommissioning 

phases were calculated by the NRC staff and discussed in detail in Appendix D. These 

calculations evaluated emissions of nitrogen oxides (NOx), carbon monoxide (CO), sulfur oxides 

(SOx), particulate matter (PM10), formaldehyde, volatile organic compounds (VOC), and carbon 

dioxide (CO2). Results show CO2 and NOx are the highest emissions of the pollutants 

evaluated. The calculated annual emissions for these pollutants during the construction phase 

bound emissions calculated for the decommissioning phase. Based on the applicant’s 

proposed schedule for wellfield construction (one wellfield per year), and an NRC staff 

assumption that the applicant would drill two deep disposal wells in the first year, the calculated 

annual emissions of CO2 and NOx are 852 t/yr [940 T/yr] and 18.1 t/yr [20 T/yr]. Results of the 

NRC staff emissions calculations indicate the drilling of deep wells contributes a significant 

proportion to the total emissions during construction. Therefore, if the applicant chose to drill all 

four proposed deep wells in the first year, these emissions would increase to 1,400 t/yr [1,600 

T/yr] CO2 and 30 t/yr [33 T/yr] NOx. Cumulative emissions approximations for CO2 and NOx for 

the lifecycle of the proposed facility (based on emissions from construction of all proposed 

wellfields, deep disposal wells, reclamation of these wellfields, and all surface facilities) are 

2400 t/yr [2600 T/yr] and 55 t/yr [61T/yr], respectively. Results for all of the diesel engine 

emissions calculated are provided in Appendix D. Mobile road (vehicle) combustion emissions 

were not calculated because these engine emissions are controlled at the source by mandated 

emission controls, and the magnitude of proposed road vehicle activity is small relative to 

existing road traffic (Section 4.3). 

The primary radioactive airborne effluent at the proposed Moore Ranch Project would be 

radon-222 gas. Radon-222 can be released in the wellfield when the pregnant lixiviant is 

brought to the surface from the ore zone aquifer. Radon-222 can be released during wellfield 

drilling, production, operation of the central plant, resin transfer operations, and aquifer 

restoration activities. The highest annual radon-222 releases would occur when multiple 

concurrent release activities occur during a single year. The applicant calculated the potential 

radon-222 emissions from the proposed Moore Ranch Project (EMC, 2007a) using methods 

documented in NRC Regulatory Guide 3.59. The NRC staff selected the highest annual 

radon-222 emissions from these results, approximately 15.0 TBq/yr [406 Ci/yr], as the sum of 

concurrent wellfield production releases for the proposed wellfields, releases from operation of 

the central plant, and releases from transferring resins from nearby satellite facilities (EMC, 

2007a). This estimate accounts for the applicant’s proposed use of pressurized downflow IX 

columns that the applicant estimates would limit radon-222 releases from IX operations to 10 

percent of the radon-222 that would be available for release using IX columns open to 

atmospheric pressure (EMC, 2007a). Additional information on proposed radon-222 emissions 

and the evaluation of potential impacts are provided in Section 4.13.1.2.1. 

The applicant has proposed installing separate ventilation systems for all indoor, nonsealed 

process tanks and vessels where radon-222 or process fumes would be expected. The system 

would consist of an air duct or piping system connected to the top of each of the process tanks. 
In-Situ Uranium Recovery and Alternatives 

 2-24 

Redundant exhaust fans would direct collected gases to discharge piping that would exhaust 

fumes to the outside atmosphere. The design of the fans would be such that the system would 

be capable of limiting employee exposures with the failure of any single fan. Discharge stacks 

would be located away from building ventilation intakes to prevent introducing exhausted 

radon-222 into the facility, as recommended in Regulatory Guide 8.31. Airflow through any 

openings in the vessels would be from the process area into the vessel and the ventilation 

system, controlling any releases that occur inside the vessel. Separate ventilation systems may 

be used, as needed, for the functional areas within the plant 

The work area ventilation system would be designed to force air to circulate within the plant 

process areas. The ventilation system would exhaust air outside the building, drawing fresh air 

inside. During favorable weather conditions, open doorways and convection vents in the roof 

would provide work area ventilation. The design of the ventilation system would be adequate to 

ensure that radon-222 daughter concentrations in the facility are maintained below 25 percent of 

the derived air concentration specified in 10 CFR Part 20. 

To ensure that the emission control system is performing within specified operating conditions, 

instrumentation would be installed that provides an audible alarm if the air pressure 

(i.e., vacuum level) falls below specified levels. Operation of this system would be checked and 

documented during dryer operations. In the event of system failure, the operator would perform 

and document checks of the differential pressure or vacuum every four hours. Additionally, 

during routine operations, data from the air pressure differential gauges for other emission 

control equipment would be observed and documented at least once per shift during 

dryer operations. 

2.1.1.1.6.2 Liquid Effluents 

During operations, the IX process would generate production bleed at an estimated rate of 114 

L/min [30 gal/min]. During groundwater restoration, the discharge from IX and/or RO processes 

would increase by an estimated 380 L/min [100 gal/min]. Any wastewater generated during or 

after the operations phase would be classified as liquid byproduct material (NRC, 2000). This 

byproduct material is not regulated as a hazardous waste under the Resource Conservation and 

Recovery Act (RCRA). The anticipated water chemistry of the injected material is summarized 

in Table 2-2. The production bleed and groundwater restoration waters would be disposed of 

via deep well injection. Other liquid waste streams from the central plant would include plant 

wash-down water and bleed stream from the elution and precipitation circuits during operations, 

and would contribute an estimated 38 L/min [10 gal/min) to the total wastewater volume 

during operations. 

Deep injection wells would be drilled to dispose of contaminated liquid effluents at the proposed 

project site. The applicant has submitted a permit application to WDEQ (currently under review) 

to construct from two to four UIC Class I disposal wells to inject liquid wastes into one of two 

geologic formations at a depth of: (i) the Lance Formation and Fox Hills Sandstone, or (ii) the 

Teckla Sandstone member of the Lewis Shale and the Teapot and Parkman Sandstone 

members of the Mesa Verde Formation. Both sets of geologic formations are located 

thousands of feet below the proposed uranium ore production zone. The WDEQ will evaluate 

the suitability of these formations for Class I deep well injection and to ensure human health and 

the environment is protected. 
In-Situ Uranium Recovery and Alternatives 

 2-25 

Table 2-2. Summary of Anticipated Liquid Byproduct Water Quality Parameters

Chemical Species Minimum (mg/L) Maximum (mg/L) 

pH 6 9 

Ammonia as N 50 500 

Sodium 150 3,000 

Calcium 200 1,000 

Potassium 10 1,000 

Bicarbonate as HCO3 1,500 4,000 

Carbonate as CO3 0 500 

Sulfate 80 2,000 

Chloride 200 4,000 

Uranium as U3O8 1 15 

Ra-226 (pCi/l) 300 3,000 

TDS 4,000 15,000 

Source: Uranium One, 2009c 

 

If injection is permitted in the Lance and Fox Hills sandstones, two UIC Class I disposal wells 

would be completed at a depth of between approximately 1,128 m to 2,286 m [3,700 ft to 

7,500 ft], with injection rates of 114 L/min [30 gal/min] per well. The injection interval would be 

overlain by at least 61 m [200 ft] of mudstone aquitard in the upper part of the Lance Formation. 

Water analyses for the Lance Formation suggest that the concentration of total dissolved solids 

in the injection interval would be in the range of 1,000 to 3,000 parts per million (ppm). 

Alternatively, injection may be permitted in the Teckla, Teapot, and Parkman sandstones, at a 

depth of approximately 2,413 m to 2,929 m [7,916 ft to 9,610 ft]. Depending on the permitted 

injection rate, up to four deep injection wells would be completed in these formations. The 

formations are overlain by the Lewis Shale, a regionally extensive aquitard that is about 122 m 

[400 ft] thick above the Teckla Sandstone. Total dissolved solids concentrations in the Teckla, 

Teapot, and Parkman sandstones are highly variable but are expected to be in the range of 

7,000 to 15,000 ppm in the Moore Ranch area. 

Domestic liquid wastes from the restrooms and lunchrooms would be disposed of in an 

approved septic system that meets WDEQ requirements for Class V underground injection 

wells. The septic system for the proposed Moore Ranch Project includes an approximately 
In-Situ Uranium Recovery and Alternatives 

 2-26 

3,788 L [1,000 gal] shop septic tank and a 7,575 L [2,000 gal] plant septic tank (Uranium 

One, 2009b). 

A small amount of uncontaminated wastewater would result from well development and well 

testing. This water would not need treatment prior to discharge to the surface. 

Stormwater runoff would also need to be managed at the proposed Moore Ranch Project. 

Facility drainage would be designed to route storm runoff water away from or around the plant, 

ancillary building and parking areas, and chemical storage areas. Federal and State agencies 

regulate the discharge of both stormwater runoff and the discharge of wastewater to surface 

waters through their permitting processes. The status of obtaining an industrial and 

construction National Pollutant Discharge Elimination System (NPDES) stormwater permit at the 

proposed Moore Ranch Project, as required under the Clean Water Act and WDEQ regulations, 

is summarized in Table 1-2. Uranium One would develop Best Management Practices (BMP) 

containing the procedures and engineering controls that would be implemented to manage 

stormwater runoff (EMC, 2007a). 

2.1.1.1.6.3 Solid Wastes 

All phases of the operational lifecycle of the proposed Moore Ranch Project could generate 

solid byproduct material and nonhazardous solid waste. Byproduct material could include spent 

resin, empty chemical containers, pipes and fittings, tank sediments, contaminated soil from 

leaks and spills, and contaminated construction and demolition debris. Nonhazardous solid 

waste includes septic solids municipal solid waste (general trash), and other solid wastes. 

Solid byproduct material is material that does not meet the NRC criteria for unrestricted release 

(including any soils contaminated from the operations). This material would be disposed of at a 

licensed disposal site. The proposed Moore Ranch Project is estimated to annually produce 76 

m3

 [100 yd3] of byproduct material during the operational period (EMC, 2007b). These materials 

would be stored on site inside the restricted area until such time that a full shipment could be 

made to a licensed waste disposal site or mill tailings facility. Based on the use of covered rolloffs with a nominal capacity of 15 m3

 [20 yd3], approximately five byproduct material shipments 

would occur per year. 

The NRC staff calculated the amount of solid byproduct material that could be generated from 

decommissioning activities based primarily on information provided in the applicant’s surety 

estimate (Uranium One, 2008) as 11,010 m3 [14,390 yd3

] plus an additional [ 512 t [565 T] of 

concrete demolition material. This estimate includes materials resulting from removal of plant 

facilities and equipment, wellfield equipment and piping from the two proposed wellfields, and 

removal of any contaminated soils that do not meet NRC limits for unrestricted release. As 

mentioned earlier, the applicant does not presently have an agreement in place with a licensed 

site to accept its solid byproduct material for disposal. The applicant would be required to have 

a disposal byproduct material agreement in place prior to operations. The applicant’s preferred 

destination for disposal of byproduct material is at the Pathfinder Mines Shirley Basin site in 

Mills, Wyoming. Chapter 3 describes the expected disposal site location, and Chapter 4 

describes the impact of disposing solid byproduct material. 

The Moore Ranch Project expects to produce approximately 1,530 m3

 [2,000 yd3] per year of 

nonhazardous solid waste composed of municipal waste (facility trash), septic solids, and other 

solid wastes, such as uncontaminated equipment, hardware, and packing materials. Waste 

minimization and recycling processes would be used to reduce the quantity of nonhazardous 
In-Situ Uranium Recovery and Alternatives 

 2-27 

solid waste generated. Since typical contract waste-haulage vehicles range in capacity from 

15 to 30 m3

 [20 to 40 yd3], a nominal capacity of 15 m3 [20 yd3] per vehicle was assumed, 

resulting in approximately 100 nonhazardous solid waste shipments per year, or an average of 

approximately two shipments per week, during the operational period (Uranium One, 2009b). 

The NRC staff calculated the amount of nonhazardous solid waste that could be generated 

from decommissioning activities based primarily on information provided in the applicant’s 

surety estimate ( Uranium One, 2008) as 482 m3

 [630 yd3] plus an additional 6,102 t [6,730 T] 

of concrete demolition material. This estimate includes materials resulting from removal of plant 

facilities and equipment and wellfield equipment from the two proposed wellfields that do not 

contain radioactive materials or that meet NRC limits for unrestricted release. Chapter 3 

describes the expected disposal site location and capacity and Chapter 4 describes the impact 

of disposing nonhazardous solid waste from the proposed Moore Ranch Project. 

As discussed in the prior section, domestic liquid wastes from the restrooms and lunchrooms 

would be disposed of in an approved septic system, which includes an approximately 3,788 L 

[1,000 gal] shop septic tank and a 7,575 L [2,000 gal] plant septic tank (Uranium One, 2009b). 

Solid materials collected in septic systems would be disposed of as solid waste, in accordance 

with WDEQ regulations. 

Based on a preliminary screening of processes and materials to be used at the proposed Moore 

Ranch Project, the applicant expects that the facility would be classified as a Conditionally 

Exempt Small Quantity Generator (CESQG), under the RCRA and Wyoming regulations. This 

classification does not require an application to the WDEQ. A CESQG: (1) must determine if 

their waste is hazardous; (2) must not generate more than 100 kilograms per month of 

hazardous waste or, except with regard to spills, more than 1 kilogram of acutely hazardous 

waste; (3) may not accumulate more than 1,000 kilograms of hazardous waste on-site at any 

time; and (4) must treat or dispose of their hazardous waste either in a nonsite or off-site U.S. 

treatment storage or disposal (TSD) facility that meets specific requirements of 40 CFR 261.5. 

If the facility fails to meet these four criteria, it would lose CESQG status and be fully regulated 

as either a small-quantity generator (more than 100 but less than 1,000 kilograms of nonacute 

hazardous waste per calendar month) or a large-quantity generator (at least 1,000 kilograms 

nonacute hazardous waste per calendar month). Any hazardous wastes, such as organic 

solvents, paints, used oil and paint thinners, empty chemical containers, tank 

sediments/sludges, chemical wastes, and spent batteries would be disposed of in accordance 

with a management program that the facility will develop to meet applicable local, State, and 

Federal regulatory requirements. 

2.1.1.1.7 Transportation 

Primary transportation activities would involve truck shipping and worker commuting. A variety 

of truck shipments are planned to support proposed activities during all phases of the facility’s 

lifecycle. This shipping activity involves construction equipment and materials, operational 

processing supplies, ion-exchange resins, yellowcake product, and waste materials. 

During construction, Uranium One expects that 16 employees would commute daily. During the 

operational and restoration phases of the project, the applicant estimates that a maximum of 

24 employees would commute (Uranium One, 2009a). Yellowcake production would be up to 

approximately 1,360,900 kg [3 million lbs]. With each outgoing truckload containing 

approximately 18,145 kg [40,000 lb], there would be 100 trips per year to the Honeywell 

Uranium Conversion Facility in Metropolis, Illinois, or the Cameco Corporation facility in Port 
In-Situ Uranium Recovery and Alternatives 

 2-28 

Hope, Ontario, Canada. This equates to an average of one shipment every 3.6 days (EMC, 

2007a). Operational waste shipments of byproduct material and uncontaminated solid wastes 

(Section 2.1.1.1.6) would be 5 shipments per year and 100 shipments per year (Uranium One, 

2009a). During the decommissioning phase, the applicant assumes 5 employees would 

commute daily. 

The traffic generated during the decommissioning phase, related to shipment of waste materials 

offsite, is expected to represent most of the truck traffic during that period. The NRC staff 

estimated the annual and average daily number of shipments that would be expected from the 

proposed decommissioning activities based on the calculated amounts of decommissioning 

solid wastes discussed in Section 2.1.1.1.6.3 and the volume of material per shipment. 

Because the applicant proposes a 12 month duration for the decommissioning of each well field, 

the staff conservatively estimated the annual decommissioning waste generated by assuming 

the applicant completes decommissioning and reclamation of a single well field (Wellfield 2) and 

all the surface facilities in a single year. This resulted in approximately 850 shipments of waste 

material for one year. Approximately 41 percent of these shipments would go to a landfill and 

the remainder to a licensed byproduct facility. If the disposal facilities are assumed to accept 

shipments 5 days per week, and the shipments are assumed to occur throughout the year with 

each shipment resulting in 2 one-way truck trips, the annual average daily traffic contribution 

would be approximately 3 truck round trips per day and about 16 shipments per week or 32 

one-way trips per week. This level of trucking activity for decommissioning waste shipments is 

lower than the applicant’s estimate for trucking during the construction phase and higher than 

the applicant’s estimate for truck traffic during the operations and aquifer restoration phases. 

Detailed traffic estimates for the proposed action and for the existing roads are provided in 

Section 4.3. 

2.1.1.1.8 Financial Surety 

As stated in Section 2.10 of the GEIS, NRC regulations [10 CFR Part 40, Appendix A, 

Criterion (9)] require that applicants cover the costs to conduct decommissioning, reclamation of 

disturbed areas, waste disposal, dismantling, disposal of all facilities including buildings and 

wellfields, and groundwater restoration. Uranium One would maintain financial surety 

arrangements to cover those costs for the proposed Moore Ranch ISR Project. The initial 

surety estimate would be based on the first year of operation. NRC and WDEQ require annual 

revisions to the surety estimate to reflect existing operations and planned construction or 

operation the following year. Once the NRC, WDEQ, and Uranium One have agreed to the 

estimate, Uranium One would submit a reclamation performance bond, irrevocable letter of 

credit, or other surety instrument to the NRC and WDEQ. The NRC reviews financial surety in 

detail as part of its review for the safety evaluation report (SER). For additional information on 

financial surety requirements, see 10 CFR Part 40, Appendix A and Section 2.10 of the GEIS. 

2.1.1.2 Alternative Wastewater Disposal Options 

Liquid wastes will be generated during the operations and aquifer restoration phases of the 

lifecycle for the proposed Moore Ranch ISR facility. These wastes are considered as byproduct 

materials and must be managed and disposed of in compliance with applicable State and 
In-Situ Uranium Recovery and Alternatives 

 2-29 

Federal regulations, as established by license and permit. The applicant indicated that the 

normal operational waste stream would be nonhazardous under RCRA. Predominantly, the 

liquid waste stream would consist of 

1. Process bleed ranging from 1 to 3 percent of the total water extracted from the 

ore horizon 

2. Effluents from the central processing plant, such as process drains, elution circuit 

bleed, and wash down water 

3. Wellfield purge water 

4. IX and RO reject brines produced during aquifer restoration. 

Of these, the process bleed would be the largest component during operations. Assuming a 

total plant throughput of 11,364 L/min [3,000 gal/min], a 1 percent process bleed would produce 

about 114 L/min [30 gal/min] of liquid waste. The applicant estimates that operational liquid 

wastes could be as much as approximately 170 L/min [45 gal/min] that would ultimately need 

disposal. During the aquifer restoration phase of the facility, the majority of the liquid waste 

would be comprised of discharge from the IX and RO processes used to treat groundwater. 

The applicant estimates that the total would increase to about 380 L/min [100 gal/min] for 

disposal (Uranium One, 2008, 2009a). 

In August 2009, the applicant submitted a permit application to WDEQ for liquid waste disposal 

via UIC Class I injection wells to the Lance Formation and Fox Hills Sandstones at a depth of 

approximately 1,128 m to 2,286 m [3,700 ft to 7,500 ft] (Uranium One, 2008, 2009a). Another 

option would be disposal into the Teckla, Teapot, and Parkman sandstones at depths from 

2,413 to 2,929 m [7,916 to 9,610 ft], although this would require more disposal wells because of 

the lower anticipated permitted injection capacity. Disposal via Class I injection well is 

discussed in Section 2.1.1.1 of this SEIS. If the applicant failed to receive a UIC permit from the 

WDEQ, then they would have to get their NRC license amended to approve another disposal 

option before they initiated operations. While not proposed in the license application, the 

following is an expanded discussion of possible alternative wastewater disposal options that 

were mentioned in the GEIS. Table 2-4 compares the various options. The analysis of potential 

environmental impacts is discussed in Section 4.1.1.2 of the SEIS but is not included in the 

comparison of alternatives in Table 2-4. Table 2-4 considers the applicant’s proposed 

wastewater disposal option to use a Class I UIC injection well. 

Historically, ISR facilities have used several other methods to manage and dispose of liquid 

wastes. These include solar evaporation ponds, land application, and surface water discharge. 

The following sections consider these disposal options, as well as deep well injection through 

UIC Class V permitted wells (NRC, 2003a). Characteristics of each of these wastewater 

disposal options are summarized in Table 2-3. 

 
In-Situ Uranium Recovery and Alternatives 

 2-30 
In-Situ Uranium Recovery and Alternatives 

 2-31 
In-Situ Uranium Recovery and Alternatives 

 2-32 

2.1.1.2.1 Evaporation Ponds 

One commonly used method for disposal of liquid wastes is to pump the liquids to one or more 

ponds and allow for natural solar radiation to reduce the volume through evaporation. The 

waste streams are usually treated prior to being discharged into evaporation ponds, but 

radionuclides and other metals may still be present, which will be concentrated as the liquids 

evaporate. The basic design criteria for an evaporation pond system are contained in 

10 CFR Part 40, Appendix A. The location of the ponds, design and construction of the 

necessary clay or geotextile liner systems and embankments for the ponds, as well as pond 

inspection and maintenance would be conducted in accordance with NRC regulations and 

guidance (NRC, 2003a, 2008), and established by NRC license conditions, as necessary. The 

siting and design of any impoundments would also take into account applicable EPA 

requirements in 40 CFR Part 264 (NRC, 2008). The Wyoming State Engineer’s Office also has 

state permitting authority for new impoundments. An earlier study of potential locations for a 

tailings impoundment associated with a potential conventional uranium mill at the proposed 

Moore Ranch Project location identified nearby natural basins underlain by a mudstone 

(NRC, 1982). This low permeability layer would be a favorable condition to be considered in 

siting potential evaporation ponds for this waste disposal option. The effectiveness of this 

wastewater disposal option will depend on the evaporation rate compared to the rate at which 

liquid wastes are produced. The evaporation rate varies seasonally, depending on temperature 

and relative humidity; the rate tends to be highest during warm, dry conditions and is lower 

during cool, humid conditions. If the evaporation rate is low or the seasonal conditions favoring 

evaporation are short in duration, the operator can compensate to some extent by increasing 

the size, and therefore, the surface area of the evaporation ponds. Historically, the area of an 

individual evaporation pond at uranium ISR facilities has ranged from approximately 0.04 to 2.5 

ha [0.1 to 6.2 ac] (NRC, 1997; 1998a,b; Cohen and Associates, 2008b), although these are for 

facilities that use a combination of waste disposal methods. 

Regulatory requirements in 40 CFR Part 61, Subpart W limit maximum lined uranium mill 

tailings impoundments to 16.2 ha [40 acres], although these tailings ponds are intended for a 

somewhat different purpose. The total footprint of the evaporation pond system for all liquid 

waste streams has been estimated as high as 40 ha [100 acres] (NRC, 1997). The estimated 

average annual evaporation rate from free water surfaces in the vicinity of the proposed Moore 

Ranch Project is approximately 102 cm/yr [40 in/yr] (Wyoming State Climate Office, 2004). 

Using this estimate, the minimum total evaporation pond area needed to handle the anticipated 

wastewater volumes would be about 10 to 18 ha [24 to 44 acres]. Taking into account annual 

precipitation effectively reduces the evaporation rate, then the pond system would need to be 

about 25 percent larger. Also, additional area would be needed to build additional storage 

areas to facilitate wastewater transfer between ponds for maintenance or repair work. During 

the winter months in Wyoming, where temperatures would be anticipated to be below freezing, 

the ponds could ice over, reducing the evaporation effectively to zero. To maintain year-round 

liquid disposal capability at the proposed Moore Ranch ISR facility, the applicant would, 

therefore, need to have either sufficient storage capacity, or at least one other disposal option 

(e.g., deep well injection, land application) available. 

To identify potential leaks from the evaporation pond system into the subsurface, the applicant 

would need to design, construct, and monitor a leak detection system and conduct routine 

inspections, typically on a daily, weekly, monthly, and quarterly basis, with special inspections 

as-needed (NRC, 2008). The applicant would also need to maintain sufficient freeboard 

(i.e., distance from the water level to top of the embankment) of about 1 to 2 m [3 to 6 ft], 

depending on the size of the individual pond, so that precipitation or wind-driven waves would 
In-Situ Uranium Recovery and Alternatives 

 2-33 

not overtop the embankment (NRC, 2008). In addition, the applicant would need to maintain 

sufficient reserve capacity in the evaporation pond system to allow the entire contents of one or 

more pond(s) to be transferred to other ponds, in the event of a leak and subsequent corrective 

action and liner repair (NRC, 2009). As necessary, the applicant would implement measures 

such as perimeter fencing and netting to protect humans and wildlife. These requirements 

would be established as conditions in an NRC license and enforced through the NRC 

inspection program. 

The applicant may need to obtain a National Emission Standards for Hazardous Air Pollutants 

(NESHAP) review by the WDEQ to demonstrate that radionuclides, such as radon, released to 

the air from this option met 40 CFR Part 61 requirements, in particular the provisions of 

Subpart W that incorporate the requirements of 40 CFR Part 192 (NRC, 2008; Cohen and 

Associates, 2008a). In developing the impoundment design, the applicant would also need to 

consider EPA surface impoundment regulations for surface impoundments in 40 CFR Part 264 

(NRC, 2008; Cohen and Associates, 2008b). 

Because ponds are open to the air, dust and dirt can be blown into a pond, and dissolved solids 

concentrations may increase through evaporation to the point where salts precipitate from the 

solution. The ponds may periodically need to be cleaned to maintain good repair and the 

necessary freeboard, and the accumulated salts and solids disposed as byproduct material at 

an NRC-licensed disposal facility. Similarly, when the operations and aquifer restoration phases 

end, the pond liners and any accumulated materials would also need to be disposed of as 

byproduct material. As an example of decommissioning waste volumes, the amount of 

byproduct material generated during decommissioning and reclamation of evaporation ponds at 

the Smith Ranch ISR facility in Converse County, Wyoming, was estimated in 2007 at 52 m3

[68 yd3

] (NRC, 2009). 

2.1.1.2.2 Land Application 

Land application is a disposal technique that uses agricultural irrigation equipment to broadcast 

wastewater on a relatively large area of land for subsequent evaporation. Land application is 

authorized at several solution mines (NRC, 1995; 1998b). Water released in this fashion would 

require treatment to meet NRC release requirements in 10 CFR Part 20, Subparts D, K, and 

Appendix B, and WDEQ surface water discharge requirements imposed by a zero release 

Wyoming Pollution Discharge Elimination System (WYPDES) permit (NRC, 2003a). Water, 

soils, and vegetation would be monitored on a regular basis, as established by license 

condition, to ensure soil loadings and vegetation concentrations remain within permit limits 

(NRC, 1995, 2003a). 

Liquid wastes pretreatment using IX columns, RO, and precipitation of barium/radium sulfate is 

typically incorporated into this process to decrease uranium and radium levels. This 

pretreatment is necessary to meet regulatory release limits and to minimize the potential buildup 

of radionuclides in surface soils and vegetation. Despite pretreatment, however, liquid waste 

disposal by land application typically requires large areas to remain below release requirements. 

For example, the Crow Butte facility near Crawford, Nebraska, has described about 40 ha 

[100 acres] as available for land application, if needed (NRC, 1998b), and the Highland Uranium 

Project in Converse County, Wyoming, identified two land application sites, each about 22 ha 

[54 acres] (NRC, 1995). Depending on how the applicant treated the waste water prior to land 

application, this disposal option might have additional land requirements related to constructing 

wastewater treatment facilities, radium-settling basins, and storage reservoirs (NRC, 1995). 

These facilities would add to the required footprint for this disposal option. For example, 
In-Situ Uranium Recovery and Alternatives 

 2-34 

radium-settling basins are typically on the order of 0.1 to 1.6 ha [0.25 to 4 acres] (NRC, 1995, 

1997, 1998a); purge reservoirs for temporary storage of treated wastewater can be much larger, 

with a surface area on the order of 4 ha [10 acres] or more, depending on the permit terms 

(NRC, 1998a). 

An additional consideration for this waste disposal option is radon released to the air. For 

example, calculations performed by NRC staff for land application over an area of 42 ha 

[104 acres], assuming average wastewater concentrations of 37 Bq/m3 [1 pCi/L] for radium and 

1 mg/L [1 ppm] for uranium, indicated that potential doses were below regulatory limits 

(NRC, 1997). Similarly, representative calculations for 7 years of land application to an area of 

18.5 ha [46 acres] with an assumed wastewater application rate of 1,514 L/min [400 gal/min], 

estimated a radon flux of 1.3 pCi/m2

-sec, not much over an assumed background of 

1 pCi/m2

-sec (NRC, 2003a, Appendix D). 

Areas used for land application would need to be included in decommissioning surveys at the 

end of the operations and aquifer restoration phases to ensure that soil concentration limits 

would not be exceeded, potentially adding to the total amount of material for disposal at a 

licensed facility (NRC, 2003a). In addition, any pond liners and precipitated solids accumulated 

in a radium-settling basin system would need to be disposed of as byproduct material. For 

example, the annual amount of radium-bearing sludges generated in a 1.6-ha [4-acre] 

radium-settling basin was estimated to be about 22.4 m3

/yr [29.3 ft3/yr] (Powertech, 2009). 

2.1.1.2.3 Surface Water Discharge 

Another disposal method historically used at uranium ISR facilities is treatment of liquid effluent 

and discharge at the surface. Like land application, the water would need to be pretreated to 

meet NRC release requirements in 10 CFR Part 20, Subparts D, K, and Appendix B, the 

provisions of 10 CFR Part 40, Appendix A that require conformance with EPA regulations in 

40 CFR Part 440, and WDEQ requirements imposed by a zero release WYPDES permit. The 

WYPDES permit would specify limits calculated to ensure the discharge does not cause a 

violation of water quality standards. WDEQ would not issue the permit if the discharge would 

either cause or contribute to the violation of water quality standards. Specific requirements for 

uranium ISL facilities are provided in EPA regulations at 40 CFR Part 440, Subpart C. 

Pretreatment of the liquid wastes using IX columns, RO, and barium/radium sulfate precipitation 

is typically incorporated into this process to decrease uranium and radium levels in the 

wastewater. Like the land application wastewater disposal option, this treatment might 

require additional land for the construction of radium-settling basins and storage reservoirs 

(NRC, 2003a). 

The regulatory framework for wastewater disposal by surface discharge is complicated, and it 

requires the applicant to make the distinction between “process wastewater” generated during 

uranium recovery operations and “mine wastewater” generated during aquifer restoration 

(NRC, 2003a). The applicant would need to develop storage capabilities, depending on 

whether it intended to maintain separate wastewater streams or commingle (mix) “process” and 

“mine” wastewater prior to treatment to 10 CFR Part 20 standards. In addition, the applicant 

would need to address any radioactivity at the discharge point or from storage facilities 

(e.g., tanks, impoundments), radium-settling basins, and related sludges as part of 

decommissioning the facility (NRC, 2003a; Cohen and Associates, 2008b). In addition, the 

applicant would not be allowed to discharge “process” wastewater to navigable waters of the 

United States, in accordance with EPA regulations at 40 CFR 440.34 (NRC, 2003a). 
In-Situ Uranium Recovery and Alternatives 

 2-35 

2.1.1.2.4 Class V Injection Well 

At the well, the techniques employed in disposing of liquid wastes through a UIC Class V deep 

injection well would be similar to those for deep injection of liquid wastes in a UIC Class I 

disposal well, as described previously in Section 2.1.1.1. The main difference would be the 

nature of the permit (WDEQ, 2001). For disposal through a UIC Class V well, WDEQ 

regulations assume that at least one underground source of drinking water would underlie the 

potential injection zone in the Lance Formation and Fox Hills sandstone, at a depth greater than 

2,286 m [7,500 ft] at the proposed Moore Ranch ISR facility (Uranium One 2008, 2009a). Also, 

the waste stream to be injected could not be classified as hazardous. For this reason, the 

wastewater would need to be treated to meet NRC release standards in 10 CFR Part 20, 

Subparts D, K, and Appendix B, and to ensure that all toxic substances remained at 

concentrations less than the WDEQ class-of-use standards or any federal primary drinking 

water standards, whichever is more stringent (WDEQ, 2001). Similar to land application and 

surface discharge, wastewater would be pretreated using IX columns, RO, barium/radium 

sulfate precipitation, and potentially radium-settling basins to decrease the levels of uranium, 

radium, and other contaminants in the waste water. As a result, the applicant would need to 

address storage facilities (e.g., tanks, impoundments) or radium settling basins and sludges as 

part of the decommissioning of the facility (NRC, 2003a). In addition, a UIC Class V permit 

would require the applicant to implement a monitoring plan to ensure that wastes would be 

confined to the authorized injection zone (WDEQ, 2008). 

2.1.2 No-Action (Alternative 2) 

Under the No-Action alternative, the NRC would not approve the license application for the 

proposed Moore Ranch Project. The No-Action alternative would result in Uranium One not 

constructing, operating, restoring the aquifer, or decommissioning the proposed Moore Ranch 

Project. No facilities, road, or wellfields would be built; no pipeline would be laid, as described 

in Section 2.1.1.1.2. No uranium would be recovered from the subsurface ore body; therefore, 

injection, production, and monitoring wells would not be installed to operate the facility. No 

lixiviant would be introduced in the subsurface and no buildings would be constructed to 

process extracted uranium or store chemicals. Because no uranium would be recovered, 

neither aquifer restoration nor decommissioning activities would occur. No liquid or solid 

effluents would be generated. The No-Action alternative is included to provide a basis for 

comparing and evaluating the potential impacts of the other alternatives, including the 

proposed action. 

2.2 Alternatives Eliminated from Detailed Analysis 

As required by NRC regulations, the NRC staff considered other alternatives to the construction, 

operation, aquifer restoration, and decommissioning of the proposed Moore Ranch Project. The 

range of alternatives was determined by considering the purpose and need for the proposed 

action and the private party’s objectives to extract uranium from a particular ore body. 

Reasonable alternatives considered in a site-specific environmental review depend on the 

proposed action and site conditions. This section describes alternatives to the proposed action 

that were considered but not carried forward for detailed analysis for reasons described in the 

following sections. Sections 2.2.1 and 2.2.2 describe different mining and associated milling 

alternatives for the proposed project site. Section 2.2.3 discusses an alternate geographic 

location, Section 2.2.4 discusses the use of different lixiviant chemistry, and Section 2.2.5 

discusses the use of alternate treatment methods for process-related liquid waste streams 

(Uranium One, 2009b). 
In-Situ Uranium Recovery and Alternatives 

 2-36 

2.2.1 Conventional Mining and Milling 

Uranium ore deposits at depth may be accessed either by open pit (surface) mining or by 

underground mining techniques. Open-pit mining is used to exploit shallow ore deposits, 

generally deposits less than 170 m [550 ft] below ground surface (EPA, 2008a). To gain access 

to the deposit, the topsoil is first removed and may be stockpiled for later site reclamation, while 

the remainder of the material overlying the deposit (i.e., the overburden) can be removed via 

mechanical shovels and scrapers, trucks or loaders, or by blasting (EPA, 1995; 2008a). The 

depth to which an ore body is surface mined depends on the ore grade, the nature of the 

overburden, and the ratio of the amount of overburden to be removed to extract one unit of ore 

(EPA, 1995). 

Underground mining techniques vary depending on size, depth, orientation, ore body grade, 

surface strata stability, and economic factors (EPA, 1995, 2008a). In general, underground 

mining involves sinking a shaft near the ore body and then extending levels from the main shaft 

at different depths to access the ore. Ore and waste rock would need to be removed through 

shafts by elevators or by using trucks to carry these materials up inclines to the surface 

(EPA, 2008a). 

In addition, once the open pit or underground workings are established, the mine may need to 

be dewatered to allow the extraction of the uranium ore. Dewatering can be accomplished 

either by pumping directly from the open pit or through pumping of interceptor wells to lower the 

water table (EPA, 1995). The mine water likely will require treatment prior to discharge, due to 

contamination from radioactive constituents, metals, and suspended and dissolved solids. 

Discharge of these mine waters may have subsequent impacts to surface water drainages and 

sediments, as well as to near-surface sources of groundwater (EPA, 1995). 

Following the completion of mining, either by open pit or underground techniques, reclamation 

of the mine is needed. Stockpiled overburden can be reintroduced into the mine, either during 

extraction operations or following any topsoil reapplied, in an attempt to reestablish topography 

consistent with the surroundings. At the end of dewatering, the water table may rebound and fill 

portions of the open pit and underground workings. Historically, uranium mines have impacted 

local groundwater supplies, and the waste materials from the mines have contaminated lands 

surrounding the mines (EPA, 2008b). 

Ore extracted from the open pit or underground mine would be processed in a conventional mill. 

As discussed in Appendix C of the GEIS (NRC, 2009), ore processing at a conventional mill 

involves a series of steps (handling and preparation, concentration, and product recovery). 

While the conventional milling techniques recover approximately 90 percent of the uranium 

content of the feed ore (NRC, 2009), the process does generate substantial wastes (known as 

tailings) since roughly 95 percent of the ore rock is disposed as waste (NRC, 2009). This 

process also can consume large amounts of water {e.g., approximately 534 liters per minute 

(Lpm); 141 gallons per minute [gpm]) for the proposed Pinon Ridge mill in Colorado 

(EFRC, 2009)}. 

Tailings are disposed in extensive lined impoundments. NRC reviews the design and 

construction of the impoundments to ensure safe disposal of the tailings (NRC, 2009). 

Reclamation of the tailings pile generally involves evaporation of liquids in the tailings, 

settlement of the tailings over time, and covering the pile with a thick radon barrier and earthen 

material or rocks for erosion control. An area surrounding the reclaimed tailings piles would be 

fenced off in perpetuity, and the site transferred to either a State or Federal agency for 
In-Situ Uranium Recovery and Alternatives 

 2-37 

long-term care (EIA, 1995). The costs associated with final mill decommissioning and tailings 

reclamation can run into the tens of millions of dollars (EIA, 1995). 

NRC evaluated the potential environmental impacts of conventional uranium milling operations 

in a programmatic context, including the management of mill tailings in the final generic 

environmental impact statement on uranium milling (NRC, 1980). This SEIS evaluated the 

nature and extent of conventional uranium milling to inform of the regulatory requirements for 

management and disposal of mill tailings and for mill decommissioning. The impacts from 

operating a conventional mill are significantly greater than for operating an ISR facility. For 

example, at the proposed Moore Ranch Project, approximately 61 ha [150 ac] would be used for 

uranium extraction operations (e.g., two wellfields, the central plant, pipeline infrastructure); 

however, for a conventional mill, more than twice that amount of land (150 ha [370 ac]) would 

be devoted to milling and allied activities during operations, and during mill construction a total 

of 300 ha [741 ac] could be impacted (NRC, 1980). Furthermore, the deposition of windblown 

tailings could further restrict land use near the tailings. Levels of contamination extended 

several hundred meters beyond the model site boundary evaluated in the GEIS for conventional 

milling. Therefore, conventional milling was eliminated from detailed analysis in the Moore 

Ranch SEIS. 

2.2.2 Conventional Mining and Heap Leaching 

Conoco, Inc. proposed to use conventional mining techniques to mine uranium in the same area 

as the proposed Moore Ranch Project and requested the issuance of an NRC Source and 

Byproduct Material License authorizing operation of the proposed Sand Rock Mill Project (NRC, 

1982). Eleven different geographic locations at the site were evaluated to meet the 

performance objectives of reducing the length of slurry pipelines to minimize the potential for 

leaks and spills and to locate a prospective evaporation pond to minimize the potential impact 

on ecological resources. The development of a conventional mine would result in the 

disturbance of a larger land area with a greater risk to wildlife than an ISR facility, and the 

fugitive dust emissions would be greater with a conventional mine compared to an ISR facility 

and require more maintenance with an associated increase in occupational exposure compared 

to an ISR facility. In addition, evaporation ponds can produce large quantities of byproduct 

material in the form of pond liners and sludges. These materials lead to higher volumes of 

decommissioning wastes, requiring transportation to and disposal at an NRC-licensed facility. 

In addition, the effectiveness of evaporation ponds in Wyoming is subject to seasonal conditions 

such as winter freezing. For these reasons, the use of evaporation ponds associated with 

conventional mining at the proposed Moore Ranch Project was eliminated from 

detailed analysis. 

Heap leaching is discussed in Appendix C of the GEIS (NRC, 2009). For low-grade ores, heap 

leaching is a viable alternative. Low-grade ore removed from open-pit or underground mining 

operations undergo further processing to remove and concentrate the uranium. Heap leaching 

is typically used when the ore body is small and situated far from the milling site. The low-grade 

ore is crushed to approximately 2.6 cm [1 in] in size and mounded above grade on a prepared 

pad. A sprinkler or drip system positioned over the top continually distributes leach solution 

over the mound. Depending on the lime content, an acid or alkaline solution can be used. The 

leach solution trickles through the ore and mobilizes the uranium, as well as other metals, into 

the solution. The solution is collected at the base of the mound by a manifold and processed to 

extract the uranium. The uranium recovery from heap leaching is expected to range from 50 to 

80 percent, resulting in final tailings material of approximately 0.01 percent uranium content. 

Once heap leaching is complete, the depleted materials are AEA, as amended by UMTRCA, 
In-Situ Uranium Recovery and Alternatives 

 2-38 

byproduct material that must be placed in a conventional mill tailings impoundment, unless NRC 

grants a disposal exemption. While the impacts from heap leaching may be less than those 

from conventional milling, the impacts from the associated open-pit or underground mining 

would still be substantial. For these considerations, similar to those listed in Section 2.2.1, this 

alternative is not carried forward for detailed analysis. 

2.2.3 Alternate Site Location 

An alternate central plant location approximately 366 m [1,200 ft] west of the proposed location 

was considered by the applicant. Although this location would have been closer to Brown Road, 

it was determined to be less suitable because more changes to the existing topography would 

be required for the proposed plant layout than evaluated under the proposed action. At the 

alternate location, more cut and fill activity would have been required, thus resulting in more 

land disturbance and the potential to impact cultural resources. 

2.2.4 Alternate Lixiviants 

Alternate lixiviant chemistry was also considered for the operations phase of the proposed 

action, including acid leach solutions and ammonia-based lixiviants. Acid-based lixiviants such 

as sulfuric acid, dissolve heavy metals and other solids associated with uranium in the host rock 

and other chemical constituents that require additional remediation and have greater 

environmental impacts. At a small-scale research facility in Wyoming, test patterns were 

developed using acid-based lixiviants. During operations, two significant problems developed. 

The mineral gypsum precipitated on the well screens and in the aquifer, which plugged the wells 

and reduced the efficiency of the wellfield restoration. Aquifer restoration had limited success, 

because of the gradual dissolution of the precipitated gypsum, which resulted in increased 

salinity and sulfate levels in the affected groundwater (Uranium One, 2009b). Because it is 

technically more difficult to restore acid mine sites, the use of an acid-based lixiviant was 

eliminated from detailed analysis in the SEIS. 

Ammonia-based lixiviants have been used at ISR operations in Wyoming. However, operational 

experience has shown that ammonia tends to adsorb onto clay minerals in the subsurface and 

then slowly desorbs from the clay during restoration, therefore requiring a much larger volume 

of groundwater be removed and processed during aquifer restoration (Mudd, 2001). Because of 

the greater consumptive use of groundwater to meet groundwater restoration requirements, the 

use of an ammonia-based lixiviant was eliminated from detailed analysis. 

2.2.5 Alternate Wastewater Treatment Methods 

A range of liquid treatment methods that considered the three primary waste streams generated 

at an ISR facility: plant eluant, wellfield purge water, and RO reject produced during wellfield 

restoration were considered for use at the proposed Moore Ranch Project. These 

methods included mechanical evaporation and chemical precipitation, as discussed in the 

following paragraphs. 

Although mechanical evaporation could produce the smallest possible volume of brine for 

disposal, it would require larger storage tanks and more offsite shipment of materials than the 

proposed action, higher energy consumption approximately 16 times greater than the proposed 

action), a larger operations workforce, and from an environmental perspective mechanical 

evaporation would have a larger carbon footprint because of the greater power requirements 

(Uranium One, 2009b). From a safety perspective, mechanical evaporation would require 
In-Situ Uranium Recovery and Alternatives 

 2-39 

operating at high temperatures and pressures and would have high chemical requirements for 

solidification chemicals, thus increasing the potential for occupational exposure and accidents. 

Finally, the capital cost for mechanical evaporation would be approximately four times greater 

than those for deep disposal wells (Uranium One, 2009a). For these reasons, mechanical 

evaporation was eliminated from detailed analysis in the SEIS. 

Chemical precipitation and RO to either pretreat the wastewater for more efficient operation of 

the RO system or for brine treatment were also considered. This practice would result in the 

formation of both brine residual and sludge. This method of treatment produces a higher 

volume of liquid residues and requires greater storage capacity than the proposed action 

(757,575 L [200,000 gal] brine storage tank compared to a 37,878 L [10,000 gal] storage tank 

for the proposed action). The brine would be concentrated waste that could potentially be 

characterized as either hazardous or mixed waste. The energy consumption for this treatment 

method would be approximately four times that of the proposed action, the labor would be 

approximately six times higher than that for the proposed action. This treatment method would 

involve the handling of the greatest amount of residues requiring onsite storage and 

transportation for offsite disposal, thus increasing the potential for occupational exposure and 

transportation accidents. For these reasons, chemical precipitation and RO were eliminated 

from detailed analysis in the SEIS. 

2.2.6 Comparison of the Predicted Environmental Impacts 

NUREG–1748 (NRC, 2003b) categorizes the significance of potential environmental impacts 

as follows: 

SMALL: The environmental effects are not detectable or are so minor that they will 

neither destabilize nor noticeably alter any important attribute of the 

resource considered. 

MODERATE: The environmental effects are sufficient to alter noticeably, but not 

destabilize important attributes of the resource considered. 

LARGE: The environmental effects are clearly noticeable and are sufficient to 

destabilize important attributes of the resource considered. 

In this section, for each of the three alternatives, the potential environmental impacts to each 

resource area are summarized for all four of the ISR phases: construction, operation, aquifer 

restoration, and decommissioning. The significance levels (SMALL, MODERATE, and LARGE) 

are specific to each resource and are defined in Chapter 4. 

Chapter 4 of this SEIS presents a more detailed evaluation of the environmental impacts from 

the proposed action and the No-Action alternative. Table 2-4 compares the environmental 

impact by ISR phase of implementing the proposed action and the No-Action alternative and 

identifies the section of the SEIS where more detailed information can be found. 

 
In-Situ Uranium Recovery and Alternatives 

 2-40 

Table 2-4. Comparison of Predicted Environmental Impacts 

4.2 Land Use Impacts Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL

4.2.1.1

NONE

4.2.2

Operation SMALL

4.2.1.2

NONE

4.2.2

Aquifer Restoration SMALL

4.2.1.3

NONE

4.2.2

Decommissioning SMALL

4.2.1.4

NONE

4.2.2

4.3 Transportation Impacts Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL

4.3.1.1

NONE

4.3.2.

Operation SMALL

4.3.1.2

NONE

4.3.2

Aquifer Restoration SMALL

4.3.1.3

NONE

4.3.2

Decommissioning SMALL

4.3.1.4

NONE

4.3.2

4.4 Geology and Soils Impacts Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL

4.4.1.1

NONE

4.4.2

Operation SMALL

4.4.1.2

NONE

4.4.2

Aquifer Restoration SMALL

4.4.1.3

NONE

4.4.2

Decommissioning SMALL

4.4.1.4

NONE

4.4.2

4.5.1 Water Resources Impacts

(Surface Water) Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL

4.5.1.1.1

NONE

4.5.1.2

Operation SMALL

4.5.1.1.2

NONE

4.5.1.2

Aquifer Restoration SMALL

4.5.1.1.3

NONE

4.5.1.2

Decommissioning SMALL

4.5.1.1.4

NONE

4.5.1.2

4.5.2 Water Resources Impacts 

(Groundwater) Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL

4.5.2.1.1

NONE

4.5.2.2

Operation SMALL

4.5.2.1.2

NONE

4.5.2.2

Aquifer Restoration SMALL

4.5.2.1.3

NONE

4.5.2.2

Decommissioning SMALL

4.5.2.1.4

NONE

4.5.2.2
In-Situ Uranium Recovery and Alternatives 

 2-41 

Table 2-4. Comparison of Predicted Environmental Impacts 

4.6 Ecological Resources 

Impacts (Vegetation) Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL

4.6.1.1.1

NONE

4.6.2

Operation SMALL

4.6.1.2.1

NONE

4.6.2

Aquifer Restoration SMALL

4.6.1.3

NONE 

4.6.2 

Decommissioning SMALL 

4.6.1.4

NONE 

4.6.2 

4.6 Ecological Resources 

Impacts (Wildlife) Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL 

4.6.1.1.2 

NONE 

4.6.2 

Operation SMALL 

4.6.1.2.2 

NONE 

4.6.2 

Aquifer Restoration SMALL 

4.6.1.3 

NONE 

4.6.2 

Decommissioning SMALL 

4.6.1.4

NONE 

4.6.2 

4.7 Meteorology, Climatology, 

and Air Quality Impacts Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL 

4.7.1.1 

NONE 

4.7.3 

Operation SMALL 

4.7.1.2 

NONE 

4.7.3 

Aquifer Restoration SMALL 

4.7.1.3 

NONE 

4.7.3 

Decommissioning SMALL 

4.7.1.4 

NONE 

4.7.3 

4.8 Noise Impacts Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL 

4.8.1.1 

NONE 

4.8.2 

Operation SMALL 

4.8.1.2 

NONE 

4.8.2 

Aquifer Restoration SMALL 

4.8.1.3 

NONE 

4.8.2 

Decommissioning SMALL 

4.8.1.4 

NONE 

4.8.2 

4.9 Impacts to Historical and 

Cultural Resources Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL 

4.9.1.1 

NONE 

4.9.2 

Operation SMALL 

4.9.1.2 

NONE 

4.9.2 

Aquifer Restoration SMALL 

4.9.1.3 

NONE 

4.9.2 

Decommissioning SMALL 

4.9.1.4 

NONE 

4.9.2 
In-Situ Uranium Recovery and Alternatives 

 2-42 

Table 2-4. Comparison of Predicted Environmental Impacts 

4.10 Visual and Scenic 

Resources Impacts Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL 

4.10.1.1 

NONE 

4.10.2 

Operation SMALL 

4.10.1.2 

NONE 

4.10.2 

Aquifer Restoration SMALL 

4.10.1.3 

NONE 

4.10.2 

Decommissioning SMALL 

4.10.1.4 

NONE 

4.10.2 

4.11 Socioeconomic Impacts 

(Demographics) Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL 

4.11.1.1.1 

NONE 

4.11.2 

Operation SMALL 

4.11.1.2.1 

NONE 

4.11.2 

Aquifer Restoration SMALL 

4.11.1.3 

NONE 

4.11.2 

Decommissioning SMALL 

4.11.1.4 

NONE 

4.11.2 

Socioeconomic Impacts 

(Income) Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL 

4.11.1.1.2 

NONE 

4.11.2 

Operation SMALL 

4.11.1.2.2 

NONE 

4.11.2 

Aquifer Restoration SMALL 

4.11.1.3 

NONE 

4.11.2 

Decommissioning SMALL 

4.11.1.4 

NONE 

4.11.2 

Socioeconomic Impacts 

(Housing) Alternative 1—Proposed Action Alternative 2—No-Action

Construction NONE 

4.11.1.1.3 

NONE 

4.11.2 

Operation SMALL TO MODERATE 

4.11.1.2.3 

NONE 

4.11.2 

Aquifer Restoration SMALL 

4.11.1.3 

NONE 

4.11.2 

Decommissioning SMALL 

4.11.1.4 

NONE 

4.11.2 

Socioeconomic Impacts 

(Employment Structure) Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL 

4.11.1.1.4 

NONE 

4.11.2 

Operation NONE 

4.11.1.2.4 

NONE 

4.11.2 

Aquifer Restoration SMALL 

4.11.1.3 

NONE 

4.11.2 
In-Situ Uranium Recovery and Alternatives 

 2-43 

Table 2-4. Comparison of Predicted Environmental Impacts 

Decommissioning SMALL 

4.11.1.4 

SMALL 

4.11.2 

Socioeconomic Impacts 

(Local Finance) Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL 

4.11.1.1.5 

NONE 

4.11.2 

Operation SMALL 

4.11.1.2.5 

NONE 

4.11.2 

Aquifer Restoration SMALL 

4.11.1.3 

NONE 

4.11.2 

Decommissioning SMALL 

4.11.1.4 

NONE 

4.11.2 

Socioeconomic Impacts 

(Education) Alternative 1—Proposed Action Alternative 2—No-Action

Construction NONE 

4.11.1.1.6 

NONE 

4.11.2 

Operation SMALL 

4.11.1.2.6 

NONE 

4.11.2 

Aquifer Restoration SMALL 

4.11.1.3 

NONE 

4.11.2 

Decommissioning SMALL 

4.11.1.4 

NONE 

4.11.2 

Socioeconomic Impacts 

(Health and Social Services) Alternative 1—Proposed Action Alternative 2—No-Action

Construction NONE 

4.11.1.1.7 

NONE 

4.11.2 

Operation SMALL 

4.11.1.2.7 

NONE 

4.11.2 

Aquifer Restoration SMALL 

4.11.1.3 

NONE 

4.11.2 

Decommissioning SMALL 

4.11.1.4 

NONE 

4.11.2 

4.12 Environmental Justice 

Impacts Alternative 1—Proposed Action Alternative 2—No-Action

Construction NONE 

4.12.2 

NONE 

4.12.3 

Operation NONE 

4.12.2 

NONE 

4.12.3 

Aquifer Restoration NONE 

4.12.2 

NONE 

4.12.3 

Decommissioning NONE 

4.12.2 

NONE 

4.12.3 

 
In-Situ Uranium Recovery and Alternatives 

 2-44 

4.13 Public Occupational 

Health and Safety Impacts Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL 

4.13.1.1 

NONE 

4.13.2 

Operation SMALL 

4.13.1.2 

NONE 

4.13.2 

Aquifer Restoration SMALL 

4.13.1.3 

NONE 

4.13.2 

Decommissioning SMALL 

4.13.1.4 

NONE 

4.13.2 

4.14 Waste Management 

Impacts Alternative 1—Proposed Action Alternative 2—No-Action

Construction SMALL 

4.14.1.1.1 

NONE 

4.14.2 

Operation SMALL 

4.14.1.1.2 

NONE 

4.14.2 

Aquifer Restoration SMALL 

4.14.1.1.3 

NONE 

4.14.2 

Decommissioning SMALL 

4.14.1.1.4 

NONE 

4.14.2 

2.3 Final Recommendation 

After weighing the impacts of the proposed action and comparing the alternatives, the NRC 

staff, in accordance with 10 CFR 51.91(d), sets forth its NEPA recommendation regarding the 

proposed action. Unless safety issues mandate otherwise, the NRC staff’s recommendation to 

the Commission related to the environmental aspects of the proposed action is that the source 

material license be issued as requested. This recommendation is based upon (1) the license 

application, including the ER submitted by Uranium One and the applicant’s supplemental 

letters and responses to the NRC staff’s requests for additional information; (2) consultation with 

Federal, State, Tribal, and local agencies; (3) the NRC staff independent review; (4) the NRC 

staff’s consideration of comments received on the draft SEISs; and (5) the assessments 

summarized in this SEIS. 

2.4 References 

Cohen and Associates, 2008a. “Final Report History and Basis of NESHAPs and Subpart W.” 

Vienna, Virginia: S. Cohen and Associates. September 25. <http://www.epa.gov/radiation/ 

docs/neshaps/subpart-w/neshap-history.pdf> (25 May 2010). 

Cohen and Associates, 2008b. “Final Report Review of Existing and Proposed Tailings 

Impoundment Technologies.” Vienna, Virginia: S. Cohen and Associates. September 25. 

<http://www.epa.gov/radiation/docs/neshaps/subpart-w/tailings-impoundment-tech.pdf> 

(25 May 2010). 

EMC (Energy Metals Corporation US), 2007a. “Application for USNRC Source Material 

License, Moore Ranch Uranium Project, Campbell County, Wyoming, Technical Report.” 

Casper, Wyoming: Uranium 1 Americas Corporation. ADAMS Accession Nos. ML072851222, 
In-Situ Uranium Recovery and Alternatives 

 2-45 

ML072851258, ML072851259, ML072851260, ML072851268, ML072851350, ML072900446. 

October 2. 

EMC, 2007b. “Application for USNRC Source Material License, Moore Ranch Uranium Project, 

Campbell County, Wyoming, Environmental Report.” Casper, Wyoming: Uranium 1 Americas 

Corporation. ADAMS Accession Nos. ML072851222, ML072851229, ML072851239, 

ML07285249, ML07285253, ML07285255. October 2. 

EIA (Energy Information Administration), 1995. “Decommissioning of U.S. Uranium Production 

Facilities.” Office of Coal, Nuclear, Electric, and Alternate Fuels. DOE/EIA–0592. February. 

EPA (U.S. Environmental Protection Agency), 2008a. “Technical Report on Technologically 

Enhanced Naturally Occurring Radioactive Materials from Uranium Mining: Mining and 

Reclamation Background.” Volume 1. Office of Radiation and Indoor Air/Radiation Protection 

Division. EPA–402–R–08–005. April. 

EPA, 2008b. “Health and Environmental Impacts of Uranium Contamination in the Navajo 

Nation: Five-Year Plan.” Requested by House Committee on Oversight and Government 

Reform. June 9. 

EPA, 1995. “Technical Resource Document: Extraction and Beneficiation of Ores and 

Minerals—Uranium.” Volume 5. Office of Solid Waste / Special Waste Branch. 

Griffin, M., 2009. <mike.griffin@uranium1.com. Phases of the Moore Ranch Project” 

September. [email communication]. ADAMS Accession No. ML092720144. 

(28 September 2009). 

Mackin, P.C., D. Daruwalla, J. Winterle, M. Smith, and D.A. Pickett, 2001. NUREG/CR–6733, 

“A Baseline Risk-Informed Performance-Based Approach for In-Situ Leach Uranium Extraction 

Licensees.” Washington, DC: NRC. September. 

Mudd, G.M., 2001. “Critical Review of Acid In-Situ Leach Uranium Mining: 1-USA and 

Australia.” Vol. 41. pp. 390–403. 

NRC, 2009 NUREG–1910, “Generic Environmental Impact Statement for In-Situ Leach 

Uranium Milling Facilities.” Washington, DC: NRC. May. 

NRC, 2008. Regulatory Guide 3.11, “Design, Construction, and Inspection of Embankment 

Retention Systems at Uranium Recovery Facilities.” Revision 3. Washington, DC: NRC. 

November 2008. 

NRC, 2003a. NUREG–1569, “Standard Review Plan for In-Situ Leach Uranium Extraction 

License Applications—Final Report.” Washington, DC: NRC. June 2003. Washington, DC: 

NRC. August. 

NRC, 2003b. NUREG–1748, “Environmental Review Guidance for Licensing Actions 

Associated With NMSS Programs.” Washington, DC: NRC. August. 

NRC, 2000. “Staff Requirements–SECY–99–013 Recommendations on Ways to Improve the 

Efficiency of NRC Regulation at In-Situ Uranium Recovery Facilities.” Washington, DC: 

July 26, 2000. 
In-Situ Uranium Recovery and Alternatives 

 2-46 

NRC, 1998a. “Environmental Assessment for Renewal of Source Material License 

No. SUA–1341, Cogema Mining, Inc. Irigaray and Christensen Ranch Projects, Campbell and 

Johnson Counties, Wyoming.” Docket No. 40-8502. Washington, DC: NRC. June 1998a. 

NRC, 1998b. “Environmental Assessment for Renewal of Source Material License No. SUA–

1534 Crow Butte Resources Incorporated Crow Butte Uranium Project Dawes County, 

Nebraska.” Docket No. 40-8943. Washington, DC: NRC. February. 

NRC, 1997. NUREG–1508, “Final Environmental Impact Statement To Construct and Operate 

the Crownpoint Uranium Solution Mining Project, Crownpoint, New Mexico.” Washington, DC: 

NRC. February. 

NRC, 1995. “Environmental Assessment for Renewal of Source Materials License 

No. SUA–1511.Power Resources Incorporated Highland Uranium Project, Converse County, 

Wyoming.” 

NRC, 1982. NUREG–0889, “Draft Environmental Statement related to the Operation of Sand 

Rock Mill Project (Draft Report for Comment).” Washington, DC. March. 

NRC, 1980. NUREG–0706, “Final Generic Environmental Impact Statement on Uranium Milling 

Project M-25.” ADAMS Accession Nos. ML032751663, ML0732751667, ML032751669. 

September. 

Powertech (USA), Inc., 2009 “Dewey-Burdock Project. Supplement to Application for NRC 

Uranium Recovery License Dated February 2009. Appendices.” Greenwood Village, Colorado: 

Powertech (USA), Inc. August. 

Uranium One (Uranium One Americas), 2009a. “Response to Request for Additional 

Information for the Moore Ranch In-Situ Uranium Recovery Project License Application (TAC 

JU011).” ADAMS Accession No. ML091900402. June 19. 

Uranium One, 2009b. “Response to Request for Additional Information for the Moore Ranch 

In-Situ Uranium Recovery Project License Application (TAC JU011).” ADAMS Accession No. 

ML092450317. August 31. 

Uranium One, 2009c. “Class I Permit Application and Comment Responses–Moore Ranch 

Uranium Project. Volumes I and II” Casper, Wyoming. Uranium One, Inc. August 17. 

Uranium One, 2008. Response to Request for Additional Information for the Moore Ranch 

In-Situ Uranium Recovery Project License Application (TAC JU011).” ADAMS Accession No. 

ML082060527. July 11. 

WDEQ (Wyoming Department of Environmental Quality), 2008. “UIC Program Policy: 

Permitting In-Situ Mine Waste Disposal Wells.” 08-001.POL. Cheyenne, Wyoming: WDEQ, 

Water Quality Division. July 16. 

WDEQ, 2001. “Water Quality Rules and Regulations, Chapter 16, Class V Injection Wells and 

Facilities Underground Injection Control Program.” Cheyenne, Wyoming: WDEQ, Water 

Quality Division. July. 
In-Situ Uranium Recovery and Alternatives 

 2-47 

WDEQ, 2000. “Guideline No. 4–In-Situ Mining, Attachment III Topsoil and Subsoil Management 

and the Associated Erosion Control at Uranium In-Situ Leaching Operations.” March. 

WDEQ, 1986. “Guideline No. 2–Vegetation.” March. 

Wyoming State Climate Office, 2004. “Wyoming Climate Atlas.” J. Curtis and K. Grimes, eds. 

Laramie Wyoming: Wyoming State Climate Office <http://www.wrds.uwyo.edu/sco 

/climateatlas/evaporation.html> (03 June 2010). 

3-1 

3 AFFECTED ENVIRONMENT 

3.1 Introduction 

The proposed Moore Ranch Project is located in the Powder River Basin in southwest Campbell 

County, Wyoming, in the Wyoming East Uranium Milling Region defined in the Generic 

Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities (NUREG–1910, 

GEIS) (NRC, 2009a). The Powder River Basin is an energy-rich area that possesses some of 

the largest coal, coal bed methane (CBM) and natural gas deposits in the United States. The 

proposed project is located approximately 80 km [50 mi] southwest of Gillette, Wyoming, and 

approximately 80 km [50 mi] northeast of Casper, Wyoming (see Figure 1-1). The proposed 

license area encompasses approximately 2,879 ha [7,110 ac] of land; an estimated 61 ha 

[150 ac] of land surface could be directly disturbed by in-situ recovery (ISR) construction 

and operations. 

This chapter describes the existing site conditions at the proposed Moore Ranch Project. For 

the purposes of this supplemental environmental impact statement (SEIS), the term license area 

refers to the 2,879 ha [7,110 ac] Moore Ranch Project plus an area extending 3.2 km [2 mi], as 

suggested in NUREG–1569 unless a different radius for a particular resource is specified (NRC, 

2003). This section describes resource areas including land use, transportation, geology and 

soils, water resources, ecology, noise, air quality, historical and cultural resources, visual and 

scenic resources, socioeconomics, public and occupational health, and current waste 

management practices. Issues identified, based on agency and public concerns and regulatory 

and planning requirements, have been considered in the description of the affected 

environment. The information in this chapter forms the basis for assessing the potential impacts 

(see Chapter 4) of the proposed action and each alternative (Chapter 2). 

3.2 Land Use 

The proposed Moore Ranch Project is located in the northeast portion of Wyoming within the 

Powder River Basin in the following townships and ranges: Township 42 North, Range 75 

West, Sections 26, 27, 33, 34, 35, 36, and portions of Sections 25 and 28; Township 41 North, 

Range 75 West, Sections 2, 3, 4, and portions of Sections 1, 9, and 10; and Township 42 North, 

Range 74 West, and portions of Sections 30 and 31. 

Section 3.1.2.2 of the GEIS described the concept of split estate where the land surface and 

mineral rights can be owned by different entities, and in particular, where the U.S. Bureau of 

Land Management (BLM) owns the mineral rights (NRC, 2009a). This situation occurs at the 

proposed Moore Ranch Project. Of the 2,879 ha [7,110 ac] comprising the proposed Moore 

Ranch Project, over 85 percent of the surface rights are previously owned, and about 14 

percent of the surface rights are owned by the State of Wyoming. About 59 percent of the 

mineral rights are owned by BLM but have been leased to Uranium One Americas (Uranium 

One), about 26 percent of the mineral rights are privately owned, and the State of Wyoming 

owns the mineral rights underlying their surface ownership. Figures 3-1 and 3-2 show the 

proposed Moore Ranch Project surface and mineral rights owners. The central plant would be 

located on privately owned land, and no mineral exploration (i.e., no wells to extract uranium) 

would occur at that location. At both Wellfields 1 and 2, the surface rights are privately owned; 

however, the mineral rights at Wellfield 1 have been leased from the BLM; and at Wellfield 2 the 

mineral rights are both publicly and privately owned. The Permit to Mine application submitted 
Affected Environment 

 3-2 

Figure 3-1. Surface Ownership at the Proposed Moore Ranch Project 
Affected Environment 

 3-3 

Figure 3-2. Mineral Rights Ownership at the Proposed Moore Ranch Site 
Affected Environment 

3-4 

to Wyoming Department of Environmental Quality (WDEQ) shows the location of mineral leases 

in Wellfield 2. 

3.2.1.1 Existing Uses 

The proposed license area for the Moore Ranch Project is currently used for growing grass and 

grain for animal feed (pastureland), cattle grazing (rangeland), and for various types of CBM 

and oil and gas extraction, which are classified as a subcategory of rangeland. There are no 

other known land uses within the proposed Moore Ranch Project, or within a 3.2-km [2-mi] 

radius surrounding the property boundaries. 

The proposed facility would be accessed from the east via State Highway (SR) 59 and SR 50, to 

SR 387 and from the west via Interstate (I)-25, to SR 259, to SR 387. The main access road 

connecting the proposed Moore Ranch Project with SR 387 is located in T42N, R75W, Section 

27. Detailed discussion on transportation routes is provided in Section 3.3 of this SEIS. 

3.2.1.2 Rangeland and Pastureland 

Ranching is the predominant land use on and in the vicinity of the proposed Moore Ranch 

Project. Approximately 2,326 ha [5,748 ac] of land is used as rangeland supporting herds of 

cattle and sheep which graze among large herds of deer and antelope. Currently, an estimated 

544 ha [1,344 ac] of land is being used as pastureland within the proposed Moore Ranch 

Project (EMC, 2007b). SR 387 is the only major transportation route that bisects the northern 

portions of the proposed Moore Ranch Project (see Figure 2-1). 

3.2.1.3 Minerals and Energy 

Uranium exploration has occurred in this portion of the Powder River Basin since the 1950s, 

and CBM development began in the 1980s. With the advancements in technology, 

development and production of CBM has substantially increased in the Powder River Basin 

since the mid-1990s (BLM, 2003). There were 465 wells located on or within a 3.2-km [2-mi] 

radius of the proposed Moore Ranch Project as of June 2009 for use as CBM or stock CBM 

wells (Uranium One, 2009b). These energy extraction facilities have attendant infrastructure 

systems, including pipelines, wellfields, and utility lines that occupy the land surface and the 

subsurface in the vicinity of the proposed Moore Ranch Project. As shown in Figure 3-3, there 

is approximately 15 km [10 mi] of either crude oil or natural gas pipeline that crosses the 

proposed Moore Ranch Project. However, no pipelines are located in areas where earthmoving 

activities would occur as part of the proposed action or alternatives. Approximately 64 km 

[40 mi] of either crude oil or natural gas pipeline occurs within a 3.2-km [2-mi] radius of the 

proposed Moore Ranch Project, as shown in Figure 3-3. 

3.3 Transportation 

As noted in the GEIS, the operation of ISR facilities has historically relied on roads for 

transportation of goods and personnel. Local roads are used to transport construction 

equipment and materials to support facility and wellfield construction activities (NRC, 2009a). 

The proposed Moore Ranch Project is located in an area served by two four-lane interstate 

highways. I-25, which is located approximately 48 km [30 mi] west of the proposed Moore 
Affected Environment 

 3-5 

Ranch Project, extends north from Colorado, terminating where it merges with I-90 at Buffalo, 

Wyoming, about 120 mi to the northwest of the proposed Moore Ranch Project (Figure 1-1). 

Figure 3-3. Land Use in the Vicinity of the Proposed Moore Ranch Project 
Affected Environment 

3-6 

The primary transportation route to the proposed Moore Ranch Project from nearby 

communities would be via SR 387, a bidirectional (two-lane, opposing travel), asphalt-paved 

highway that connects the proposed license area to regional population and economic centers 

along I-25 to the west and SR 59 to the east (Uranium One, 2009b). The City of Gillette is 

located approximately 80 km [50 mi] northeast of the proposed Moore Ranch Project. SR 387 

runs east-west from the town of Wright to I-25 at the town of Midwest, bisecting the northern 

portion of the proposed license area (Figure 1-1). SR 50 commences in Gillette and runs to the 

south and connects with SR 387 approximately 6.4 km [4 mi] east of the proposed Moore Ranch 

Project. SR 59 connects with SR 387 at Wright, located approximately 48 km [30 mi] east of the 

proposed Moore Ranch Project. Both SR 50 and SR 59 are also bidirectional, asphalt-paved 

highways in good to average condition. The lanes on SR 50, 59, and 387 are 3.6 m [12 ft] wide, 

and the total width of paved roadway ranges from 8 to 12 m [26 to 40 ft], based on the varying 

width of the paved shoulder (Uranium One, 2009b). 

All state highways adjacent to the proposed Moore Ranch Project are access controlled and 

maintained year round by the Wyoming Department of Transportation. Highway maintenance 

includes snow removal, debris removal, and road repairs (Uranium One, 2009b). Onsite road 

maintenance would include periodic grading of the primary access roads, snow plowing, 

applying water or other agents for controlling fugitive dust emissions, and regular inspections to 

ensure the adequacy of erosion control measures (Uranium One, 2009b). 

Approximately 7.2 km [4.5 mi] of SR 387 crosses the northern portion of the proposed Moore 

Ranch Project (Figure 2-1). Numerous county roads provide access to public and private lands, 

many of which consist of maintained gravel surfaces. Unimproved or minimally improved 

private roads are common. Brown Road, an existing gravel road, accesses the general location 

selected for construction of the central plant and is currently used for agricultural and oil and gas 

activities in the area. The proposed location of the central plant would be approximately 0.8 km 

[0.5 mi] from the intersection of SR 387 and Brown Road. Brown Road may require minor 

improvements to accommodate trucks and heavy equipment access during the construction and 

operation phases of the proposed Moore Ranch Project. In addition, approximately 1.2 km 

[0.8 mi] of gravel roads would be constructed to connect the central plant to Brown Road, to 

connect Wellfield 1 to Brown Road, and to connect Wellfield 2 to an existing access road 

(Figure 2-2). Other roads enter the proposed Moore Ranch Project, but none provide access to 

residences or other public destinations. 

Annual average daily traffic counts for trucks using SR 387 in the vicinity of the proposed Moore 

Ranch Project ranged from 220 to 410 trucks in 2006. The figure for all vehicle types was 

970 to 3,130 per day (Uranium One, 2009b). For SR 50, the annual average daily traffic count 

for all vehicles was 550 in 1999 (BLM, 2003). No traffic count data are available for Brown 

Road. Table 3-1 provides traffic count data for the surrounding state routes. 

3.4 Geology and Soils 

The proposed Moore Ranch Project is located in the Pumpkin Buttes Uranium District in the 

Powder River Basin within the Wyoming East Uranium Milling Region evaluated in the GEIS 

(NRC, 2009a). Section 3.3 of the GEIS provides a general description of the geology and soils 

within this area. Section 3.4.1 of this SEIS provides a site-specific discussion of the geology 

and soils in the vicinity of the proposed Moore Ranch Project. 
Affected Environment 

 3-7 

Table 3-1. Annual Average Daily Traffic Counts 

Route 

Name Description 

All Vehicles Trucks 

1998 1999 2005 2006 2005 2006 

SR 59 Gillette South of 

Urban Limits 18,690 17,760 

SR 59 Johnson-Campbell 

County Line 1,110 1,210 

SR 59 Wright 2,150 2,250 3,630 3,930 690 750 

SR 59 Converse-Campbell 

County Line 1,350 1,450 

SR 387 Johnson-Campbell 

County Line 1,110 1,210 

SR 387 Between SR 50 and 

SR 59 970–3,130 970–3,130 210–410 220–410 

Source: Uranium One, 2009b

The Powder River Basin is a large structural and topographic depression that parallels the 

Rocky Mountains. The basin is bounded to the north by the Miles City Arch in southeastern 

Montana, to the south by the Hartville Uplift and the Laramie Range, to the east by the Black 

Hills, and to the west by the Big Horn Mountains and the Casper Arch. As indicated in the 

GEIS, the basin was formed during the Laramide Orogeny (mountain-building era) approximate 

50 to 65 million years ago (NRC, 2009a). Rapidly subsiding portions of the basin received thick 

clastic wedges (i.e., made of fragments of other rocks) of predominantly arkosic sediment 

(i.e., sediments containing a significant fraction of feldspar), while large more slowly subsiding 

portions of the basin received a greater proportion of paludal (marsh) and lacustrine 

(lake) sediments. 

The sedimentary rock sequence in the basin ranges in age from recent (Holocene) to early 

Paleozoic (Cambrian–500 million to 600 million years ago) and overlies a basement complex of 

Precambrian (more than a billion years old) igneous and metamorphic rocks. As noted in the 

GEIS, erosion has removed the upper part of the sedimentary sequence in the Powder River 

Basin, leaving only the Tertiary-aged White River, Wasatch, and Fort Union Formations. The 

White River Formation is of the Oligocene age and is the shallowest Tertiary unit in the Powder 

River Basin. It is underlain by the Wasatch, which is of the Eocene Age. The Paleocene age 

Fort Union Formation directly underlies the Wasatch Formation, which directly overlies the 

Cretaceous Lance Formation. Figure 3.3-5 of the GEIS provides a stratigraphic section of 

Tertiary-aged formations in the Wyoming East Uranium Milling Region (NRC, 2009a). The 

Tertiary-aged Wasatch Formation hosts the uranium deposits proposed for mining at the 

proposed Moore Ranch Project. 
Affected Environment 

3-8 

3.4.1 Geology 

The early Eocene Wasatch Formation unconformably overlies the Fort Union Formation around 

the margins of the Powder River Basin. However, within the basin center and in the vicinity of 

the proposed Moore Ranch Project, the two formations are conformable. The relative amount of 

coarse, permeable clastics increases near the top of the Fort Union Formation, and the 

overlying Wasatch Formation contains numerous sandstone beds that can be correlatable over 

wide areas. Except in isolated areas of the Powder River Basin, the Wasatch-Fort Union 

contact is arbitrarily set at the top of either thick coals or a thick sequence of clays and silts. 

The applicant considers the top of the Roland coal as the boundary of the Wasatch Formation at 

the proposed Moore Ranch Project. 

The Wasatch Formation reaches a maximum thickness of about 488 m [1,600 ft] and outcrops 

at the surface in the proposed license area. The Wasatch Formation is composed of 

interbedded sandstones, siltstones, clays, and coals and was deposited in a fluvial (river) 

environment. These sandstone horizons are the host rock for several uranium deposits in the 

southern Powder River Basin. Within the proposed Moore Ranch Project, mineralization occurs 

in a 15 to 30-m [50- to 100-ft] thick sandstone lens, which extends over an area of several 

townships. This formation dips gently to the northwest from 1 degree to 21⁄2 degrees in the 

southern part of the Powder River Basin (EMC, 2007b). 

Locally, remnants of the overlying White River Formation are known to occur on top of the 

Pumpkin Buttes. A basal conglomerate forms the resistant cap rock on top of the buttes. This 

formation is not known to contain significant uranium resources in this area. 

Detailed stratigraphic analysis of a portion of the Wasatch Formation was performed because 

the target ore zone occurs within the sands in this formation. The site-specific stratigraphy has 

been characterized based on subsurface data collected from thousands of well borings in and 

around the proposed license area in the 1970s and 1980s. This data is associated with the 

Conoco, Inc. application to the U.S. Nuclear Regulatory Commission (NRC) to construct and 

operate a uranium mill associated with an open-pit mine in the same area being evaluated for 

the proposed Moore Ranch Project (NRC, 1982). This data was supplemented with data 

collected from additional applicant well borings drilled in late 2006 and early 2008. The 

underlying Fort Union Formation was not studied in detail because it would not be influenced by 

the project. The top of the Roland Coal, which separates the Wasatch Formation, from the 

underlying Fort Union Formation is approximately 335 m [1,100 ft] thick across the proposed 

Moore Ranch Project. 

The applicant adopted the Conoco, Inc. nomenclature for the hydrostratigraphic units of interest 

within the proposed Moore Ranch Project. Sands occurring stratigraphically above the Roland 

Coal are numbered, increasing toward the surface. Figure 3-4 illustrates the stratigraphic 

sequence at the proposed Moore Ranch Project. The applicant generated 13 geologic cross 

sections to characterize the vertical and lateral stratigraphy at the site. Figure 3-5 illustrates an 

isopach map of the 70 Sand showing the areal distribution and thickness of the unit containing 

the ore zone. Figure 3-6 illustrates the stratigraphy in Wellfield 1, and Figure 3-7 illustrates the 

stratigraphy in Wellfield 2. The applicant technical report provides figures and maps showing 

the areal distribution and thickness of overlying and underlying sand and shale sequences 

(EMC, 2007b). 
Affected Environment 

 3-9 

The 40 and 50 Sands that occur immediately above the Roland Coal are regionally extensive 

and considered significant aquifers (EMC, 2007b). The approximate thickness of the 40 and 

Figure 3-4. Generalized Stratigraphy Sequence Showing the 70 Sand Ore Production in 

the Wasatch Formation 
Affected Environment 

3-10 

Figure 3-5. Isopach Map Showing the Thickness of the 70 Sand 

50 Sands within the proposed Moore Ranch Project are 24 and 27 m [80 and 90 ft]. A 1.5 to 

12 m [5 to 40 ft] thick shale or mudstone separates the 40 and 50 Sands. The overlying 

58 Sand varies in thickness from 1.5 to 24 m (5 to 80 ft) across the proposed project area. The 

overlying 60 Sand is approximately 30 m [100 ft] thick, is continuous throughout the proposed 

project area, and separated from the 58 Sand by about 1.5 to 21 m [5 to 70 ft] of shale and 

mudstone. The 68 Sand is the first sand underlying the 70 Sand, which contains the economic 

ore deposits in the proposed Moore Ranch Project. The 68 Sand is separated from the 60 Sand 

by 0 to 8 m [0 to 25 ft] of shale or mudstone. The 68 Sand ranges from to 12 to 30 m [40 to 

100 ft] across the proposed license area and coalesces with the 60 Sand on the west side of the 

proposed license area. The 70 Sand, the proposed ore production zone, coalesces with the 

68 Sand in Wellfield 2. The 70 Sand is laterally extensive and ranges from 12 m to 37 m [40 to 

120 ft] thick across the proposed Moore Ranch Project. The dip is generally less than one 

Source: modified from Application for U.S. 

NRC Source Material License Moore Ranch 

Uranium Project, Environmental Report 
Affected Environment 

 3-11 

Figure 3-6. West-East Stratigraphic Cross Section of Wellfield 1 
Affected Environment 

3-12 

Figure 3-7. West-East Stratigraphic Cross Section of Wellfield 2 
Affected Environment 

 3-13 

degree toward the northwest. A coal layer, referred to as the E Coal, that ranges in thickness 

from 0.3 to 0.9 m 

[1 to 3 ft] typically occurs a few feet above the top of the 70 Sand. The 72 Sand overlies the 

70 Sand and is the shallowest sand occurring across the proposed project area. The 70 Sand 

is separated from the overlying 72 Sand by a shale sequence ranging in thickness from a few 

feet to 49 m [160 ft] in some areas. 

The applicant has proposed two different injection zones for use in waste disposal at the 

proposed Moore Ranch Project. The applicant has submitted an Underground Injection Control 

(UIC) permit application to WDEQ that evaluates injection into the Teapot-Teckla-Parkman 

Sandstones, at a depth ranging from 2,413 to 2,929 m [7,916 to 9,610 ft] below ground surface 

and the Lance Formation and Fox Hills Sandstone, at a depth ranging from 1,128 to 2,286 m 

(3,700 to 7,500 ft) below ground surface. Both of these formations are thousands of feet deeper 

than the 70 Sand ore production zone. 

3.4.2 Soils 

The applicant performed a soil survey of the proposed Moore Ranch Project in 2007 to define 

the existing topsoil resource and determine the extent, availability, and suitability of soils 

material for use in reclamation. A site-specific map was generated to show the areal distribution 

of different soil types, and soil map units and soil series descriptions were included in the 

applicant environmental report (EMC, 2007b). The general topography of the proposed Moore 

Ranch Project includes rolling hills and ridges, as well as drainages. Soils occurring in this area 

were generally fine-textured throughout with patches of sandy loam on upland areas. Finetextured soils occur near or in drainages. The proposed project area contains deep soils on 

lower toe slopes and flat areas near drainages; shallow and moderately deep soils occur on 

upland ridges and shoulder slopes. Soils on the proposed Moore Ranch Project are typical for 

semiarid grasslands and shrublands in the Western United States. Most soils have some 

suitable topsoil. The primary limiting factor is texture. 

The 2007 soil fieldwork characterized the soils within the proposed license area with respect to 

topsoil salvage depths and related physical and chemical properties. Based on data from 

samples collected from within the proposed license area, from field observations and knowledge 

of the soils in southern Campbell County, an approximate salvage depth for each map series 

was identified. These salvage depths ranged from 0.24 m to 1.5 m [0.8 to 5 ft]. An average 

salvage topsoil depth over the proposed Moore Ranch Project was estimated as 1.1 m [3.6 ft]. 

The potential for wind and water erosion of soil within the proposed Moore Ranch Project varies 

from slight to severe and is mainly a factor of the texture and organic content of the surface soil. 

Because the surface soils throughout the proposed Moore Ranch Project have a fine loamy and 

sandy texture, the soils are more susceptible to erosion from wind than water. 

No prime farmland has been documented at the proposed Moore Ranch Project, based on a 

reconnaissance survey by the National Resources Conservation Service. 
Affected Environment 

3-14 

3.5 Water Resources 

3.5.1 Surface Waters and Wetlands 

As noted in Section 3.3.4.1 of the GEIS, the Wyoming East Uranium Milling Region 

encompasses 10 primary watersheds (NRC, 2009a). The Antelope Creek Watershed drains the 

location for the proposed Moore Ranch Project. Surface water features, both in the vicinity of 

and within the proposed license area, include intermittent streams that flow to the southeast 

ultimately to the Cheyenne River. Water bodies within the Wyoming East Uranium Milling 

Region are mainly classified as Class 3B surface waters, according to the state classification of 

designated uses. The designated uses for Class 3B surface waters are recreation, aquatic life 

other than fish, wildlife, agriculture, industry, and scenic value. 

3.5.1.1 Drainage Basins 

The proposed Moore Ranch Project area lies within the Ninemile Creek drainage basin, which 

covers an area of 163 km2

 [63 mi2]. Ninemile Creek is a tributary to Antelope Creek, which is a 

tributary of the South Cheyenne River, which ultimately flows to the Missouri River. Seven 

subwatersheds occur within the proposed license area and are associated with Ninemile Creek, 

Simmons Draw, Pine Tree Draw and their tributaries (Figure 3-8). Each of these 

subwatersheds drains to the southeast; Simmons Draw and Pine Tree Draw flow into Ninemile 

Creek. As shown in Figure 3-8, Wash #1 is an intermittent tributary to Simmons Draw and flows 

to the west of Wellfield 1. Upper Wash #2 is another intermittent stream to Simmons Draw, and 

it bisects the central portion of Wellfield 2. 

3.5.1.2 Surface Water Features 

The arid conditions in eastern Wyoming limit the formation of year-round surface water and 

wetland features. Regional annual rainfall averages approximately 35.5 cm [14 in] per year, 

while annual lake evaporation may reach 101 cm [40 in] per year. Surface waters, particularly 

in the upper headwaters of watersheds, are seasonal in nature, responding to springtime snow 

melt. In some instances, surface waters may manifest intermittent flow conditions in response 

to extreme rainfall events. Otherwise, rainfall is normally absorbed into the soil. 

Despite the arid conditions and headwater setting, linear wetland features and nine small, 

artificial ponds persist and are scattered across the proposed Moore Ranch Project within 

low lying drainages in response to the CBM operations that occur throughout the area. 

CBM-produced water in the vicinity of the proposed Moore Ranch Project is estimated to 

contribute 9 to 52 percent of surface flows and could result in perennial flows in formerly 

intermittent channels (Uranium One, 2009a). Approximately 31 CBM wells occur within the 

proposed license area, with another 101 located within a 3.2-km [2-mi] radius of the boundary of 

the proposed Moore Ranch Project (Figure 3-9). These operations discharge extracted 

groundwater onto the surface and are responsible for sustaining the existing surface water 

features (wetlands and ponds). 

The CBM discharges are monitored through three Wyoming Pollutant Discharge Elimination 

Systems (WYPDES permits) issued to operators located either within or adjacent to the 

proposed license area. Surface water flow is discussed in Section 3.5.1.3 of this SEIS. 
Affected Environment 

 3-15 

 

Figure 3-8. Drainage Basin and Sub-Watersheds at the Proposed Moore Ranch Project 
Affected Environment 

3-16 

Figure 3-9. CBM Production Near the Proposed Moore Ranch Project 
Affected Environment 

 3-17 

3.5.1.2.1 Intermittent Streams 

Ninemile Creek, Simmons Draw, and Pine Tree Draw are the dominant streams within the 

proposed license area. Each of these intermittent streams collect surface water runoff from the 

numerous drainages or “washes” carved into the landscape (Figure 3-8). Because these 

channels remain dry most of the year, the channels contain upland vegetation growth. 

Hydrophytes (plants adapted to saturated soil conditions) persist yearlong only in short reaches 

where near-surface soil saturation extends well into the summer months from discharge from 

CBM and livestock wells. As previously noted, none of these intermittent streams drain the 

basins that encompass the proposed wellfields, except for Upper Wash #1 and Upper Wash #2. 

The stream channels on the proposed Moore Ranch Project are briefly described in the 

following text. For purposes of this document, unnamed channels are given designations such 

as “Tributary A” or “Wash #1.” Subtitle designations such as “Upper” and “Lower” relate to 

subwatersheds, based on water quality sampling stations discussed later in Section 3.5.1.4. A 

map of the stream channels and contributing watersheds is provided in Figure 3-8. 

Ninemile Creek flows through approximately 2.4 km [1.5 mi] of the southwest corner of the 

proposed license area and drains a total area of 16,316 ha [63 mi2

]. The elevation difference 

from the headwaters to the mouth of Ninemile Creek is 186 m [610 ft] over an approximate 

channel length of 32 km [20 mi], with an average gradient of 0.6 to 0.7 percent. Simmons Draw, 

a tributary to Ninemile Creek, flows to the southeast through the western boundary of the 

proposed license area, approximately 13.8 km [6.8 mi] at a gradient of 0.7 percent, with a 

drainage area of 21 km2

 [8.1 mi2]. The total basin elevation difference is 79 m [260 ft]. 

Simmons Draw has two main tributaries: Simmons Draw Tributary A (Wash #1) and Simmons 

Draw Tributary B (Wash #2). Wash #1 has a length of approximately 4.5 km [2.8 mi] with a 1.4 

percent gradient; Tributary B (subdivided into Upper Wash #2 and Lower Wash #2) has 

drainage areas of 4.9 and 2.5 km2 [1.9 and 0.95 mi2

], with channel lengths of 0.74 and 2.1 km 

[0.46 and 1.3 mi] and average gradients of 0.012 and 0.007 ft/ft. Each of these tributaries are 

intermittent with fragmented wetlands and ponds based primarily on discharges from CBM and 

livestock wells. 

Pine Tree Draw has a drainage area of 124 ha [8.2 mi2

] and drains the eastern side of the 

proposed license area. The total basin elevation difference is 110 m [360 ft] over a channel 

length of approximately 12.2 km [7.6 mi], resulting in a gradient near 0.9 percent. Pine Tree 

Draw Tributary A has a drainage area of 4.6 km2

 [1.8 mi2], a channel length of 5.1 km [3.2 mi], 

and an average gradient of 0.014 ft/ft. 

Pine Tree Spring, a relatively short tributary to Pine Tree Draw, drains the far eastern side of the 

proposed license area and has a channel length of approximately 1.1 km [0.7 mi]. 

3.5.1.2.2 Ponds 

Nine small, disconnected artificial ponds (reservoirs) are scattered across the proposed license 

area and occur within the channels of Ninemile Creek, Simmons Draw, Pine Tree Draw, and 

their principal tributaries. These reservoirs have been permitted through the Wyoming State 

Engineers Office (WSEO) within the proposed license area because they could be impacted by 

CBM-produced water discharge. The ponds are classified as palustrine unconsolidated bottom, 

in accordance with the Cowardin classification system (Cowardin, et al., 1978), and are 

generally less than 0.4 ha [1 ac] in size. These surface water features result from accumulation 
Affected Environment 

3-18 

behind structures (dams and dikes), in excavated pits, or from the discharge of pumped 

groundwater from CBM operations, windmills, or livestock watering tanks. 

3.5.1.3 Surface Water Flow 

The CBM-produced water in the vicinity of the proposed Moore Ranch Project is estimated to 

contribute 9 to 52 percent of the surface water flows and could result in perennial flows in 

formerly intermittent channels (Uranium One, 2009a). The CBM discharges are monitored 

through three WYPDES permits issued to CBM operators located either within or adjacent to the 

proposed license area. Thirty outfalls are monitored under the e WYPDES permits; 7 outfalls 

are located upstream of the proposed Moore Ranch Project, and the remaining 22 outfalls are 

located on the proposed Moore Ranch Project. Eight of these locations are in the vicinity of 

Wellfield 1 and Wellfield 2. 

The average historic discharge rate of the CBM unit with the most permitted outfalls on the 

proposed Moore Ranch Project was 106,061 L/day [28,800 gal/day] over a period of eight years 

(2000 to 2008) compared to a maximum permitted limit of 2.6 × 106

 L/day [680,000 gal/day]. 

Flow from this CBM unit is anticipated to be less than 22,727 L/day [6,000 gal/day] by the year 

2013 (EMC, 2007b). The average discharge from outfalls located in the vicinity (which were not 

dry) was approximately 57,197 L/day [15,100 gal/day]. 

Peak flood flows were also calculated for each of the drainage basins on the proposed Moore 

Ranch Project, as part of the Draft EIS for the Sand Rock Mill Project, docket No. 40-8743 

(NRC, 1982). The Draft EIS calculations were reviewed to determine the validity of the 

analytical methods and estimate surface water runoff. The applicant used different methods to 

estimate peak flood discharges, as described in their technical report (EMC, 2007b). Based on 

this analysis, it was determined that Wellfield 1 and the central plant were located higher than 

any region that could potentially be flooded. However, Wellfield 2 could potentially be flooded 

by a 100-year flood event. Therefore, the applicant proposed to minimize damage to 

infrastructure in a potential flooding event by avoiding installation in main channels of drainages; 

sizing culverts properly; and implementing best management practices for embankments, 

culverts, and drainage crossings. 

3.5.1.4 Surface Water Quality 

The proposed Moore Ranch Project lies entirely within the Antelope Creek drainage basin as 

shown in Figure 3-8. The EPA listed Antelope Creek and its tributaries as unimpaired surface 

waters. The WDEQ classifies Antelope Creek as a Class 3B surface water. This classification 

of waters includes intermittent and ephemeral streams that are able to support aquatic 

communities but are not known to support fish populations or be used as a drinking water 

supply. Class 3B waters may also support recreation, agriculture, industry, and provide 

scenic value. 

All surface water sample locations within the proposed Moore Ranch Project are characterized 

as existing stock ponds or areas in drainages where ponding occurs. Water ponded at all 

surface water locations are typically fed by springtime snow melt runoff or high intensity rain 

events in the summer. 

As noted above, 31 CBM outfalls occur in the proposed license area under 3 WYPDES permits. 

These permits monitor maximum flow, pH, specific conductance, chlorides, total recoverable 
Affected Environment 

 3-19 

arsenic and barium, and dissolved iron. Other chemical species are also monitored, including 

total radium-226. 

Three sets of surface water samples collected during fall 2006, early spring 2007, and late 

spring 2007 were analyzed from nine locations within the proposed Moore Ranch Project, as 

shown on Figure 3-8. No surface water samples were collected from locations MRSW-10 and 

MRSW-11, which were both dry during the above sampling events. Table 3-2 summarizes the 

sample results. 

The sample results indicate a seasonal variability in surface water quality largely influenced by 

the CBM operations in the area. The surface water in ponds typically exhibit saline 

characteristics of CBM surface discharge (higher conductivity, total dissolved solids (TDSs), and 

bicarbonate readings) in the summer and fall when there is less precipitation. The surface 

water sample results indicate that surface waters are basic, with numerous samples exceeding 

the CBM-permitted pH limit of 9.0. The average of all pH readings during all sampling periods 

was 9.08, which is above the Wyoming Class I (domestic use), Class II (agricultural use), and 

Class III (livestock use) standards. Although sampling for lead appears to exceed the 

0.015 mg/L Class I standard, the minimal detection limit in the laboratory for lead was set at 

0.05 mg/L for the fall 2006 samples. Therefore, the actual lead concentration fell below the 

0.05 mg/L detection limit. Subsequent sampling indicated lead concentrations below the lead 

Class I standard. 

As expected, the water samples taken during the fall months at CBM discharge locations 

commonly exhibited significantly higher values for bicarbonate, carbonate, chloride, 

conductivity, fluoride, TDS, gross alpha, gross beta, nitrogen, arsenic, potassium, magnesium, 

and sodium compared to samples taken during the spring months, indicating that surface water 

quality improves during the springtime as a result of diluted surface water from snow melt or 

large precipitation events, or both.

3.5.1.5 Wetlands 

Wetlands are areas that are inundated or saturated by surface or groundwater at a frequency 

and duration to support, and under normal circumstances do support, a prevalence of 

vegetation typically adapted to life in saturated soil conditions (USACE, 1987). 

A wetland delineation was performed, as part of the baseline assessment for the proposed 

Moore Ranch Project, using the methodologies outlined in the Regional Supplement to the 

U.S. Army Corps of Engineers (USACE) Wetland Delineation Manual: Great Plains Region 

(2006) to support reclamation planning and wellfield infrastructure (EMC, 2007b). The wetland 

survey methodology is described in Energy Metal Corporation (EMC) (2007b). Identification of 

potential wetlands was based on visual assessment of vegetation, hydrology indicators, and 

intrusive soil sampling to determine the presence of wetland criteria indicators (EMC, 2007b). 

The proposed license area was found to contain nine wetlands classified as palustrine emergent 

based on the Cowardin, et al. (1979) wetland classification system (EMC, 2007b). Emergent 

wetlands are located in channels and total 12.6 ha [31.2 ac]. Similarly, nine ponds classified as 

palustrine open water were delineated and total 1.7 ha [4.1 ac]. These wetlands and ponds are 

shown in Figure 3-10. 
Affected Environment 

3-20 

Table 3-2. Surface Water Quality at the Proposed Moore Ranch Project 

Sample 

Parameters 

MRSW-1+MRSW-2 MRSW-3 MRSW-4 MRSW-5 MRSW-6#MRSW-7#

MRSW-8 MRSW-9#

Bicarbonate as 

HCO3,mg/l 782 763 161 199 1064 457 665 402 99 

Carbonate as 

CO3, mg/L 37 36 7 21 63 61 17 580 14 

Chloride, mg/L 5 5 5 11 8 3 6 8 2 

Conductivity, 

umhos/cm 1305 1170 694 1087 1843 839 979 1528 204 

Fluoride, mg/L 0.5 0.6 0.5 0.5 0.7 0.5 0.5 1.1 0.2 

pH, s.u. 8.99 8.96 9.10 9.37 8.80 9 9 9.40 9 

Solids, Total 

Dissolved TDS @ 

180C, mg/L 801 729 327 711 1159 540 646 1017 122 

Sulfate, mg/L 14 4 219 350.33 62 6 13 8 4 

Gross Alpha, pci/L 3.9 2.25 10.3 4.05 6.7 1.1 5.4 3.35 1 

Gross Beta, pci/L 16.05 11.85 11.6 9.75 21.85 6.9 13.1 15.5 2 

Lead 210 pci/L* 57.3* <1.0 <1.0 1.0 4.0 <1.0 <1.0 <1.0 4.8 

Polonium 210 pci/L <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 

Radium 226, pci/L <0.2 <0.2 <0.2 0.2 1.3 0.9 <0.2 <0.2 <0.2 

Radium 228, pci/L <1.0 <1.0 1.3 1.0 <1.0 <1.0 <1.0 <1.0 <1.0 

Thorium 230, pci/L <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 

Nitrogen, Ammonia 

as N,mg/L 0.12 <0.05 0.08 0.27 0.20 0.14 0.09 0.33 <0.05 

Nitrogen, 

Nitrate+Nitrite as 

N,mg/L 0.3 <0.1 <0.1 0.1 0.4 <0.1 <0.1 <0.1 <0.1 

Aluminum, mg/L 0.6 0.1 <0.1 0.1 <0.1 0.7 0.3 0.1 0.2 

Arsenic mg/L 0.003 0.002 0.002 0.006 0.005 0.004 0.004 0.011 0. 002 

Barium, mg/L 0.4 0.5 0.1 0.1 0.2 0.3 0.4 0.3 <0.1 
Affected Environment 

 3-21 

Table 3-2. Surface Water Quality at the Proposed Moore Ranch Project 

Sample 

Parameters 

MRSW-1+MRSW-2 MRSW-3 MRSW-4 MRSW-5 MRSW-6#MRSW-7#

MRSW-8 MRSW-9#

Boron, mg/L <0.1 <0.1 <0.1 0.1 0.1 <0.1 <1.0 0.1 <0.1 

Cadmium, mg/L <0.005 <0.005 

<0.00

5 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 

Calcium, mg/L 21 17 50 26 32 18 21 10 14 

Chromium, mg/L <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 

Copper, mg/L <0.01 0.02 <0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Iron, mg/L 0.25 0.11 0.08 0.13 0.35 0.33 0.65 0.32 0.11 

Lead, mg/L <0.05 0.019 <0.05 0.050 <0.05 0.001 <0.001 <0.05 <0.001 

Magnesium, mg/L 35 30 16 22 54 13 14 26 5 

Manganese, mg/L <0.01 0.02 <0.01 0.02 0.03 0.02 0.02 0.01 <0.01 

Mercury, mg/L <0.001 <0.001 

<0.00

1 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 

Molybdenum mg/l <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

Nickel, mg/L <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 

Potassium, mg/L 12 10 7 8 16 7 9 12 5 

Selenium, mg/L 

<0.000

2 <0.0002 0.001 0.001 0.002 <0.002 <0.001 0.0013 <0.001 

Silica, mg/L 5.1 2.6 4.8 6.8 7.5 7.6 8.0 5.6 5.2 

Sodium, mg/L 244 238 84 189 348 155 218 369 22 

Uranium, mg/L 0.0022 

0.00046

7 

0.009

7 0.0044 0.0022 0.0003 0.0005 0.0020 0.0017 

Vanadium, mg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

Zinc, mg/L <0.01 0.015 <0.01 0.010 0.01 0.01 <0.01 <0.01 <0.01 

Iron, TOTAL mg/L 0.65 0.157 0.22 0.16 0.45 0.62 0.69 0.374 0.14 

Manganese, 

TOTAL mg/L 0.02 0.013 0.015 0.05 0.04 0.03 0.03 0.01 <0.01 

Lead 210, 

suspended pci/L <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 
Affected Environment 

3-22 

Table 3-2. Surface Water Quality at the Proposed Moore Ranch Project 

Sample 

Parameters 

MRSW-1+MRSW-2 MRSW-3 MRSW-4 MRSW-5 MRSW-6#MRSW-7#

MRSW-8 MRSW-9#

Polonium 210 

suspended pci/L <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 

Radium 226, 

suspended pci/L <0.2 <0.2 <0.2 <0.2 0.97 0.3 <0.2 <0.2 <0.2 

Thorium 230 

suspended pci/L <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 

Uranium 

suspended, pci/L 

<0.000

3 <0.0003 

<0.00

3 

<0.000

3 

<0.000

3 

<0.000

3 

<0.000

3 <0.003 

<0.000

3 

Source: EMC, 2007b 

Refer to Figure 3-8 for sample locations. 

+ The average of three samples collected from 2006 to 2007 except as noted. 

# The average of two samples collected during either 2006 or 2007. 

* Average contains an anomalous value considered analytical error. 

 No samples collected from MRSW-10 and MRSW-11; location was always dry. 

Wetlands comprise narrow, linear emergent systems within drainages and stream channels, as 

a direct result of CBM and livestock well discharges. Several CBM outfalls also jointly serve as 

livestock watering holes, comprising open water pools located along or within drainages. Some 

of the outfalls and accompanying watering tanks were observed releasing water and influencing 

the presence of wetland parameters. In those drainages where water is released, the wetland 

characteristics are actively present. In those drainages where there is a gradual decrease in the 

volume of CBM water being discharged via the outfalls described in Section 3.5.1.3 of this SEIS, 

the wetland parameters are receding, particularly wetland hydrology and hydrophytic vegetation, 

and upland vegetation is encroaching into the streambeds. 

The wetlands delineated on the proposed Moore Ranch Project include the following systems: 

a single thread confined to the Ninemile Creek channel at the southern end of the proposed 

license area; three systems found within the Simmons Draw channel; one wetland within 

Simmons Draw Tributary A and Simmons Draw Tributary B; and three wetlands within the Pine 

Tree Draw drainage basin, as shown in Figure 3-10. 

On May 10, 2010, the USACE concurred with the applicant’s methods used to identify wetlands 

within the proposed project area and deemed that the methods are consistent with the USACE 

Wetland Delineation Manual and the Great Plains Region supplement (USACE, 2010). This 

verification of wetland delineation is valid for 5 years (until May 10, 2015). Additionally, the 

USACE determined that authorization is not required for any construction activities within 

Wellfield 1. Installation of wells and associated pipelines within wetland areas at Wellfield 2 are 

authorized by Nationwide Permit (NP) 12 (USACE, 2010). WDEQ-specific conditions have 

been incorporated as regional conditions of NP 12. 
Affected Environment 

 3-23 

Figure 3-10. Wetlands Located on the Proposed Moore Ranch Project 
Affected Environment 

3-24 

3.5.2 Groundwater 

3.5.2.1 Regional Groundwater Resources 

As noted in Section 3.3.4.3 of the GEIS, the Powder River Basin where the proposed Moore 

Ranch Project is located is part of the Wyoming East Uranium Milling Region (NRC, 2009a). In 

this region, uranium bearing aquifers are part of the Northern Great Plains regional aquifer 

system, which extends over one-third of Wyoming. 

The Northern Great Plains aquifer system consists of five major aquifers, which from shallowest 

to deepest are designated as the Lower Tertiary, Upper Cretaceous, Lower Cretaceous, Upper 

Paleozoic, and Lower Paleozoic aquifers. The shallowest Lower Tertiary aquifers are located in 

sandstone beds within the Wasatch and Fort Union Formations, which are up to 1,400 m 

[4,600 ft] thick. These aquifers act as important regional water supplies for drinking water and 

livestock. Below them are the Upper Cretaceous aquifers, which are found in sandstone beds 

in the Lance, Hell Creek, and Fox Hills sandstones. These formations when combined are up to 

1,070 m [3,850 ft] thick. The Fox Hills Sandstone is a significant water source. The next Lower 

Cretaceous aquifers are located beneath a regional thick sequence of shales known as the 

Pierre, Lewis, and Steele shales. Water yielding aquifers in the Lower Cretaceous are 

widespread and include the Muddy Sandstone and the Inyan Kara in the Powder River Basin. 

These Lower Cretaceous aquifers contain little freshwater. The Upper Paleozoic aquifers are 

the Madison and the Tensleep Limestone in the western portion of the Powder River Basin and 

the Minnelusa Formation in the eastern portion. They are deeply buried and contain little to no 

freshwater. The Lower Paleozoic aquifers are the Winnipeg sandstone, Red River limestone, 

and Stonewall limestone formations. They are not typically used for water supplies because 

they are very deep and slightly saline to moderately saline in the southern extent and contain 

freshwater only in a small area in north-central Wyoming. 

3.5.2.2 Local Groundwater Resources 

The uranium-bearing aquifer at the proposed Moore Ranch Project is located in the Wasatch 

Formation, which is part of the shallow Lower Tertiary aquifer system. The Wasatch formation 

is described as an arkosic fine- to coarse-grained sandstone with siltstone, claystone, and 

coals. The contact between the underlying Fort Union Formation and the Wasatch Formation is 

gradational in the vicinity of Moore Ranch and is generally arbitrarily set at the top of the thicker 

coals or thick sequence of clays and silts. The applicant has identified the boundary between 

the two formations to be the top of the Roland Coal. The Wasatch Formation total thickness 

ranges from 244 to 335 m [800 to 1,100 ft] in the proposed project area. In the southern portion 

of the Powder River Basin, the Wasatch Formation generally dips to the northwest at 1.0 to 

2.5 degrees. 

There are commonly multiple water-bearing sands within the Wasatch Formation. Due to their 

higher permeability, these water-bearing sands provide the primary sources for groundwater 

withdrawal. Groundwater within the Wasatch aquifers is typically under confined (artesian) 

conditions, although locally unconfined conditions exist. Well yields from the Wasatch 

Formation in the southern part of the Powder River Basin where the site is located are reported 

to be as high as 1,900 Lpm [500 gpm]. The overall flow of groundwater in the shallow aquifers 

in the vicinity of the proposed Moore Ranch Project is toward the Powder River Basin to the 

north-northwest. 
Affected Environment 

 3-25 

As previously discussed in Section 3.4.1, the applicant has adopted the nomenclature used by 

Conoco, Inc., for the hydrostratigraphic units of interest within the proposed Moore Ranch 

Project. Sands above the Roland Coal are numbered, increasing upward. The 40 and 

50 Sands lie immediately above the Roland Coal and are regionally extensive sands that are 

considered significant aquifers. The approximate thickness of the 40 and 50 Sands in the 

proposed license area are 24 to 27 m [80 and 90 ft]. The 58 Sand varies in thickness from 

1.5 to 24 m [5 to 80 ft]. The 60 Sand is approximately 30 m [100 ft] thick and is continuous 

throughout the proposed project area. It is separated from the 58 Sand by about 1.5 to 21 m 

[5 to 70 ft] of shale and mudstone. The 68 Sand is the first sand underlying the 70 Sand, which 

contains the economic ore deposits in the area. The 68 Sand ranges from 12 to 30 m [40 to 

100 ft] across the proposed license area and coalesces with the 60 Sand on the west side of the 

proposed license area. The 70 Sand is the proposed ore production zone and coalesces with 

the 68 Sand in one of the proposed wellfields. The 72 Sand overlies the 70 Sand and is the 

shallowest sand over the majority of the proposed license area. The 70 Sand is separated from 

the overlying 72 Sand by a continuous shale layer ranging in thickness from 1 to 49 m [3.3 to 

160 ft] in some areas. Over small portions of the proposed license area, the 80 Sand overlies 

the 72 Sand. 

3.5.2.3 Uranium-Bearing Aquifers 

The 70 Sand is the proposed production aquifer located 30.5 to 91.4 m [100 to 300 ft] below 

ground surface in the proposed project area. The 70 Sand is laterally extensive and ranges 

from 12.2 to 36.6 m [40 to 120 ft] thick. The 70 Sand dips to the northwest at about 1 degree. It 

outcrops approximately 1.6 km [1 mi] south of the proposed project area. The 70 Sand is not 

completely saturated over its thickness in most of the proposed license area. Since the water 

levels in the 70 Sand are below the overlying shale, it is defined as an unconfined aquifer. 

Water produced from wells in unconfined aquifers comes from physical drainage of water from 

the formation pores, not from compression of the sediments and expansion of water due to 

pressure decreases, as in confined aquifers. The natural groundwater flow is estimated to be to 

the northwest in the 70 Sand at about 2.4 m/yr [7.8 ft/yr], based on the reported gradient of 

0.004 ft/ft and hydraulic conductivity of 5.36 ft/day. 

3.5.2.3.1 Hydrogeologic Characteristics 

The hydraulic properties of the 70 Sand production aquifer have been evaluated through a 

series of pumping tests. Aquifer testing was performed between 1978 and 1980 while Conoco 

was investigating the Moore Ranch site as a possible surface mine site. The applicant 

conducted additional pumping tests in 2007 and 2008. Analysis of data from the 2008 test 

estimated the transmissivity and hydraulic conductivity of the 70 Sand to be 37.6 m2

/day 

[405 ft2

/day] and 1.63 m/day [5.36 ft/day], respectively. Estimates of specific yield for the 

unconfined aquifer ranged from 0.011 to 0.039. 

3.5.2.3.2 Level of Confinement 

The 70 Sand is separated from the overlying 72 Sand by a continuous shale and coal seam 

across the proposed license area. Water levels in the 72 Sand are much higher than the 

70 Sand. The 70 Sand is also not completely saturated. These two features demonstrate that 

the aquifers are not hydraulically connected. All of the pumping tests conducted in the 70 Sand 

to date have demonstrated no response in the 72 Sand, which supports the lack of a hydraulic 

interconnection. Because the 70 Sand is not completely saturated, the groundwater in the 

72 Sand is likely perched on the shale separating the two aquifers. 
Affected Environment 

3-26 

The 70 Sand is separated from the underlying 68 Sand by shale over much of the proposed 

project area. Pumping tests conducted to date have identified no hydraulic interconnection 

between these sands in proposed Wellfield 1. In portions of proposed Wellfield 2, however, 

boring data indicates that the shale is missing or less than 5 ft thick. In this area, the 68 Sand 

coalesces with the 70 Sand. Pumping tests in Wellfield 2 where the shale is absent have shown 

a hydraulic connection between the 68 and 70 Sand. Water levels in the 68 and 70 Sands are 

also similar, supporting a potential hydraulic connection. In the area in Wellfield 2 where the 68 

and the 70 Sands coalesce, the applicant considers the 60 Sand to be the underlying aquifer. 

3.5.2.3.3 Groundwater Quality 

Baseline groundwater quality programs have characterized the quality of groundwater within the 

shallow Wasatch aquifers within the proposed Moore Ranch Project area (Table 3-3). 

Groundwater quality in the 72 Sand aquifer and production zone 70 Sand exceed the WDEQ 

Class I standards for TDS and sulfate. The radionuclides radium-226 and uranium are elevated 

above EPA maximum contaminant levels (MCL) for drinking water in the majority of samples 

collected from the production zone 70 Sand aquifer and the underlying 68 Sand aquifer. The 

Table 3-3. Average Preoperational Baseline Groundwater Quality for the “72 Sand” 

Overlying Aquifer, the “70 Sand” Extraction zone Aquifer, the “68 Sand,” and the “60 

Sand” Underlying Aquifer 

Water Quality Parameter 

Average 

“72 Sand” “70 Sand” “68 Sand” “60 Sand” 

Bicarbonates as HCO3 (mg/L) 208.2 277.2 148.6 225.8 

Carbonates asCO3 (mg/L) 1.6 1.0 10.4 4.4 

Chloride (mg/L) 4.1 2.3 2.0 2.6 

Conductivity (umhos/cm) 1051.6 1034.2 753.3 621.0 

Fluoride (mg/L) 0.2 0.2 0.2 0.2 

pH (s.u.) 8.07 7.58 8.99 8.77 

TDS (mg/L) 770.6 712.5 416.5 414.4 

Sulfate (mg/L) 401.0 330.3 162.0 128.4 

Gross Alpha (pCi/L) 5.7 259.1 78.24 74.7 

Gross Beta (pCi/L) 14.4 80.6 40.09 16.4 

Lead-210 (pCi/L) 2.0 9.2 6.81 1.37 

Polonium-210 ( pCi/L) 1.2 5.6 3.55 1.17 

Radium-226 (pCi/L) 1.1 95.6 21.1 0.71 

Radium-228 (pCi/L) 1.9 1.7 1.2 1.32 

Thorium-230 (pCi/L) 0.3 0.3 0.2 0.05 

Nitrogen, Ammonia as N (mg/L) 0.214 0.1 0.5 Nondetect 

Nitrogen, Nitrate + Nitrite as N 

(mg/L) 0.4 0.2 0.3 Nondetect 
Affected Environment 

 3-27 

Table 3-3. Average Preoperational Baseline Groundwater Quality for the “72 Sand” 

Overlying Aquifer, the “70 Sand” Extraction zone Aquifer, the “68 Sand,” and the “60 

Sand” Underlying Aquifer 

Water Quality Parameter 

Average 

“72 Sand” “70 Sand” “68 Sand” “60 Sand” 

Aluminum (mg/L) 0.1 0.1 0.1 Nondetect 

Arsenic (mg/L) 0.001 0.002 0.002 0.001 

Barium (mg/L) 0.1 0.1 0.1 Nondetect 

Boron (mg/L) 0.1 0.1 0.1 Nondetect 

Cadmium (mg/L) 0.005 0.005 0.005 Nondetect 

Calcium (mg/L) 137.4 135.2 54.4 58.8 

Chromium (mg/L) 0.05 0.05 0.05 Nondetect 

Copper (mg/L) 0.01 0.01 0.011 Nondetect 

Iron (mg/L) 0.082 0.151 0.052 Nondetect 

Lead (mg/L) 0.001 0.002 0.005 Nondetect 

Magnesium (mg/L) 37.3 31.8 7.4 6.1 

Manganese (mg/L) 0.064 0.033 0.016 0.014 

Mercury (mg/L) 0.001 0.001 0.001 Nondetect 

Molybdenum (mg/L) 0.1 0.1 0.1 Nondetect 

Nickel (mg/L) 0.05 0.05 0.05 Nondetect 

Potassium (mg/L) 16.6 10.2 14.7 8.3 

Selenium (mg/L) 0.001 0.025 0.135 0.083 

Silica (mg/L) 10.9 13.0 11.2 Nondetect 

Sodium (mg/L) 32.3 33.3 63.4 70.2 

Uranium (mg/L) 0.001 0.161 0.050 0.0532 

Vanadium (mg/L) 0.1 0.1 0.1 Nondetect 

Zinc (mg/L) 0.01 0.01 0.01 Nondetect 

Source: EMC, 2007b, Table 2.7.3-21. 

average radium 226-228 concentration in the production zone is an order of magnitude greater 

than the EPA MCL. The 68 Sand aquifer also exceeds the EPA MCL for selenium. In 

Wellfield 2, the 60 Sand aquifer exceeds the EPA MCL for selenium and uranium. Elevated 

concentrations of these radionuclides is consistent with the presence of uranium ore-bodies. 

Using WDEQ standards, Uranium One classified the class of use for each shallow aquifer on a 

well-by-well basis in the proposed license area. WDEQ Class I is drinking water, Class II is 

agricultural use, Class III is for livestock use, and Class VI is water that is unsuitable for any of 

these uses. The single well in the perched 80 Sand aquifer was classified as Class VI. One 

well in the 72 Sand aquifer was classified as Class I, another as Class II, and two others as 
Affected Environment 

3-28 

Class III. In the 70 Sand production zone aquifer, all eight wells were Class VI and one well 

outside the ore zone was Class I. All four wells in the 68 Sand and three wells in the 60 Sand 

were found to be Class VI. 

For ISR operations to be conducted in a proposed ore-bearing aquifer within the permit 

boundaries of the proposed ISR Site, the aquifer must be declared as an exempted aquifer, in 

compliance with 40 CFR Part 146. The applicant is required to obtain a Class III UIC exemption 

permit from the State. The State requests an aquifer exemption from the EPA for the proposed 

Class III UIC permit. The applicant must have both the UIC permit and the exemption before 

operations may begin. The water quality of the 70 Sand production zone aquifer in the project 

area is Class VI under WDEQ standards, which means the groundwater cannot be used for 

drinking, livestock, or agricultural use as a consequence of its uranium and radium-226 

concentrations. It would, therefore, be a candidate for an exempt aquifer declaration. The 

68 Sand would also be a candidate, given its water quality is also Class VI. 

3.5.2.3.4 Current Groundwater Uses 

According to a search of the WSEO database, there are 559 wells with groundwater rights 

located within the 3.2-km [2-mi] radius of the proposed Moore Ranch Project as of June 2009. 

Groundwater rights for wells are granted on a well-by-well basis through the WSEO (Uranium 

One, 2009b). Domestic and stock wells have a limit of 94.7 L/min [25 gal/min] per well. There 

are no minimum water levels entitled with the groundwater rights. The vast majority of water 

rights in and near the proposed Moore Ranch Project area are for CBM activities in the Fort 

Union Formation at depths exceeding 244 m [800 ft]. 

Of the wells identified in the search, 465 are CBM or stock–CBM wells. All of these CBM and 

stock–CBM wells that have completion records, are greater than 213 m [700 ft] deep. Of those 

with no completion records it is unlikely they are completed in shallower Wasatch Formation 

sands, as the target for CBM production is the Fort Union Formation, which is located at depths 

exceeding 244 m [800 ft] in the proposed license area. Given the depth of these wells, it is 

unlikely they will be impacted by operations in the 70 Sand production zone. 

Within the 3.2 km [2 mi] radius, there are three domestic water wells ranging from 41.7 to 134 m 

[137 to 440 ft] deep. Two are located east of the proposed Moore Ranch Project area near the 

limit of the 3.2-km [2-mi] radius. One well is located in the license area and is permitted as an 

industrial, domestic well by Rio Algom Mining Corporation. While these wells are permitted for 

domestic use, there are no currently occupied residences within the proposed license area and 

3.2-km [2-mi] radius; therefore, these wells are not being primarily used for human consumption. 

Given both the distance from the proposed operations and the well’s upgradient locations, they 

would unlikely be impacted by the proposed operations. 

Also within the 3.2-km [2-mi] radius there are 27 permitted stock wells, of which 3 are located in 

the proposed project area. Of these wells, 25 are completed at depths greater than 213 m 

[700 ft] and two are completed at less than 213 m [700 ft]. At least four other unpermitted stock 

wells are known to be in the proposed project area, for which no completion information is 

available, but they are estimated to be in the 68, 70, and 72 Sands. An inoperable windmill with 

an unpermitted well is also located in the proposed project area. Some of these wells that are 

located in the shallow 68, 70, and 72 Sands may be impacted by operations within the 70 Sand 

production zone. 
Affected Environment 

 3-29 

There are no irrigation water wells within the 3.2 km [2 mi] radius. The deepest water well that 

has groundwater rights within the 3.2-km [2 mi] radius is permitted as a CBM well and is 430 m 

[1,410 ft] deep. It is not likely to be impacted by ISR operations. The remaining deep wells in 

the proposed project area are oil and gas wells. 

If the domestic well is completed in the exempted portion of the ore-bearing aquifer, the well 

cannot be used as a source of drinking water, in compliance with 40 CFR Part 146. In this 

case, the domestic well is required to be properly plugged and abandoned prior to 

commencement of ISR operations. If industrial or livestock wells are completed in the 

exempted portion of the aquifer, these wells would be required to be properly plugged and 

abandoned to avoid potential negative impacts on targeted bleed rates during ISR operations 

and also to minimize potential adverse impacts on the environment. Upon completion of ISR 

operations, the applicant is required to return groundwater quality in the exempted portions of 

the production aquifer to restoration standards, in compliance with 10 CFR Part 40, Appendix A, 

Criterion 5B(5). 

3.5.2.4 Surrounding Aquifers 

In addition to the sands of the Wasatch discussed previously, the underlying Fort Union 

Formation and Fox Hills Sandstones include potentially important aquifers. However, because 

of the relatively shallow depth of 30.5 to 91.4 m [100 to 300 ft] for the 70 Sand production zone 

in the overlying Wasatch, these deeper aquifers that are separated by thick sequences of shale 

are not likely to be impacted by ISR operations in the production zone. 

The shallowest deep aquifer is the Lance Formation at depths of 1,128–1,738 m 

[3,700–5,700 ft] below ground surface. The TDS content of groundwater in the Lance 

Formation is on average 1,200 ppm (EMC 2007a; Section 3.4.3.3). Because of its low water 

yields and large depths, the Lance Formation is not expected to be a drinking water supply at or 

in the vicinity of the permit area. If the Lance Formation is considered as a candidate deep 

disposal aquifer for the proposed Moore Ranch Project, the State of Wyoming would evaluate 

the feasibility of using the formation for deep well disposal via a Class I injection well. The State 

and EPA would only grant such a permit to the applicant if it can demonstrate that liquid effluent 

could be safely isolated in a deep aquifer. 

3.6 Ecology 

The Wyoming East Uranium Milling Region, as described in the GEIS, encompasses the 

Wyoming Basin, Northern Great Plains, Southern Rockies, and Western High Plains. The 

proposed Moore Ranch ISR Project is located within the Powder River Basin of the 

Northwestern Great Plains ecoregion. Section 3.3.5.1 of the GEIS provides the following 

description of this region: 

The Northwestern Great Plains encompass the Missouri Plateau section of the Great 

Plains. This area includes semiarid rolling plains of shale and sandstone derived soils 

punctuated by occasional buttes and badlands. For the most part, it has not been 

influenced by continental glaciation. Cattle grazing and agriculture with spring wheat 

and alfalfa farming are common land uses. Agriculture is affected by erratic precipitation 

and limited opportunities for irrigation. In Wyoming, mining for coal and coal-bed 

methane production is prevalent, with a large increase in the number of coal-bed 

methane wells drilled in recent years. Native grasslands and some woodlands persist, 

especially in areas of steep or broken topography (Chapman, et al., 2004). 
Affected Environment 

3-30 

Section 3.3.5.1 of the GEIS provides the following description of the Powder River Basin: 

The Powder River Basin ecoregion of the Northwestern Great Plains covers rolling 

prairie and dissected river breaks surrounding the Powder, Cheyenne, and Upper North 

Platte Rivers. The Powder River Basin has less precipitation and less available water 

than the neighboring regions. Vegetation within this region is composed of sagebrush 

and mixed-grass prairie dominated by blue grama (Bouteloua gracilis), western 

wheatgrass (Elymus smithii), prairie junegrass (Koeleria macrantha), Sandberg 

Bluegrass (Poa secunda), needle-and-thread grass (Stipa comata), rabbitbrush 

(Chrysothamnus), fringed sage (Artemisia frigida), and other forbs, shrubs, and grasses 

(Chapman et al., 2004). 

The applicant conducted a number of ecological studies at the proposed Moore Ranch Project 

to accomplish the objectives specified in NUREG–1569, “Standard Review Plan for In-Situ

Leach Uranium Extraction License Applications,” and to meet the applicable State of Wyoming 

requirements. These studies include vegetation and wetland surveys conducted in the 

spring/summer of 2007 and wildlife surveys conducted from fall 2006 through summer 2007. 

3.6.1 Terrestrial Ecology 

The proposed project area is comprised primarily of grassland, with areas of sagebrush in the 

southwest corner. Interspersed among those major plant communities are less abundant 

seeded grasslands (improved pastures) habitats and intermittent streams, as described next. 

No perennial streams or other permanent water bodies exist within the proposed Moore Ranch 

Project (EMC, 2007a). 

3.6.1.1 Vegetation 

The applicant conducted baseline vegetation and wetland surveys during the spring/summer of 

2007, in accordance with applicable State and Federal guidelines. The applicant’s 

environmental report (EMC,2007a) provides a detailed description of the survey results. The 

spatial distribution of the vegetation types within the proposed Moore Ranch Project are shown 

in Figure 3-11. 

The proposed license area for the Moore Ranch Project is approximately 2,879 ha [7,110 ac] 

and consists primarily of four vegetation communities: Meadow Grassland, Upland Grassland, 

Agricultural Grassland, and Big Sagebrush Shrublands, as shown in Figure 3-11. 

Approximately 61 ha [150 ac] or about 2 percent of the proposed license area would be 

disturbed by the proposed action. Each vegetation community was investigated to establish a 

baseline, in support of the NRC license application. No threatened or endangered plant species 

were encountered within the proposed license area. Two State-listed species of concern, or 

State designated weeds, Canada thistle (Cirsium arvense) and field bindweed (Convolvulus 

arvensis), were identified in the proposed project area and should be managed. 
Affected Environment 

 3-31 

Figure 3-11. Vegetation Communities on the Proposed Moore Ranch Project 
Affected Environment 

3-32 

Table 3-4 summarizes the area of each vegetation community within the proposed license area. 

The applicant’s environmental report summarizes the vegetation community mapping units for 

the proposed Moore Ranch Project (EMC, 2007a). Upland grassland is the predominant 

vegetation type within the proposed license area, as summarized in Table 3-4. 

Table 3-4. Areal Distribution of Vegetation Communities within the 

Proposed License Area 

Mapping Unit 

Proposed License Area 

(in hectares) 

Proposed License 

Area (in Acres) Percent of Area 

Meadow Grassland 130.9 323.32 5 

Upland Grassland 2,027 5,006.69 70 

Agricultural 

Grassland

377 931.19 13 

Big Sagebrush 

Shrubland

286.43 707.48 10 

Disturbance 53.5 132.15 2 

TOTAL 2,875 7,100.83 100 

Source: EMC, 2007a

3.6.1.2 Wildlife 

Baseline wildlife information for the proposed Moore Ranch Project is available from previous 

data collection efforts conducted for CBM plans-of-development that generally covered all but 

the extreme southeastern and western sections of the proposed Moore Ranch Project area and 

the perimeter. These annual surveys were conducted from the years 2003 through 2006 and 

included numerous wildlife species, habitat features such as bald eagle nesting and winter roost 

sites, sage-grouse leks, raptor nests, and surveys for avian species of concern. In addition, the 

applicant conducted a site-specific survey from October 2006 through June 2007. Detailed 

results of these investigations are documented in the applicant’s environmental report (EMC, 

2007a). Because much of the proposed license area has been included in annual wildlife 

monitoring since 2003, the Wyoming Game and Fish Department (WGFD) delineated the study 

area for raptors and other migratory birds to those portions of the proposed Moore Ranch 

Project and a 1.6-km [1-mi] perimeter not encompassed by the previous overlapping studies. 

Site-specific wildlife surveys of the proposed Moore Ranch Project targeted bald eagle winter 

roost sites, sage-grouse leks, nesting raptors (including eagles), mountain plovers, and other 

avian species of concern. 

3.6.1.2.1 Big Game 

Pronghorn antelope (Antilocapra americana) and mule deer (Odocoileus hemionus) are the only 

two big game species that regularly occur on the proposed license area. No crucial big game 

habitat or migration corridors occur in or within several kilometers of the area (WGFD, 2009). 
Affected Environment 

 3-33 

Pronghorn antelope are more abundant than mule deer in the proposed Moore Ranch Project 

area, but neither species is prevalent because it is not their preferred habitat. The WGFD 

classified the proposed license area as a yearlong pronghorn antelope range, meaning that a 

portion of a population of animals makes general use of this habitat on a year-round basis. The 

proposed Moore Ranch Project spans two WGFD pronghorn antelope herd units bisected by 

highway SR 387. The WGFD estimated the 2006 post-season pronghorn antelope populations 

in those two hunt areas to be approximately 36,500 and 32,300, which is above the WGFD 

population objectives to manage and regulate big game herds (WGFD, 2006a,b). 

Mule deer use nearly all habitats but prefer sagebrush-grassland and are not abundant in the 

proposed license area. Monitoring data indicate that mule deer are not very migratory in the 

vicinity of the proposed Moore Ranch Project. The majority of the proposed license area has 

been classified by WGFD as a yearlong mule deer range, except portions south of the highway 

that are considered inadequate to support mule deer. The WGFD estimated the 2006 

post-season mule deer population to be approximately 12,350 and 9,700 animals, compared to 

herd objectives of 11,000 and 9,100 (WGFD, 2006a,b). 

3.6.1.2.2 Avian Species 

This section of the SEIS describes bird species that have been identified at the proposed Moore 

Ranch Project, based on the surveys described previously. 

Upland Game Birds 

The mourning dove (Zenaida macroura) is the only upland game bird known to regularly occur 

in the vicinity of the proposed Moore Ranch Project, and it is a relatively common breeder in 

Campbell County. Most sightings at the proposed Moore Ranch Project occur during migration 

near sites with water sources or trees, though they were occasionally recorded in upland 

grassland habitats. 

The greater sage-grouse (Centrocercus urophasianus) is listed as a Federal candidate species 

and an avian species of special concern in Wyoming, and it is discussed in more detail in 

Section 3.6.3 (75 FR13090; WGFD, 2005a). Sage-grouse are found in sagebrush shrubland 

habitats, and sagebrush is essential during all seasons and for every phase of their life cycle. 

Sage-grouse are rare in the vicinity of the proposed Moore Ranch Project because of the limited 

habitat to support their existence. No large expanses of contiguous sagebrush occur within 

several kilometers of the proposed Moore Ranch Project. Consequently, few sage-grouse have 

been documented in the area; and no grouse leks have ever been discovered either on or near 

the proposed Moore Ranch Project. The nearest known sage-grouse lek is located 

approximately 4.0 km [2.5 mi] to the northwest of the proposed Moore Ranch Project area 

(BLM, 2009). 

Raptors 

Suitable habitat for several raptor species occurs in the proposed Moore Ranch Project area 

and within a 1.6-km [1-mi] perimeter of the site. These raptor species include golden eagle 

(Aquila chrysaetos), ferruginous hawk (Buteo regalis), red-tailed hawk (Buteo jamaicensis), 

Swainson's hawk (Buteo swainsoni), northern harrier (Circus cyaneus), American kestrel (Falco 

sparverius), prairie falcon (Falco mexicanus), great horned owl (Bubo virginianus), burrowing 

owl (Athene cunicularia), and short-eared owl (Asio flammeus) (EMC, 2007a). Nests have been 
Affected Environment 

3-34 

observed for the ferruginous hawk, red-tailed hawk, great horned owl, and Swainson's hawk but 

not for the other raptors, based on BLM data (BLM, 2007a). 

Thirty-six raptor nest sites have been identified within the vicinity of the proposed Moore Ranch 

Project since 2003 (EMC, 2007a). Nineteen nest sites were located within the proposed 

Moore Ranch Project, and the remaining 17 were located around the perimeter of the site 

(EMC, 2007a). 

Waterfowl and Shorebirds 

The proposed Moore Ranch Project has extremely limited and marginal habitat for waterfowl 

and shorebirds because of the lack of surface water. Natural aquatic habitats are mainly 

present during spring migration and consist of small, isolated pools that can be completely dry 

during summer. Recent CBM development in the proposed Moore Ranch Project area has 

increased the number of localized water sources with limited depth, geographic area, and 

duration. Several common species of waterfowl and shorebirds, including the mallard (Anas 

platyrhynchos) and killdeer (Charadrius vociferus), have been infrequently observed in the 

proposed Moore Ranch Project area (EMC, 2007a). 

3.6.1.2.3 Other Mammals, Reptiles, and Amphibians 

A variety of small- and medium-sized mammal species occur in the vicinity of the proposed 

Moore Ranch Project. These include predators and furbearers, such as the coyote (Canis 

latrans), red fox (Vulpes vulpes), swift fox (Vulpes velox), bobcat (Lynx rufus), striped skunk 

(Mephitis mephitis), weasel, badger (Taxidea taxus), muskrat (Ondatra zibethicus), and raccoon 

(Procyon lotor). Prey species include various rodents, such as mice, rats, voles, gophers, 

ground squirrels, chipmunks, and lagomorphs (jackrabbits and cottontails). These prey species 

are cyclically common and widespread throughout the region and are important for raptors and 

other predators. No occupied black-tailed prairie dog (Cynomys ludovicianus) colonies have 

been documented on or in the vicinity of the proposed Moore Ranch Project, based on repeated 

surveys (EMC, 2007a). 

Few reptiles and amphibians have been recorded during recent wildlife surveys because of the 

lack of suitable habitat (EMC, 2007a). The common bullsnake (Pituophis melanoleucas sayi)

was the only herpetological species recorded on the proposed Moore Ranch Project in the 

baseline studies conducted in 2006 and 2007. 

3.6.2 Aquatic Ecology 

Aquatic habitat on and near the proposed Moore Ranch Project is limited by the intermittent 

nature of surface waters in the proposed license area. The lack of deep-water habitat and 

extensive and persistent water sources precludes the presence of fish and limits the abundance 

and diversity of other aquatic species. No perennial drainages are present in the proposed 

license area. 
Affected Environment 

 3-35 

3.6.3 Protected Species 

Threatened and Endangered Species

Table 3-5 lists species that are Federally-listed under the Endangered Species Act (ESA) of 

1973, State-listed under the Final Comprehensive Wildlife Conservation Strategy for Wyoming, 

or BLM-listed as sensitive species and that occur in Campbell and Johnson Counties. 

No threatened and endangered species occur within the proposed Moore Ranch Project study 

area. Based on consultation with the U.S. Fish and Wildlife Service (FWS) (2008a), federally 

listed threatened and endangered species (or their designated habitat) that could potentially 

occur in the proposed project area are discussed in the following paragraphs. 

The Ute ladies’-tresses orchid (Spiranthes diluvialis) is Federally-listed as threatened. The 

species is a perennial, terrestrial orchid that occurs in Nebraska, Wyoming, Colorado, Utah, 

Idaho, Montana, and Washington. Within Wyoming, it inhabits moist meadows with moderately 

dense but short vegetative cover. The species is found at elevations of 1,280 to 2,130 m [4,200 

to 7,000 ft], though no known populations occur in Wyoming above 1,680 m [5,500 ft] (Fertig, 

2000). Generally, this orchid is found in low densities of four to eight flowering plants per 

square meter (Fertig, 2000). The species is likely to inhabit silt, sand, or gravely soils in areas 

with ample sunlight (Fertig, 2000). It is characterized by 12- to 50-cm [4.7- to 20-in] stems with 

linear basal leaves up to 28 cm [11 in] long and spikes of small white to ivory flowers that bloom 

between early August and early September (Fertig, 2000). Urbanization, livestock grazing, 

pesticide use, competition with noxious weeds, and loss of pollinators threaten this species’ 

survival (Fertig, 2000). This species was not identified during the applicant vegetation 

inventories and it is not known to occur on or in the vicinity of the proposed project site. 

The black-footed ferret (Mustela nigripes) is listed as an endangered species that inhabits 

prairie dog colonies. A black-footed ferret survey was not required, since black-footed ferrets 

live exclusively in prairie dog colonies, which are not present on or within 1.6 km [1 mi] of the 

proposed Moore Ranch Project area. 

The black-footed ferret is a small mammal in the weasel family with a natural to buff-colored 

body and black face, feet, and tail. Adults are 46 to 61 cm [18 to 24 in] long and weigh 0.7 to 

1.1 kg [1.5 to 2.5 lb], with males generally larger than females (FWS, 2008b). Generally, 

black-footed ferret occurrence coincides with prairie dog habitat (black-tailed [Cynomys 

ludovicianus], Gunnison’s [C. gunnisoni], and white-tailed [C. leucurus]) because prairie dog is 

the main prey of the ferret, and the ferret also uses prairie dog burrows for shelter (FWS, 

2008b). Black-footed ferrets are more likely to occur in black-tailed prairie dog habitat than in 

other prairie dog species’ habitat; historically, it is estimated that 85 percent of all black-tailed 

ferrets occurred in black-tailed prairie dog habitat, 8 percent in Gunnison’s prairie dog habitat, 

and 7 percent in white-tailed prairie dog habitat (FWS, 2008b). 

The bald eagle (Haliaeetus leucocephalus) was delisted from threatened status in 2007, but it is 

still protected under the Bald and Golden Eagle Protection Act and the Migratory Bird Treaty 

Act. Potential habitat for bald eagle nesting and roosting activities is quite limited within the 

proposed license area because of the lack of trees. Nor does the proposed Moore Ranch 

Project contain unique or sizeable, concentrated prey sources (e.g., fisheries, waterfowl 

wintering areas) that would be expected to attract bald eagles. There have been no bald eagle 

sightings during either site-specific winter roost surveys or other baseline surveys completed by 

the applicant in 2006 and 2007 nor have they been observed in annual surveys conducted since 
Affected Environment 

3-36 

2003 (EMC, 2007a). In addition to the wildlife inventories conducted by Uranium One, a BLM 

environmental assessment for the Yates Petroleum Corporation All Day Plan of Development 

(BLM, 2008) identifies information concerning bald eagle roosts within the Hank Unit of the 

proposed Nichols Ranch ISR Project, located about 32 km [20 mi] northwest of the proposed 

Moore Ranch Project. The environmental assessment documented observation of 7 bald 

eagles on December 3, 2007, 5 bald eagles on December 16, 2008, 1 bald eagle on 

January 12, 2009, and 13 bald eagles on February 11, 2009 (BLM, 2008). 

The blowout penstemon (Penstemon haydenii) is Federally-listed as endangered. The species 

is a perennial herb that is endemic to the Nebraska Sandhills in north-central Nebraska and to 

the northeastern region of the Great Divide Basin in Carbon County, Wyoming (Fertig, 2008). 

The species is found exclusively in sparsely vegetated, early successional sand dunes or 

blowout areas at elevations of 1,790 to 2,270 m [5,860 to 7,440 ft] (Fertig, 2008). The proposed 

Moore Ranch ISR Project does not have sand dune habitat and is outside of the elevation range 

in which this species is typically found. This species was not identified during vegetation 

inventories and it is not known to occur on or in the vicinity of the proposed site. 

The swift fox (Vulpes velox) is a State of Wyoming species of concern and a BLM-designated 

sensitive species. The species was removed from the ESA Candidate List in 2002 due to 

successful conservation measures and reintroduction efforts in western states. The species is 

native to the Great Plains region, and in Wyoming, the swift fox inhabits flat terrain east of the 

Continental Divide with shortgrass or mixed-grass prairie and is often associated with prairie 

dog colonies (WGFD, 2005b). Swift foxes are nocturnal and use underground dens year round. 

Threats to the species’ continued survival include loss of prairie habitat, trapping and hunting, 

and predator control campaigns (WGFD, 2005b). This species was not identified during the 

applicant wildlife inventories and it is not known to occur on or in the vicinity of the proposed 

project site. 

The Greater sage-grouse (Centrocercus urophasianus) is Federally-listed as a candidate 

species, a State of Wyoming species of concern, and a BLM-designated sensitive species. On 

March 5, 2010, the FWS published a finding in the Federal Register stating that listing of the 

species was warranted but precluded by higher priority listing actions (75 FR 13909). The 

Wyoming Governor issued an Executive Order in August 2008 that sets out 12 provisions for oil 

and gas resources management within core and noncore population areas to protect the 

species on the State level (State of Wyoming, 2008). WGFD published Recommendations for 

Development of Oil and Gas Resources Within Important Wildlife Habitats, and the Wyoming 

BLM issued an instructional memorandum on March 5, 2010, which supplements the BLM 2004 

National Sage-Grouse Habitat Conservation Strategy, to be consistent with the Governor’s 

Executive Order (WGFD, 2010; BLM, 2004; BLM, 2010). This guidance was again updated in 

April 2010 (WGFD, 2010). The species inhabits open sagebrush plains in the western United 

States and is found at elevations of 1,200 to 2,700 m [4,000 to 9,000 ft], corresponding with the 

occurrence of sagebrush habitat (69 FR 933). The greater sage-grouse is a mottled brown, 

black, and white ground-dwelling bird that can be up to 0.6 m [2 ft] tall and 76 cm [30 in] in 

length (69 FR 933). Breeding habitat, referred to as leks, and stands of sagebrush surrounding 

leks are used in early spring and are particularly important habitat because birds often return to 

the same leks and nesting areas each year. Leks are generally more sparsely vegetated areas 

such as ridgelines or disturbed areas adjacent to stands of sagebrush habitat. Threats to this 

species’ survival include loss of habitat, agricultural practices, livestock grazing, hunting, and 

land disturbances from energy/mineral development and the oil and gas industry (Sage-Grouse 
Affected Environment 

 3-37 

Working Group, 2006). This species was not identified during the applicant wildlife inventories 

and few have ever been documented on or in the vicinity of the proposed site. 

Species of Concern

The Wyoming Field Office of the USFWS uses the list, Migratory Bird Species of Management 

Concern in Wyoming (also known as Migratory Birds of High Federal Interest) for conducting 

reviews related to noncoal surface disturbance projects (FWS, 2002). This list (Table 3-5) is 

based on the Wyoming Bird Conservation Plan (Nicholoff, 2003). Seventy seven avian species 

of concern are identified on this list; 22 species are identified as being species in need of 

Table 3-5. Migratory Bird Species of Management Concern Observed on the Proposed 

Moore Ranch Project

Species 

Primary Nesting 

Habitat(s) 

Status/Occurrence 

in Project Region* 

Occurrence 

Within Proposed 

License Area

Species Of Level I Concern–Conservation Action Needed 

McCown’s longspur 

Calcarius mccownii 

Short-grass prairie, 

shrub-steppe Breeder Observed, presumed breeder 

Ferruginous hawk 

Buteo regalis 

Shrub-steppe 

grasslands Breeder Observed, breeder 

Species Of Level II Concern–Continued Monitoring Recommended 

Lark Bunting 

Calamospiza melanocorys 

Short-grass prairie, 

shrub steppe Breeder Observed, presumed 

breeder 

Chestnut-collared Longspur 

Calcarius ornatus Short-grass prairie Potential breeder Observed, likely 

breeder 

Vesper Sparrow 

Pooecetes gramineus Shrub-steppe Breeder Observed, presumed 

breeder 

Reference: EMC, 2007a 

*Wyoming lat/long encompassing Moore Ranch Project

conservation action (Level I); and the remaining 55 species are classified as Level II concern, 

for which continued careful monitoring is recommended. 

Surveys for avian species of concern, including mountain plovers (Charadrius montanus), 

sage-grouse, and bald eagle, were conducted annually from 2003 through 2007 at the proposed 

Moore Ranch Project. Most surveys have occurred in the spring and summer to document 

migrating and breeding birds; winter surveys were conducted for bald eagle roost sites. The 

study area for previous surveys included most of the proposed project area and a 0.8-km 

[0.5-mi] perimeter {1.6-km [1-mi] for bald eagles}. The applicant surveyed the entire proposed 

Moore Ranch Project from fall 2006 through early summer 2007. 

Table 3-6 lists the five avian species of concern that were observed in the proposed Moore 

Ranch Project area during the applicant 2006–2007 baseline studies, including their primary 

nesting habitats and historical occurrence in the general area. For these five species, BLM 

Wyoming has enacted the Sensitive Species Policy and List to focus species management 

efforts within BLM lands and ensure that actions authorized, funded, or carried out by BLM do 

not contribute to the need for any species to become listed under the ESA.
Affected Environment 

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Table 3-6. Federally- and State-Listed Species 

Scientific Name Common Name 

Federal 

Status* State Status†

County of 

OccurrenceI

Amphibians 

Ambystoma tigrinum tiger salamander – SGCN CAM; JOH 

Bufo cognatus Great Plains toad – SGCN CAM 

Rana pipiens northern leopard frog – SGCN; 

BLM-SS 

CAM; JOH 

Rana pretiosa spotted frog – BLM-SS CAM; JOH 

Rana sylvatica wood frog – SGCN JOH 

Birds 

Accipiter gentilis northern goshawk – SGCN; 

BLM-SS 

JOH 

Aegolius funereus boreal owl – SGCN JOH 

Ammodramus bairdii Baird’s sparrow – BLM-SS CAM; JOH 

Ammondramus 

savannarum 

grasshopper sparrow – SGCN CAM; JOH 

Amphispiza belli sage sparrow – SGCN; BLMSS 

CAM; JOH 

Asio flammeus short-eared owl – SGCN CAM; JOH 

Athene cunicularia burrowing owl – SGCN; 

BLM-SS 

CAM; JOH 

Buteo regalis ferruginous hawk – SGCN; BLMSS 

CAM; JOH 

Calcarius mccownii McCown’s longspur – SGCN CAM; JOH 

Calcarius ornatus chestnut-collared longspur – SGCN CAM 

Centrocercus 

urophasianus 

greater sage-grouse Candidate SGCN; BLMSS CAM; JOH 

Charadrius montanus mountain plover – SGCN CAM; JOH 

Coccyzus americanus yellow-billed cuckoo – SGCN; BLMSS 

JOH 

Cygnus buccinator trumpeter swan – BLM-SS CAM; JOH 

Dolichonyx oryzivorus boblink – SGCN CAM 

Egretta thalus snowy egret – SGCN JOH 

Falco peregrinus anatum American peregrine falcon DL SGCN; BLMSS 

CAM; JOH 

Gaviea immer common loon – SGCN JOH 

Haliaeetus leucocephalus bald eagle DL SGCN CAM; JOH 

Lanius ludovicianus loggerhead shrike – BML-SS CAM; JOH 

Numenius americanus long-billed curlew – SGCN; BLMSS 

CAM 

Nycticorax nycticorax black-crowned night-heron – SGCN CAM; JOH 

Oreoscoptes montanus sage thrasher – BLM-SS; 

SGCN 

CAM; JOH 

Plegadis chihi white-faced ibis – BLM-SS CAM; JOH 

Rallus limicola Virginia rail – SGCN JOH 

Sitta pygmaea pygmy nuthatch – SGCN CAM; JOH 

Spizella breweri Brewer’s sparrow – BLM-SS; 

SGCN 

CAM; JOH 

Fish 

Hiodon alosoides goldeye – SGCN JOH 

Hybognathus argyritis western silvery minnow – SGCN CAM; JOH 

Macrhybopsis gelida sturgeon chub – SGCN CAM; JOH 
Affected Environment 

 3-39 

Table 3-6. Federally- and State-Listed Species 

Scientific Name Common Name 

Federal 

Status* State Status†

County of 

OccurrenceI

Oncorhynchus clarki 

bouvieri 

Yellowstone cutthroat trout – BLM-SS CAM; JOH 

Scaphirhynchus 

platorynchus 

shovelnose sturgeon – SGCN CAM; JOH 

Stizostedion canadense sauger – SGCN CAM; JOH 

Mammals 

Corynorhinus townsendii Townsend’s big-eared bat – BLM-SS; 

SGCN 

CAM; JOH 

Cynomys leucurus white-tailed prairie dog – SGCN JOH 

Cynomys ludovicianus black-tailed prairie dog – SGCN JOH 

Euderma maculatum spotted bat – BLM-SS CAM; JOH 

Lasionycteris noctivagans silver-haired bat – SGCN CAM; JOH 

Lasiurus cinereus hoary bat – SGCN CAM; JOH 

Lontra canadensis river otter – SGCN JOH 

Martes pennanti fisher – SGCN JOH 

Microtus richardsoni water vole – SGCN JOH 

Mustela nigripes black-footed ferret E SGCN CAM; JOH 

Mustela nivalis least weasel – SGCN JOH 

Myotis ciliolabrum western small-footed 

myotis 

– SGCN JOH 

Myotis evotis long-eared myotis – BLM-SS; 

SGCN 

CAM; JOH 

Myotis thysanodes fringed myotis – BLM-SS; 

SGCN 

JOH 

Myotis volans long-legged myotis – SGCN JOH 

Perognathus fasciatus olive-backed pocket mouse – SGCN CAM; JOH 

Sorex haydeni Hayden’s shrew – SGCN JOH 

Sorex nanus dwarf shrew – SGCN CAM; JOH 

Vulpes velox swift fox – BLM-SS; 

SGCN 

CAM; JOH 

Reptiles 

Coluber constrictor 

flaviventris 

eastern yellowbelly racer – SGCN CAM; JOH 

Plants 

Anemone narcissiflora 

ssp. zephyra 

zephyr windflower PSC JOH 

Arnica lonchophylla northern arnica – PSC JOH 

Cymopterus williamsii Williams’ waferparsnip – BLM-SS; PSC JOH 

Cypripedium montanum mountain lady-slipper – PSC JOH 

Draba fladnizensis var.

pattersonii 

white artiv whitlow grass – PSC JOH 

Festuca hallii Hall’s fescue – PSC JOH 

Juncus triglumis var. 

triglumis 

three-flower rush – PSC JOH 

Papaver kluanense alpine poppy – PSC JOH 

Parnassia kotzebuei Kotzebuei’s grass-ofparnassus 

– JOH 

Pedicularis contorta var. 

ctenophore 

coil-breaked lousewort – PSC JOH 

Penstemon haydenii blowout penstemon E – CAM; JOH 

Physaria lanata woolly twinpod – PSC CAM; JOH 
Affected Environment 

3-40 

Table 3-6. Federally- and State-Listed Species 

Scientific Name Common Name 

Federal 

Status* State Status†

County of 

OccurrenceI

Polygala verticillata whorled milkwort – PSC CAM 

Polygonum 

spergulariiforme 

fall knotweed – PSC JOH 

Potamogeton amplifolius large-leaved pondweed – PSC JOH 

Psilocarphus brevissimus dward woolly-heads – PSC CAM 

Puccinellia cusickii Cusick’s alkali-grass – PSC JOH 

Pyrrocoma clementis var.

villosa 

hairy tranquil goldenweed – HCP JOH 

Rubus acaulis northern blackberry – PSC JOH 

Schoenoplectus 

heterochaetus 

slender bulrush – PSC CAM 

Sesuvium verrucosum sea purslane – PSC CAM 

Spiranthes diluvialis ute ladies’-tresses T – CAM; JOH 

Sporobolus compositus longleaf dropseed – PSC CAM 

Triodanis leptocarpa slim-pod Venus’ lookingglass 

– PSC CAM 

*DL = delisted; E = endangered; T = threatened; – = not listed. 

†BLM-SS = BLM Wyoming-designated Sensitive Species; PSC = plant species of concern, as designated by the 

WYNDD; SGCN = species of greatest conservation need, as designated by the WGFD 

ICAM = Campbell County, Wyoming; JOH = Johnson County, Wyoming 

Sources: BLM, 2002; FWS, 2008b; U.S. Department of Agriculture, 2009; WGFD, 2005b; Wyoming Natural Diversity 

Database (WYNDD), 2009a,b 

3.7 Meteorology, Climatology, and Air Quality 

3.7.1 Meteorology and Climatology 

The majority of Wyoming is dominated by mountain ranges and rangelands of the Rocky 

Mountains and high altitude prairies. The closest mountain ranges to the proposed Moore 

Ranch Project are the Bighorn Mountains, the Black Hills, and the northern Laramie Range 

located approximately 80, 137, and 80 km [50, 85, and 50 mi] from the proposed Moore Ranch 

Project. Because of these distances, the site does not experience significant wind channeling 

or shielding from any of these three mountain ranges (Uranium One, 2008). The average 

elevation over the eastern and southern prairie region, also known as the High Plains region, is 

over 1,828 m [6,000 ft] above mean sea level (AMSL). The Rocky Mountains are perpendicular 

to the prevailing westerly winds and provide an effective barrier to the significant Pacificgenerated weather systems. Much of the moisture produced from these systems is dropped 

along the western slopes of the Rocky Mountains, thereby leaving the eastern portion of the 

state in a semiarid condition. 

 

The proposed Moore Ranch Project is located within the Powder River Basin in northeastern 

Wyoming. The physical setting of the Powder River Basin is characterized by semiarid plains 

with low hills and buttes, little vegetation, and few substantial topographical features. The basin 

stretches approximately 190 km [120 mi] east to west and 320 km [200 mi] north to south in 

southeast Montana and northeast Wyoming. The region has extensive natural resources, such 

as coal, CBM, and uranium. It is both a topographic drainage and geologic structural basin. 

The proposed Moore Ranch Project area is located at 43o34’12.83” N latitude, 105o50’49.72” W 

longitude in the south-central portion of the Powder River Basin. The elevation of the proposed 

project area is approximately 1,670 m [5,500 ft] AMSL. This region of Wyoming experiences 
Affected Environment 

 3-41 

diverse weather patterns that fluctuate throughout the year, largely because of its proximity to 

the Rocky Mountain system and its relatively high elevation. The area is characterized by long 

winters, generally from December to April, which can bring frequent snow storms. Summer can 

be hot in the Powder River Basin due to the lack of moisture; however, the summer season 

tends to be short, with occasional hail, thunder, or snow storms. The Powder River Basin is 

treated as a single air quality control area by State and Federal regulators because of the 

uniformities in geography and climate. 

Because of the extensive surface coal mining that has developed over the last 30 years, the 

Powder River Basin airshed is heavily monitored. Coal production in the Powder River Basin 

grew from a few million tons in 1973 to over 400 million tons in 2006. A parallel growth in 

ambient air quality monitoring throughout the Powder River Basin accompanied the growth in 

coal production through the enactment of the Clean Air Act and the Surface Mining Control and 

Reclamation Act of the 1970s. There are more than 100 particulate monitoring samplers and 

more than 20 meteorological monitoring towers in the Powder River Basin to support air quality 

permitting, compliance, and research objectives (Uranium One, 2008). 

Since no onsite meteorological data are available for the proposed Moore Ranch Project, data 

from the Antelope Mine, located approximately 40 km [25 mi] southeast of the proposed Moore 

Ranch Project were used to describe the expected meteorological conditions in the proposed 

project area. The Antelope mine location has similar topographic features as the Moore Ranch 

Project area, characterized by mildly rolling hills covered with grass and sparse shrubs. No 

mountain ranges channel or shield the wind between these two locations nor are there bodies of 

water that would alter the general meteorological conditions at either the proposed Moore 

Ranch Project or the Antelope mine (Uranium One, 2008). As a result of the NRC’s safety 

review, Uranium One will be required by a license condition to collect onsite 

meteorological data. 

3.7.1.1 Temperature 

Temperatures fluctuate greatly throughout the year in the Powder River Basin. Located in a 

semiarid climate, summer temperatures at the proposed project site can be quite warm, while 

winters are commonly quite cold. The annual average temperature in the project area region is 

7 oC [46 oF]. The average maximum daily temperature is 32 oC [90 oF], with July yielding the 

warmest average temperatures. The average minimum daily temperature is −12 oC [10 oF], with 

January being the coldest month on average. Large, diurnal temperature variations occur in the 

region due to its high altitude and low humidity. Spring and summer daily variations of 8 to 

14 oC [15 to 25 oF] are common, with maximum temperature variations of 17 to 21 oC [30 to 

40 oF] observed during extremely dry periods. Less daily variation is observed during the cooler 

portions of the year; fall and winter have fluctuations of 5 to 7 oC [10 to 15 oF] (EMC, 2007a). 

3.7.1.2 Wind 

Wyoming is quite windy, and frequently winter winds reach 48 to 64 kph [30 to 40 mph], with 

gusts up to 80 to 97 kph [50 to 60 mph]. Prevailing wind directions vary from west-southwest 

through west to northwest. In many localities, winds are so strong and constant that trees 

(when present) show a definite lean towards the east or southeast. Average wind speeds within 

the project area vary from 24 to 27 kph [15 to 17 mph] from the west-northwest throughout 

the year. 
Affected Environment 

3-42 

Wind data for the proposed project area were obtained from Glenrock Coal Company, 

approximately 70 km [45 mi] south of the project area; and Antelope Coal Company, 

approximately 60 km [35 mi] east of the project area. The average annual wind speed is 

approximately 20.6 kph [14.8 mph] at Glenrock Coal Company and approximately 17.9 kph 

[11.1 mph] at Antelope Coal Company. Maximum hourly averages of greater than 80 kph 

(50 mph) have been recorded at both mine sites. Seasonal wind roses for the Antelope Coal 

Company site are shown in Figure 3-12. As noted in Section 3.7.1, data from the Antelope Coal 

Company are considered to be most representative of the proposed Moore Ranch Project. 

3.7.1.3 Precipitation 

The proposed project area receives relatively little rainfall. The mean annual precipitation within 

the area is approximately 35 cm [13.7 in]. May has been the wettest, and January has been the 

precipitation gauges capture only a small proportion of snowfall under windy conditions. Severe 

storms generated from severe weather conditions that could bring wind, rain, snow, or hail from 

any given direction are rare because the surrounding mountains effectively block or weaken 

storms (EMC, 2007a). 

Table 3-7 summarizes average temperature, precipitation, and snow fall trends taken from a 

National Climate Data Center weather station located in the town of Midwest, approximately 

32 km [20 mi] southwest of the proposed project area. Table 3-7 reflects the large temperature 

fluctuations between seasons, as well as the relatively small amount of precipitation that occurs 

at the proposed project area. 

3.7.1.4 Evaporation 

As discussed in Section 3.3.6.1 of the GEIS, the annual evaporation rates in the Wyoming East 

Uranium Milling Region range from about 102 to 127 cm [40 to 50 in] (NWS, 1982 in NRC, 

2009a). The low humidity, sunshine, and high winds contribute to a high rate of evaporation. 

driest month on average. The actual annual moisture may be somewhat higher because 

3.7.1.5 Climate Change and Greenhouse Gases 

On a larger scale, climate change is a subject of national and international interest. The recent 

compilation of the state of knowledge in this area by the U.S. Global Change Research Program 

(GCRP), a Federal Advisory Committee (GCRP, 2009), was considered in preparation of this 

SEIS. Average U.S. temperatures have risen more than 1.1 EC [2 EF] over the past 50 years 

and are projected to rise more in the future. During the period from 1993–2008, the average 

temperature in the Great Plains increased by approximately 0.83 EC [1.5 °F] from the 1961 to 

1979 baseline (GCRP, 2009). The projected change in temperature over the period from 2000 

to 2020, which encompasses the period the proposed Moore Ranch Project would be licensed, 

ranges from a decrease of approximately 0.28 EC [0.5 °F] to an increase of approximately 

1.1 EC [2 °F]. Although the GCRP did not incrementally forecast a change in precipitation by 

decade, they did project a change in spring precipitation from the baseline period (1961 to 1979) 

to the next century (2080 to 2099). For the region in Wyoming where the proposed Moore 

Ranch Project is located, the GCRP forecasted a 10 to 15 percent increase in spring 

precipitation (GCRP, 2009). 

The EPA determined that potential changes in climate caused by greenhouse gas (GHG) 

emissions endanger public health and welfare based on a body of scientific evidence assessed 
Affected Environment 

 3-43 

by the U.S. Global Climate Research Program, the Intergovernmental Panel on Climate 

Change, and the National Research Council (74 FR 66496). The Administrator issued an 

endangerment finding based on the Technical Support Document compiled by the abovereferenced scientific organizations which indicates that, while ambient concentrations of GHG 

emissions do not cause direct adverse health effects (such as respiratory or toxic effects), public 

Table 3-7. Climate Data for Midwest, Wyoming, Climate Station 

Temperature (°C/°F) 

Mean-Annual 7.5/45.5 

Low-Monthly Mean −5.7/21.7 

High-Monthly Mean 21.5/70.7 

Precipitation (cm/in) 

Mean-Annual 35.0/13.7 

Low-Monthly Mean 1.4/0.5 

High-Monthly Mean 6.5/2.5 

Snowfall (cm/in) 

Mean-Annual 135/53 

Low-Monthly Mean 0/0 

High-Monthly Mean 22.6/8.8 

Source: National Climatic Data Center (NCDC), 2009. “Climatography of the United States No. 20: Monthly 

Station Climate Summaries, 1971–200.” Asheville, North Carolina: National Oceanic and Atmospheric 

Administration (2004 in NRC). 

health risks and impacts can result indirectly from changes in climate. Based on EPA’s 

determination, NRC recognizes that GHGs may have an effect on climate change. In CLI-09-

21, the Commission provided guidance to the NRC staff to consider carbon dioxide and other 

GHG emissions in its National Environmental Policy Act (NEPA) reviews. GHG emissions were 

considered as an element of the existing air quality assessment. Relevant GHG emissions are 

discussed in both Chapters 4 and 5 of this SEIS. 
Affected Environment 

3-44 

Figure 3-12. Seasonal Wind Roses for the Antelope Coal Company 

Source: modified from Application for U.S. NRC Source Material License Moore Ranch Uranium 
Affected Environment 

 3-45 

3.7.2 Air Quality 

The proposed Moore Ranch Project is located in an attainment area for all the primary 

pollutants. The terrain within the area, combined with windy conditions, provides good 

conditions for dispersion of air pollutants. The closest resident is approximately 4.5 km [2.8 mi] 

from the center of the proposed Moore Ranch Project. 

The WDEQ adopted the EPA National Ambient Air Quality Standards (NAAQS), as summarized 

in Table 3.2-8 of the GEIS (NRC, 2009a). The proposed Moore Ranch Project is located in 

Campbell County, Wyoming, which is an attainment area for all the primary pollutants. The 

dominant emissions from activities at the proposed Moore Ranch Project would be carbon 

monoxide (CO) and particulate matter (PM). CO is an odorless and colorless pollutant. In 

general, CO at ISR projects would be generated primarily by engine combustions (including all 

vehicles as well as stationary motors such as generators). Over 90 percent of CO comes from 

motor vehicles. 

As discussed in Section 3.3.6.2 of the GEIS, the EPA has established air quality standards to 

promote and sustain healthy living conditions. These standards, known as the NAAQS, address 

CO, lead (Pb), nitrogen dioxide (NO2), particulate matter (PM10 and PM2.5), ozone (O3), and 

sulfur dioxide (SO2). EPA revised the NAAQS standards after the preparation of the GEIS. This 

includes a new rolling 3-month average standard for lead at 0.15 μg/m3

 and a new one hour 

nitrogen dioxide standard at 100 parts per billion. EPA revisions to SO2 and O3 standards are 

under consideration but are not finalized (EPA, 2010). States may develop standards that are 

stricter or that supplement the NAAQS. Wyoming has a more restrictive standard for SO2

(annual at 60 μg/m3

 and 24 hours at 260 μg/m3) and supplemental standards for particulate 

matter (annual PM10 at 50 μg/m3

 and 24-hour PM2.5 at 65 μg/m3) (WDEQ, 2008). 

Particulate matter refers to particles found in the air. Some particles are large enough to be 

seen as dust, soot, or smoke, while others are too small to be visible. As noted previously, the 

NAAQS for PM10 and PM2.5, limit the allowable concentration of particulate matter particles 

smaller than 10 and 2.5 micrometers. Emissions from highway and nonroad construction 

vehicles compose approximately 28 percent of total PM10 and PM2.5 emissions. The large 

sources of PM include fugitive dust from paved and unpaved roads, agricultural and forestry 

activities, wind erosion, wildfires, and managed burning. 

The WDEQ Air Quality Division analyzes measurements from 26 stations located throughout 

Wyoming to ensure ambient air quality is maintained, in accordance with NAAQS. Annually, the 

results are synthesized into the Wyoming Ambient Air Monitoring Annual Network Plan (WDEQ, 

2009). The baseline air quality conditions of the proposed Moore Ranch Project were 

determined by evaluating data from four monitoring stations in the region, to provide a 

reasonable representation of the air pollutant levels that could be expected to occur at the site. 

Monitoring data were reviewed for the Wamsutter, Casper, Lander, and Murphy Ridge 

monitoring locations. Furthermore, the GEIS reported that all areas within the Wyoming East 

Uranium Milling Region were classified as being in attainment for NAAQS (NRC, 2009a). 

WDEQ monitors air quality and annually reports the results to EPA. The 2007 monitoring 

results are consistent with the areas attainment status (WDEQ, 2009). Construction activities at 

two locations resulted in a couple of anomalous PM10 readings; however, these were 

attributable to localized, temporary construction activities, and, therefore, not representative. 

Table 3-8 presents the air quality monitoring data for all of the monitoring stations. 
Affected Environment 

3-46 

As discussed in Section 3.3.6.2 of the GEIS, Prevention of Significant Deterioration (PSD) 

requirements identify maximum allowable increases in concentrations for particulate matter, 

SO2, and NO2 for areas designated as attainment. There are several different classes of PSD 

areas, with Class I areas having the most stringent requirements. No Class I areas are present 

in the Wyoming East Uranium Milling Region (NRC, 2009b). GEIS Table 3.4-9 identifies the 

Class I areas in Wyoming, South Dakota, Montana, and Nebraska. GEIS Figures 3.2-16 and 

3.4-20 maps the locations of Class I areas. Wind Cave National Park, the closest Class I area 

to the proposed action, is located about 188 km [117 mi] to the east of the Moore Ranch site. 

Cloud Peak Wilderness Area, the closest Class II area to the proposed action, is located about 

124 km [77 mi] to the northwest of the Moore Ranch site. 

3.8 Noise 

The proposed Moore Ranch Project area is located in rural Campbell County, Wyoming. The 

known land uses within both the proposed Moore Ranch Project and within a 3.2 km [2 mi] 

radius of the proposed project boundary are grazing, wildlife habitat, and CBM recovery 

operations, none of which generate significant noise. Traffic along the road leading to the site 

would generate some noise. Sound levels from CBM operations would be expected to be 

Table 3-8. Existing Conditions—2007 Ambient Air Quality Monitoring Data 

Monitoring 

Stations Wamsutter Casper Lander Murphy Ridge

Distance to 

Site 

290 km 

(180 mi) 

97 km 

(60 mi) 

258 km 

(160 mi) 

484 km 

(300 mi) 

Pollutant Standards 

 (Averaging Time) 

Carbon 

Monoxide 

N/A N/A N/A 0.7 ppm 9 ppm 

(8-hour) 

N/A N/A N/A 0.9 ppm 35 ppm 

(1-hour) 

Lead 1.5 μg/m3 N/A N/A N/A 1.5 μg/m3

(Quarterly Average) 

Nitrogen 

Dioxide 

0.007 μg/m3 

N/A N/A 0.003 μg/m3 100 μg/m3

(Annual) 

Arithmetic Mean) 

Particulate 

Matter (PM10) 

227.0 μg/m3

(Note: 2006 

was 73.0 

μg/m3

) 

30 μg/m3

 40 μg/m3 64 μg/m3 150 μg/m3

(24-hour) 

Particulate 

Matter (PM2.5) 

N/A N/A 26.0 μg/m3 N/A 15 μg/m3

(Annual) 

 (Arithmetic Mean)

N/A N/A 7.6 μg/m3 N/A 35 μg/m3

(24-hour) 

Ozone 0.064 ppm N/A N/A 0.068 ppm 0.08 ppm 

(8-hour) 

Sulfur Dioxide 

0.001 ppm N/A N/A 0.001 ppm 0.03 ppm 

(Annual) 

0.010 ppm N/A N/A 0.002 ppm 0.14 ppm 

(24-hour) 

Source: WDEQ, 2009 
Affected Environment 

 3-47 

unnoticeable from distances of 490 m [1,600 ft] and beyond (BLM, 2003). The closest 

residence to the proposed Moore Ranch Project is located approximately 4.5 km [2.8 mi] from 

the center of the proposed license area. No people reside in the proposed license area 

(EMC, 2007a). 

The Federal Highway Administration (FHWA) and the Wyoming Department of Transportation 

(WYDOT) have noise impact assessment procedures and criteria to help protect the public 

health and welfare from excessive vehicular traffic noise. FHWA established Noise Abatement 

Criteria described in Table 3-9 according to land use, recognizing that different areas are 

sensitive to noise in different ways. A person is considered to be impacted by noise according 

to WYDOT procedures when existing or expected future sound levels approach [within 1 

decibels (dBA)], are or exceed the Noise Abatement Criteria, or when expected future sound 

levels exceed existing sound levels by a substantial amount (15 dBA). These criteria were used 

to assess impacts at the proposed Moore Ranch Project. Cattle grazing, the primary land use 

within the proposed project area generates minor noise. However, SR 387, which crosses 

through the northern portion of the proposed project area and Brown Road, which accesses the 

site, are line sources of noise. Vehicular traffic sound a distance of 15 m [50 ft] from the 

receptor has been estimated at 54 to 62 dBA for passenger cars and 58 to 70 dBA for heavy 

trucks (NRC, 2009a). Because noise from line sources such as roads is reduced by 

approximately 3 dBA per doubling of distance (NRC, 2009a), the maximum truck sound level of 

70 dBA on the shoulder of either SR 387 or Brown Road would diminish to the level of a 

Category “A” Activity, shown in Table 3-9, approximately 480 m [1,575 ft] from the source, 

excluding the noise dampening characteristics of topographic interference and vegetation. 

Table 3-9. Noise Abatement Criteria: 1-Hour, A-Weighted Sound Levels in 

Decibels (dBA) 

Activity 

Category Leq(h)* Description of Activity Category 

A 57 

(Exterior) 

Lands on which serenity and quiet are of extraordinary significance and 

serve an important public need and where the preservation of those 

qualities is essential if the area is to continue to serve its intended 

purposes. 

B 67 

(Exterior) 

Picnic areas, recreation areas, playgrounds, active sports areas, parks, 

residences, motels, hotels, schools, churches, libraries, and hospitals. 

C 72 

(Exterior) 

Developed lands, properties, or activities not included in Categories A or B 

above. 

D -- Undeveloped lands 

E 52 

(Interior) 

Residences, motels, hotels, public meeting rooms, schools, churches, 

libraries, hospitals, and auditoriums. 

*Leq(h) is an energy-averaged, one-hour, A-weighted sound level in decibels (dBA). 

Source: 23 CFR Part 772 

It was assumed that sound levels beyond a distance of 480 m [1,575 ft] from SR 387 and Brown 

Road would approximate 40 dBA, to conservatively overestimate a baseline that is consistent 
Affected Environment 

3-48 

with the GEIS statement that existing ambient noise levels in this region would be 22 to 38 dBA 

(NRC, 2009a). Figure 3.2-17 of the GEIS provides examples of sound levels for common 

activities (NRC, 2009a). 

With regard to wildlife located on the site, field observations suggest that noise from oil and gas 

and CBM operations could affect greater sage-grouse lek activity (Braun, 1998; Wisdom, et al., 

2002). The construction and operation of ISR facilities would involve similar activities. 

However, sage-grouse leks have not been discovered on or near the proposed project area, 

based on a 2007 survey (EMC, 2007a). 

3.9 Historical and Cultural Resources 

Section 3.3.8 of the GEIS provides a general overview of historical and cultural resources for 

the Wyoming East Uranium Milling Region in which the proposed Moore Ranch Project is 

located (NRC, 2009a). This section discusses the cultural background and historic and cultural 

resources identified at the proposed Moore Ranch Project and in the surrounding area. 

No structures or buildings were evaluated for the proposed Moore Ranch Project site since 

potential buildings and structures were previously investigated. Brunette (2007) noted the 

occurrence of “active and abandoned ranch headquarters/ranching related buildings [and] 

earthen dikes/stock ponds” in and around the proposed Moore Ranch Project. None of these 

sites are located in the immediate vicinity of the central plant and proposed wellfields. Site 

48CA146 includes features and remains associated with an abandoned ranch located about 

0.8 km [0.5 mi] south of the proposed wellfield areas. Site 48CA3400, the remains of an historic 

homestead, is located approximately 1.5 mi southwest of the Moore Ranch Project area 

(Brunette, 2007). Site 48CA6173 also contains the remains of an historic homestead. 

Site 48CA6173 is located southwest of the proposed project area (Brunette, 2007). 

The National Historic Preservation Act (NHPA) requires federal agencies to consider the effects 

of their undertakings on historic properties. Historic properties are defined as resources that are 

eligible for listing on the National Register of Historic Places (NRHP). The criteria for eligibility 

are listed in Title 36, “Parks, Forests, and Public Property,” Part 60, Section 4, “Criteria for 

Evaluation,” of the Code of Federal Regulations (36 CFR Part 60.4) and include (1) association 

with significant events in history; (2) association with the lives of persons significant in the past; 

(3) embodies distinctive characteristics of type, period, or construction, and (4) or sites or places 

that have yielded or are likely to yield important information (ACHP, 2010). The historic 

preservation review process (Section 106 of the NHPA) is outlined in regulations issued by the 

Advisory Council on Historic Preservation in Title 36, Parks, Forests, and Public Property, Part 

800, Protection of Historic Properties (36 CFR Part 800). The NRC has coordinated its Section 

106 review for the proposed Moore Ranch Project through NEPA per 36 CFR 800.8(c). 

The issuance of a materials license is a federal action that could possibly affect either known or 

undiscovered historic properties located on or near the proposed Moore Ranch Project. In 

accordance with the provisions of the NHPA, the NRC is required to make a reasonable effort to 

identify historic properties in the area of potential effect (APE). The APE for this review is area 

that may be impacted by construction, operation, aquifer restoration, and decommissioning 

activities associated with the proposed action. If no historic properties are present or affected, 

the NRC is required to notify the State Historic Preservation Office before proceeding. If it is 

determined that historic properties are present, the NRC is required to assess and resolve 

possible adverse effects of the undertaking. 
Affected Environment 

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Cultural resources identification and assessment also considers the ARPA [16 United States 

Code (USC) 469-469c-e] as amended, which covers permitting of archaeological investigations 

on public land such as that managed by the BLM. Finally, State of Wyoming laws dealing with 

protection of archaeological resources also are considered. These various laws and regulations 

were discussed in Appendix B of the GEIS. 

The NRC initiated consultation with the Wyoming State Historic Preservation Office (SHPO), 

under Section 106 of the NHPA (NRC, 2008). A response to an NRC letter was received from 

the Wyoming SHPO on June 5, 2008. By letter dated November 3, 2009, the Wyoming SHPO 

concurred with the determination that the sites located in the proposed project area were 

ineligible for listing on the NRHP (Wyoming SHPO, 2010). 

3.9.1 Cultural History 

The archaeological cultural sequence for the proposed Moore Ranch Project is divided between 

the prehistoric periods (Paleoindian, Archaic, and Late Prehistoric) and the recent 

protohistoric/historic era. The former encompasses about 11,000 years between 12,000 B.P. 

(before present) and 250 B.P. (about A.D. 1700). The protohistoric/historic era ranges from 

A.D. 1700 to A.D. 1959. 

3.9.1.1 Prehistoric Era 

As mentioned previously, the prehistoric periods are divided into Paleoindian, Archaic, and Late 

Prehistoric. The hallmark artifact forms for the Paleoindian period (12000 to 8500 B.P.) in the 

region include, from oldest to youngest, Clovis, Folsom/Goshen, Agate Basin, Hell Gap, Eden, 

Scottsbluff, and Cody. Paleoindian sites in the region, yielding both Pleistocene megafauna and 

Paleoindian artifacts, include the James Allen site in southwestern Wyoming; Hell Gap and 

Agate Basin in eastern Wyoming, located east and southeast of the project; and Medicine 

Lodge Creek in central Wyoming. The Paleoindian period comes to a close in the terminal 

Pleistocene/early Holocene era. The Pleistocene megafauna (e.g., mammoth, muskox) are 

replaced by modern antelope, bison, deer, and elk. These smaller grazers were better adapted 

to the change from savannah to grassland communities that resulted from the onset of warmer 

and drier conditions in the Holocene. The Archaic period (8500 to 1500 B.P.) in eastern and 

northeastern Wyoming is broken into three subperiods: Early (8500 to 5000 B.P.), Middle 

(5000 to 3000 B.P.), and Late (3,000 to 1,500 B.P). 

In general, the regional Early Archaic sites are marked by the presence of various side- and 

corner-notched projectile points and side-notched knives. The subperiod is known for 

semisubterranean houses that are usually marked by the presence of one or more hearths, 

firepits, storage pits, and milling basins. The latter is of particular interest because features 

clearly indicate that floral species were playing an important role in subsistence strategies. The 

Middle Archaic site assemblages reflect a relatively broad spectrum of gathering and hunting 

responses, with an emphasis on bison procurement. By the Late Archaic times, communal 

bison kills occur and recorded examples contain diagnostic Yonkee points (large, cornernotched projectile points), which are the preferred method of felling the bison through the 

subperiod. Late Archaic faunal assemblages demonstrate the presence of smaller game 

animals and midsize ungulates (deer and antelope). 

The Late Prehistoric period (1500 to 300 B.P.) heralds the acceptance of new technologies, 

such as smaller projectile points adapted to use with arrows. Prior to the Late Prehistoric 

period, the points were hafted on spears. Also introduced at this time is earthenware 
Affected Environment 

3-50 

technology, which improves food preparation techniques. Stewing, braising, and boiling were 

now possible, which significantly broadened the number of floral and faunal species that could 

be used. At some time between 1000 and 600 B.P., there is considerable movement of people 

into Wyoming from several directions. Kiowa-Apache and Shoshone-Comanche move into the 

region first, probably in response to several factors including population pressures from eastern 

sedentary groups who had partially adapted to horticultural regimes. Between about 600 B.P. 

(A.D. 1300) and A.D. 1700, the Crow, Cheyenne, and Arapaho all move into Wyoming to pursue 

their bison-oriented lifestyles. 

3.9.1.2 Protohistoric/Historic Era 

The Protohistoric period dates between about A.D. 1700 and 1840. This period includes the 

time when European goods and the domesticated horse are introduced into the region. There is 

no appreciable European presence in the region, with the exception of French fur traders 

moving up and down the Missouri River. Across the northern High Plains, there was active 

trading in European material goods, including metal knives, pots, and glass beads. However, 

Native American goods in similar styles also continued to be produced. The Native American 

tribes continued to pursue Native traditions into the 1900s in the region, although the majority of 

the tribal members were relocated to the Wind River Reservation. 

The Historic era is subdivided into seven periods: Early Historic (A.D. 1801–1842), Preterritorial 

(A.D. 1843–1867), Territorial (A.D. 1868–1889), Expansion (A.D. 1890–1919), Depression 

(A.D. 1920–1939), World War II (A.D. 1940–1946), and Post-World War II (A.D. 1947–1959). 

Various themes have been identified that crosscut the periods. The proposed project area was 

historically used for cattle ranching, with limited oil and gas exploration in the nearby vicinity. 

There is no indication from the proposed project sites identified to date that there were earlier 

historic occupations of the area. Thus, at best, historic occupations are limited to the expansion 

and post-expansion periods. 

3.9.2 Historic and Cultural Resources Identified and Places of 

Cultural Significance 

3.9.2.1 Previous Cultural Resources Investigations 

Seven cultural resource investigations have been conducted on the proposed license area 

dating from 1981 to the present. These investigations have been conducted in support of 

energy extraction activities, including the data used to support the analysis in the NRC draft EIS 

for the Sand Rock Mill Project (NRC, 1982). Four historic investigations overlap the areas that 

could potentially be directly disturbed by the proposed action. 

3.9.2.1.1 Archaeology–Identification and Evaluation 

The proposed Moore Ranch Project site has been subjected to three Class III surveys; two of 

the surveys were completed for earlier projects. In 1981, the Office of the Wyoming State 

Archaeologist (project #WY 56-81) completed a survey in support of the Conoco, Inc. license 

application to the NRC for the Sand Rock Mill (Brunette, 2007). The second survey was 

conducted for permitting CBM wells (Brunette, 2007). 

Systematic cultural resource investigations for the proposed Moore Ranch Project were 

conducted in 2007 (Brunette, 2007), and the results of the site file research and the 
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archaeological survey of the project are filed under BLM Cultural Resource Use Permit 

No. 320-WY-SR05. Brunette (2007) requested or conducted site file searches in August and 

December 2006 and April 2007 prior to fieldwork. Archaeological surveys were conducted in 

phases between September 2006 and July 2007 using standard BLM-mandated survey 

approaches and following the general guidance provided in the State Protocol for the execution 

of Class III surveys. 

Brunette systematically surveyed a total of 492 ha [1,215 ac] using 30-m [100-ft] transects. The 

Brunette 2006 and 2007 surveys resulted in the relocation of Sites 48CA962 through 48CA965, 

48CA967, 48CA970; the identification of seven new sites; and the recording of 25 isolated 

resources. Per the State Protocol between BLM and the Wyoming SHPO, isolated finds are 

ineligible to the NRHP, and no further archaeological consideration was recommended 

(Brunette, 2007). Table 3-10 summarizes newly identified and relocated archaeological sites at 

the proposed Moore Ranch Project. 

Table 3-10. Newly Identified and Relocated Archaeological Sites by Location and 

Site Characteristics 

48CA962 Multicomponent lithic and 

historic scatter 

Not eligible. Site boundaries for site 48CA6695 have 

been expanded to include 48CA962. 

48CA963 Multicomponent lithic and 

historic scatter Not eligible 

48CA964 Multicomponent lithic and 

historic scatter with historic 

feature 

Unevaluated for NRHP eligibility pending further 

evaluative testing. The site would not be impacted by 

proposed action. 

48CA965 Prehistoric: lithic scatter Not eligible 

48CA967 Prehistoric: lithic scatter Not eligible 

46CA970 Multicomponent lithic and 

historic debris scatters Not eligible, site no longer extant 

48CA6691 Prehistoric: lithic scatter 

with hearth Not eligible. 

48CA6692 Prehistoric: lithic scatter 

with hearth and firecracked rock (FCR) 

concentration 

Not eligible. 

48CA6693 Multicomponent lithic and 

historic debris scatters with 

hearth 

Not eligible. 

48CA6694 Multicomponent lithic and 

historic debris scatters with 

shallow historic depression 

Unevaluated for NRHP eligibility pending further 

evaluative testing. The site is outside areas proposed 

for development. The site would not be impacted by 

proposed actions as currently planned. 
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Table 3-10. Newly Identified and Relocated Archaeological Sites by Location and 

Site Characteristics 

48CA6695 Prehistoric: lithic and FCR 

scatter Not eligible. 

48CA6696 Prehistoric: lithic, FCR, 

and groundstone scatter. 

Unevaluated for NRHP eligibility pending further 

evaluative testing. The site is outside areas proposed 

for development. The site would not be impacted by 

proposed actions as currently planned. 

48CA6697 Historic: dump Not eligible. 

Source: Brunette 2007, Wyoming SHPO, 2009; 2010 

The seven newly identified cultural resources include Sites 48CA6691 through 48CA6697. Of 

this grouping, Brunette (2007) recommended Sites 48CA6694 and 48CA6696 as eligible to the 

NRHP. Brunette (2007) also relocated six previously recorded sites from the 1981 survey, 

including area sites 48CA962 through 48CA965, 48CA967, and 48CA970. Site 48CA970 no 

longer exists and requires no additional consideration (Wyoming SHPO, 2009). Of the newly 

identified and relocated sites, three were recommended eligible to the NRHP (48CA964, 

48CA6694, and 48CA6696). However, these sites have not been formally investigated to 

determine their NRHP eligibility. The Wyoming SHPO stated that, until further testing is 

conducted, the NRHP eligibility status of these sites is unevaluated (Wyoming SHPO, 2009). 

These sites are discussed in detail in Section 3.9.3. 

3.9.2.1.2 Ethnology–Identification and Evaluation 

Consultation with the tribes that have heritage interest in the proposed Moore Ranch Project is 

ongoing. Section 106 tribal consultation letters were sent to the following tribes on 

December 24, 2008: Blackfeet, Cheyenne River Sioux, Crow, Eastern Shoshone, Ft. Peck 

Assiniboine/Sioux, Northern Arapaho, Northern Cheyenne, Oglala Sioux, and Three Affiliated 

Tribes. No response has been received indicating that traditional cultural properties or 

landscapes of importance occur within the proposed license area. 

3.9.3 Historic Properties Listed in the National Register of Historic Places 

No cultural resources on the proposed Moore Ranch Project are currently listed in the National 

Register of Historic Places (NRHP). Three sites on the proposed Moore Ranch Project were 

recommended eligible to the NRHP: 48CA964, 48CA6694, and 48CA6696. Two of the sites 

are multicomponent; Site 48CA6696 has only prehistoric artifacts. Site 48CA964 was originally 

recommended eligible to the NRHP by archaeologists from the Office of the Wyoming State 

Archaeologist (project #WY 56-81). The site is a multicomponent, prehistoric/historic site. The 

site has two distinct areas separated by an intermittent drainage. The historic artifacts date 

from the 19th century and include solder dot cans, an oval iron ring, and a tin stove. The 

prehistoric component consisted of a corner-notched projectile point and chipped stone flakes. 

The 1981 flake types are not noted in the Brunette (2007:21) summary of the site; however, the 

occurrence of two chert, tertiary flakes was noted during the 2007 relocation of the resource. 
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Site 48CA6694 is also a multicomponent prehistoric/historic site located near the central plant 

and proposed wellfields. Historic components recovered include architectural remains of a 

structure and associated 20th century refuse. Prehistoric artifacts recovered include fire-cracked 

rock (FCR), a groundstone mano, an Eden projectile point, bifaces, unifaces, and flakes. The 

Eden point is representative of the late Paleoindian Cody Complex. Brunette (2007:12) notes 

that two of the bifaces may be Paleoindian point fragments as well. No subsurface 

investigations were conducted at the site, so it is unknown if the FCR is associated with 

subsurface features. This site was recommended to be eligible to the NRHP because of its 

diagnostic, prehistoric artifacts and the possibility that data from the site could be used to 

address research questions concerning settlement patterns, subsistence strategies, seasonal 

migration rounds, landscape evolution, and climatic reconstruction (Brunette, 2007). 

Site 48CA6696 is located to the east of the proposed Moore Ranch Project. The site is 

prehistoric and consists of a surface scatter of artifacts including groundstone, FCR, chipped 

stone tools, and tools. The tool assemblage lacks temporal diagnostics but does include both 

formed and expedient tools. The flakes recovered suggest that late stage reduction and tool 

maintenance may have occurred at the site. Brunette (2007) recommended the site to be 

eligible to the NRHP because dates obtained from it could be used to address research 

questions concerning settlement, subsistence, and landscape use strategies. However, these 

sites have not been formally investigated to determine their NRHP eligibility. The Wyoming 

SHPO stated that until further testing is conducted, the NRHP eligibility status of these sites is 

unevaluated (Wyoming SHPO, 2009). 

3.9.4 Tribal Consultation and Places of Cultural Significance 

Consultation with Native American tribes was initiated in 2008 (see Section 3.9.2.1.2). No 

places of cultural significance have been identified by Native American tribes or others in the 

proposed project area. Consultation is ongoing and will continue throughout this review. 

3.10 Visual and Scenic Resources 

The proposed Moore Ranch Project is located on private land; therefore, no public agency 

protects scenic quality. However, it is located in prairie landscape of the Powder River Basin in 

the vicinity of public lands that are administered by the Buffalo Field Office of the BLM. The 

BLM evaluates the scenic quality of the land it administers through a Visual Resource Inventory 

(BLM, 2007b) to ensure that the scenic (visual) value is preserved. As part of this inventory, the 

BLM completes a scenic quality evaluation, a sensitivity level analysis, and a delineation of 

distance zones in order to group areas into one of four visual resource management (VRM) 

classes. Class I is the most protected of visual and scenic resources, and Class IV is the 

least restrictive. 

The portion of the Powder River Basin in which the proposed Moore Ranch Project is located is 

characterized as basin and range country with prominent buttes and ridges interspersed by 

rolling grasslands. Semi-permanent streams are fed by intermittent drainages, which 

seasonally drain the adjacent uplands. Past changes to land surfaces include those associated 

with human habitation; the development of stock ponds and reservoirs; access roads; and the 

introduction of gas, oil, and other energy development infrastructure. The proposed license 

area is comprised of about 2,879 ha [7,110 ac] of privately owned land. The surface area 

affected by the proposed operation would be about 61 ha [150 ac] and would consist of 

the central plant, wellfields, and support facilities such as warehouses and chemical 

storage facilities. 
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3-54 

The BLM has established VRM classifications and has resource management plans for all of the 

Wyoming East Uranium Milling Region, which includes the proposed Moore Ranch Project 

(NRC, 2009a). The VRM classifications for the region are shown in Figure 3.3-17 of the GEIS 

(NRC, 2009a). In the past, the landscape has been extensively modified in urban areas and in 

several rural areas by oil, natural gas, coal production, and power generation. The bulk of the 

Wyoming East Uranium Milling Region is categorized as VRM Class III (along highways) and 

Class IV (open grassland, oil and natural gas, urban areas). The BLM resource management 

plans for this region do not identify any VRM Class I resources. 

The area considered for visual resources associated with the proposed Moore Ranch Project 

includes the proposed project site, access roads, and a 3.2 km [2 mi] buffer area outside of the 

proposed license area. Beyond this distance, any changes to the landscape would be in the 

background distance zone, which would either be unobtrusive or imperceptible to viewers. 

Areas and associated viewer types considered to be potentially sensitive to visual changes 

include park, recreation, and wilderness study areas; major travel routes; and residential areas. 

No parks, recreation areas, wilderness study areas, or residential areas occur within the 

proposed Moore Ranch Project. As shown in Figure 2-1, SR 387 traverses the northern section 

of the proposed project site. In addition to the highway, the proposed project area is currently 

used for pastureland, rangeland, and for various types of CBM and gas extraction (see 

Section 3.2, Land Use). These energy extraction facilities have attendant infrastructure systems 

including pipelines, wellfields, and utility lines that occupy land surface areas in the vicinity of 

the proposed project area. 

The BLM has inventoried the landscape within the proposed Moore Ranch Project and the 

surrounding 3.2-km [2-mi] area and rated the areas as VRM Class IV. The management 

objective of VRM Class IV is to provide for management activities that require major 

modification of the existing character of the landscape. The level of change to the characteristic 

landscape can be high, and the proposed action is compatible with these objectives. 

3.11 Socioeconomics 

This section of the SEIS describes current socioeconomic factors that have the potential to be 

directly or indirectly affected by the construction and operation of a new uranium recovery 

facility at the proposed Moore Ranch Project site. The proposed Moore Ranch Project is 

located in the Wyoming East Uranium Milling Region, which is described in Section 3.3.10 of the 

GEIS (NRC, 2009a). The proposed ISR facility and the people and communities that would 

support it can be described as a dynamic socioeconomic system. The communities provide the 

people, goods, and services required to construct and operate the facility. Construction and 

operations, in turn, create the demand for people, goods, and services and pays for them in the 

form of wages, salaries, and benefits, and payments for goods and services. Income from 

wages and salaries and payments for goods and services is then spent on other goods and 

services within the community, thus creating additional opportunities for employment 

and income. 

The proposed Moore Ranch Project is located in a rural portion of Campbell County between 

the small towns of Midwest and Wright. The city of Gillette is located approximately 80 km 

[50 mi] to the northeast of the proposed project site, and it is home to over half of the Campbell 

County population (approximately 20,000 people). The city of Casper is located approximately 
Affected Environment 

 3-55 

85 km [53 mi] southwest of Moore Ranch. Casper is located in Natrona County and has a 

relatively large population of approximately 50,000 people. The city of Douglas, located 

approximately 96 km [60 mi] southwest of the proposed project area, and the town of Glenrock, 

located approximately 77 km [48 mi] south of the proposed project area may also provide 

workers and housing for the proposed ISR construction and operations (NRC 2009b; USCB, 

2009). The socioeconomics region of influence (ROI) is defined by the area where employees 

and their families would reside, spend their income, and use their benefits, thereby affecting the 

economic conditions of the region. 

Most of the construction and operations workers for the proposed ISR facility would likely come 

from several surrounding communities in Campbell County. Additional workers would also 

come from communities in Converse, Johnson, and Natrona counties. Given that most 

employees would reside near the ISR facility, the most significant impacts of plant construction 

and operations are likely to occur in Campbell County. The focus of the analysis in this SEIS is, 

therefore, on the impacts of the proposed ISR facility in the ROI, Campbell County. 

The following subsections describe the demographics, income, housing, employment structure, 

local finance, and education and public services in the ROI surrounding the proposed ISR 

facility at the proposed Moore Ranch site. 

3.11.1 Demographics 

Campbell County is currently home to an estimated population of approximately 

40,000 residents (USCB, 2010). The population of Campbell County is mostly comprised of 

White nonHispanics, with Hispanic, American Indian, and other races each comprising less than 

5 percent of the population. Table 3-11 shows population projections and growth rates from 

1980 to 2050 in Campbell County. The population in Campbell County has grown and is 

projected to continue to grow at a declining rate through 2050. 

Table 3-11. Population and Percent Growth in Campbell County, Wyoming, from 1980 

to 2050 

Year Population Percent Growth* 

1980 24,367 — 

1990 29,370 20.5 

2000 33,698 14.7 

2008 41,473 23.1 

2010 43,440 28.9 

2020 52,130 20.0 

2030 59,990 15.1 

2040 68,403 14.0 

2050 76,678 12.1 

— = No data available. 

*Percent growth rate is calculated over the previous decade. 

Sources: Population data for 1980–2000 [U.S. Census Bureau (USCB), 2010]; 2008 estimate (USCB, 

2010); projected population data for 2010–2030 

Sources: USCB, 2010; Wyoming Department of Administration and Information, Economic Analysis 

Division, 2008 <http://eadiv.state.wy.us] July 2008>; population projections for 2040 and 2050 

(calculated)]. 
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3-56 

The 2000 demographic profile of the population in Campbell County is presented in Table 3-12. 

Persons self-designated as minority individuals comprise about 6.0 percent of the total 

population in 2000. The minority population is composed largely of Hispanic or Latino residents 

According to the U.S. Census Bureau (USCB) 2006–2008 American Community Survey 3-Year 

Estimates, minority populations were estimated to have increased by approximately 

1,300 persons and comprised 8.3 percent of the county population (see Table 3-13). Most of 

Table 3-12. Demographic Profile of the Population in Campbell County in 2000 

Campbell 

County Percent 

Total Population 33,698 — 

Race (Not-Hispanic or Latino)

White 31,701 94.1 

Black or African American 47 0.1 

American Indian and Alaska Native 280 0.8 

Asian 100 0.3 

Native Hawaiian and Other Pacific Islander 28 0.1 

Some other race 11 0.0 

Two or more races 340 1.0 

Ethnicity

Hispanic or Latino 1,191 3.5 

Minority Population (including Hispanic or Latino ethnicity)

Total minority population 1,997 5.9 

Source: US Census Bureau 2010, Census 2000 Summary File 1 (SF 1) 100-Percent Data, Table P4, Hispanic 

or Latino, and Not Hispanic or Latino by Race for Campbell County, Wyoming <http://factfinder.census.gov>; 

USBC, 2010. 

Table 3-13. Demographic Profile of the Population in Campbell County, 2006–

2008 Three-Year Estimate 

Campbell 

County Percent 

Total Population 40,121 — 

Race (Not-Hispanic or Latino)

White 36,805 91.7 

Black or African American 189 0.5 

American Indian and Alaska Native 380 0.9 

Asian 204 0.5 

Native Hawaiian and Other Pacific Islander 0 0.0 

Some other race 82 0.2 

Two or more races 481 1.2 

Ethnicity

Hispanic or Latino 1,980 4.9 

Minority Population (including Hispanic or Latino ethnicity)

Total minority population 3,316 8.3 

Source: US Census Bureau, 2010; ACS Demographic and Housing Estimates, 2006–2008; American 

Community Survey 3-Year Estimates; Hispanic or Latino and Race for Campbell County, Wyoming 

http://factfinder.census.gov USBC, 2010 

this increase was due to an estimated influx of Hispanic or Latinos (approximately 800 persons), 

an increase in population of over 66 percent from 2000. The next largest increase in minority 

population was Black or African American, an increase of approximately 140 persons 

from 2000. 
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 3-57 

3.11.2 Income 

Estimated income information for the ROI is presented in Table 3-14. According to the USCB 

2006–2008 American Community Survey 3-year estimates, median household and per capita 

income in Campbell County were both above the Wyoming average. An estimated 5.1 percent 

of the population and 4.2 percent of families in Campbell County were living below the official 

poverty level (USCB, 2010). 

According to the USCB 2006–2008 American Community Survey 3-year estimates, the annual 

unemployment average for Campbell County was 3.1 percent, which was slightly lower than the 

annual unemployment average of 3.5 percent for Wyoming (USCB, 2010); however, those rates 

doubled by the first quarter of 2009 to 4.1 percent. 

Table 3-14. Income Information for the Region of Influence 2006–2008 American 

Community Survey 3-Year Estimates 

Campbell 

County Wyoming 

Median household income (dollars)* 76,666 53,096 

Per capita income (dollars)* 31,122 27,873 

Percent of families below the poverty level 4.2 5.5 

Percent of persons below the poverty level 5.1 8.9 

Source: U S Census Bureau (2010), 2006–2008 American Community Survey 3-Year Estimates, Economic 

Characteristics for Campbell County and Wyoming <http://factfinder.census.gov> USCB, 2010. 

*In 2008 inflation-adjusted dollars.

3.11.3 Housing 

Table 3-15 lists the total number of occupied housing units, vacancy rates, and median value in 

Campbell County. According to the 2000 Census, there were over 13,000 housing units in the 

ROI, of which approximately 12,000 were occupied. The median value of owner-occupied units 

was $102,900. 

By 2008, the total number of housing units in Campbell County had grown by almost 1,700 units 

to 14,959, while the total number of occupied units also grew by 1,700 units to 13,907. As a 

result, the number of available vacant housing units decreased slightly by almost 30 units to 

1,052, or 7 percent of all housing units (USCB, 2010). 

3.11.4 Employment Structure 

Between 2000 and 2008, the civilian labor force in Campbell County increased by approximately 

31 percent to 24,566 (USCB, 2010). The largest source of employment in Campbell County is 

the mining industry, which accounts for 27 percent of all jobs but 40 percent of all earnings in 

the county. Government-related jobs are the second largest employers in Campbell, providing 

13 percent of the total job force, and retail trade accounts for 10 percent of the employment. 

3.11.5 Local Finance 

Campbell County taxes commercial personal property. The County determines assessed 

valuation of commercial property at 11.5 percent of the market value (Wyoming Department of 

Revenue, 2001). 
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3-58 

Wyoming has a 5 percent sales tax and allows counties to increase sales tax up to 4 percent 

above the state rate. Campbell County has an additional 0.25 percent sales and use tax for a 

total of 5.25 percent (Liu, 2008). The additional tax added by the county comes back to 

Table 3-15. Housing in Campbell County, Wyoming 

2000 

Total 13,288 

Occupied housing units 12,207 

Vacant units 1,081 

Vacancy rate (percent) 8.1 

Median value (dollars) 102,900 

2006–2008; 3-year Estimate 

Total 14,959 

Occupied housing units 13,907 

Vacant units 1,052 

Vacancy rate (percent) 7.0 

Median value (dollars) 200,200 

Source: US Census Bureau, 2010, 2006–2008 American Community Survey 3-Year Estimates, Housing 

Characteristics for Campbell County for years 2000 and 2006–-2008 <http://factfinder.census.gov> USCB, 2010. 

the county and only receives a portion of the 5 percent state tax. The average property tax rate 

in Campbell County is 6.25 percent. 

3.11.6 Education 

The Campbell County School district currently enrolls 7,500 students. Campbell County 

School District #1, including the Gillette area, had a student-to-teacher ratio of 12.98 to 1 in 

2007 (Wyoming Department of Education, 2007). By 2009, the student-to-teacher ratio was 

19.2 to 1 (Campbell County School District, 2009). 

3.11.7 Health and Social Services 

The primary care facility in Campbell County is the Campbell County Memorial Hospital, which 

is located in Gillette. The hospital also has two branch clinics located in Gillette and the town of 

Wright (Wyoming Hospital Association, 2009). The closest medical center offering full service 

emergency services is the Wyoming Medical Center in Casper, located approximately 87 km 

(54 mi) southwest of the proposed Moore Ranch Project. There are a variety of utility service 

providers in the area. 

3.12 Public and Occupational Health and Safety 

The purpose of this section is to summarize the natural background radiation levels in and 

around the proposed Moore Ranch Project area. Descriptions of these levels are known as 

“preoperational” or “baseline” radiological conditions, and they would be used for evaluating 

potential radiological impacts associated with ISR operations. Also included in this chapter of 
Affected Environment 

 3-59 

the document are descriptions of applicable safety criteria and radiation dose limits that have 

been established for public protection and occupational health and safety. 

Radiation dose is a measure of the amount of ionizing energy that is deposited in the body. 

Ionizing radiation is a natural component of the environment and ecosystem, and members of 

the public are exposed to natural radiation continuously. Radiation doses to the general public 

occur from radioactive materials found in the earth soils, rocks, and minerals. Radon-222 is a 

radioactive gas that escapes into ambient air from the decay of uranium (and its progeny, 

radium-226) found in most soils and rocks. Naturally-occurring low levels of uranium and 

radium are also found in drinking water and foods. Cosmic radiation from outer space is 

another natural source of radiation. In addition to natural sources of radiation, there are also 

artificial or manmade sources that contribute to the dose received by the general public. 

Medical diagnostic procedures using radioisotopes and x-rays are a primary manmade radiation 

source. The National Council for Radiation Protection (NCRP) in its Report No. 160, estimates 

the annual average dose to the public from all natural background radiation sources (terrestrial 

and cosmic) is 3.1 millisieverts ([mSv) [310 millirem (mrem)]. The annual average dose to the 

public from all sources (natural and manmade) is 6.2 mSv [620 mrem] (NCRP, 2009). 

3.12.1 Background Radiological Conditions 

In accordance with NRC regulations contained in 10 CFR Part 40, Appendix A, Criterion 7, a 

preoperational monitoring program was developed and implemented to establish baseline 

conditions at the proposed project site. Results of the baseline radiological environmental 

monitoring provide data on background levels that can be used for evaluating future impacts 

from routine facility operations or from accidental or unplanned releases. The scope of the 

baseline program conducted for the proposed Moore Ranch Project is generally consistent with 

the NRC guidelines in Regulatory Guide 4.14 (NRC, 1980). As a result of the NRC’s safety 

review, Uranium One will be required by a license condition to collect additional baseline data. 

Following the guidance of Regulatory Guide 4.14 (NRC, 1980), some of the specific sampling 

methods included 

• An integrated gamma scan survey using gamma sensitive NaI(Tl) detectors using global 

positioning systems (GPS) for mapping the ambient gamma radiation levels across the 

proposed site; 

• Soil samples, including surface soil (top 5 cm depth), 15-cm depth samples and 1-m depth 

samples. All samples were analyzed for radium-226. Selected samples were also analyzed 

for uranium, thorium-230, and lead-210; 

• Sediment samples from primary stream drainage areas and surface water impoundments; 

• Ambient gamma and radon monitoring, using thermoluminescent dosimeters for total 

ambient gamma and alpha track etch dosimeters for radon; 

• Airborne particulate sampling, collected weekly with quarterly composite (by location) 

analysis. Samples were analyzed for uranium, thorium-230, radium-226, and lead-210; 

• Groundwater and surface water sampling with analysis for gross alpha and gross beta, 

uranium, thorium-230, radium-228, radium-226, polonium-210, and lead-210; and 
Affected Environment 

3-60 

• Vegetation (short grasses and clover) samples with analysis for uranium, thorium-230, 

radium-226, polonium-210, and lead-210. 

The intent of the overland gamma survey was to characterize and quantify natural background 

or preoperational radiation level and radionuclide concentrations in soils throughout the 

proposed license area. As shown in Section 6.1.2 of the environmental report, the average 

results for measured gamma radiation are within the range of gamma radiation levels typically 

measured in this region of Wyoming. The applicant identified elevated areas as likely 

attributable to their physical features, such as hilltops and exposed rock, which are known to 

demonstrate elevated levels of natural background radioactivity (EPA, 2006). Similar variability 

in surface or near-surface measurements taken at other Wyoming sites have been attributed to 

natural radioactivity potentially influenced by weathering factors, such as erosion and/or 

deposition (Whicker, et al., 2008). 

Surface and subsurface soil samples were analyzed for radium-226, uranium, thorium-230, and 

lead-210. As presented in Section 6.1.3 of the environmental report and Addendum 6.2A, 

surface soil samples results were consistent with typical background U.S. ranges (EMC, 2007a). 

The average radium-226 concentration for surface samples from the proposed Moore Ranch 

Project was 1.2 pCi/g, with a maximum value of 4.8 pCi/g. The average radium-226 

concentration for subsurface samples was 2.5 pCi/g, with a maximum value of 9.2 pCi/g. 

Sediment samples collected from streambeds were analyzed for radium-226, uranium, 

thorium-230, and lead-210. As presented in Section 6.1.4 and Addendum 6.2A of the applicant 

environmental report, results for the majority of the sediment samples were consistent with 

typical U.S. background ranges (EMC, 2007a). The average radium-226 concentration was 

1.2 pCi/g, with a maximum value of 3.1pCi/g. The uranium average was 1.9 pCi/g, with a 

maximum value of 9.6 pCi/g. The lead-210 average was 3.3 pCi/g, with a maximum value of 

11 pCi/g. The thorium-230 average was 1 pCi/g, with a maximum value of 3.2 pCi/g. 

Generally, all average values are consistent with the typical range of background concentrations 

[0.5 to 2 pCi/g] for these radionuclides (EMC, 2007a). Similar results were reported for pond 

sediment samples. 

The applicant placed radon samplers, along with passive gamma detectors, in 10 downwind and 

upwind locations and obtained baseline measurements. Twelve months of sampling results are 

presented in Section 6.1.5 of the applicant environmental report and Addendum 6.2A (EMC, 

2007a). Reported average radon-222 results for all sampling locations range from 0.1 to 

1.7 picocuries/L in air and are consistent with typical background levels. Gamma 

measurements collected at these same sampling locations range from 0.41 to 0.78 mSv [41 to 

78.5 mrem] per quarter and are consistent with typical U.S. background levels (NCRP, 2009). 

The applicant also collected air particulate samples at 4 locations over 12 consecutive months. 

Air samples were collected on a weekly basis to prevent dust loading the filters; composited for 

a given quarter; and analyzed for radium-226, uranium, thorium-230, and lead-210. Air 

samplers were located at the nearest residence, an upwind (background) location, and selected 

downwind locations within the proposed license area, based on NRC regulatory Guide 4.14 

criteria. Results were reported in Section 6.1.6 of the applicant environmental report and 

Addendum 6.2A and include the following (EMC, 2007a): 

• Uranium: Concentrations ranged from zero (with a detection level of 1 × 10−16

microcuries per milliliter) to 7.22 × 10−16 μCi/mL. 
Affected Environment 

 3-61 

• Thorium-230 (Th-230): Concentrations ranged from zero (with a detection level of 

1 × 10−16 μCi/mL) to 2.14 × 10−15 μCi/mL. 

• Radium-226 (Ra-226): Concentrations ranged from zero (with a detection level of 

1 × 10−16 μCi/mL) to 8.64 × 10−16 μCi/mL. 

• Lead-210 (Pb-210): Concentrations ranged from zero (with a detection level of 

2 × 10−15 μCi/mL) to 3.59 × 10−14 μCi/mL. 

These values are within levels measured at other locations across the region and the 

United States (NCRP, 2009). 

The applicant collected groundwater samples at 11 locations over 12 consecutive months. 

Water samples were collected on a quarterly frequency and analyzed for gross alpha, gross 

beta, radium-226, radium-228, uranium, thorium-230, polonium-210, and lead-210. Monitoring 

wells are located within the proposed production and project areas, based on NRC Regulatory 

Guide 4.14 criteria. The monitoring results are reported in Section 6.1.8 of the applicant 

environmental report and Addendum 6.2A (EMC, 2007a). Except for a limited number of 

elevated values for radium and uranium, as may be expected for an environment with such a 

number of elevated uranium deposits and where there was historic drilling and exploration 

activity, the results were consistent with typical groundwater background levels. 

Surface water samples were collected at eleven locations over two consecutive quarters. There 

was insufficient water to sample during the last two quarters of the year. Water samples were 

collected on a quarterly frequency and analyzed for gross alpha, gross beta, radium-226, 

radium-228, uranium, thorium-230, polonium-210, and lead-210. Sampling locations were 

located within the proposed production and project areas, following NRC Regulatory 

Guide 4.14. The sampling results are reported in Section 6.1.9 of the applicant environmental 

report (EMC, 2007a). Except for lead-210 and uranium, sample concentration results were 

either below limits of detection or considered consistent with the range of values for typical 

background surface water measurements. Two samples from within the same drainage area 

had lead-210 results above the proposed EPA drinking water standard of 1 pCi/L in the Fall of 

2006. One of the samples is considered an analytical error (EMC, 2007a). Follow-up samples 

taken 5 months later from the same sample points were below analytical reporting limits for 

lead-210. Most sample results identified dissolved uranium above analytical reporting limits, 

with some results approaching the EPA drinking water standard of 30 μg/L (approximately 

20 pCi/L). These elevated uranium results appear to be the background levels for dissolved 

uranium in surface water for the area. 

Section 6.1.10 of the applicant environmental report presents results for three vegetation 

samples collected within the proposed license area (EMC, 2007a). Vegetation types sampled 

included sage brush and grasses. Samples were analyzed for radium-226, uranium, 

thorium-230, lead-210, and polonium-210. All results are consistent with typical vegetation 

background levels. 

The results of the sampling and analysis as summarized in Section 6.1 of the applicant’s 

environmental report, provide data suitable for describing the natural, preoperational 

background radiation levels for the area surrounding the proposed facility (EMC, 2007a). 
Affected Environment 

3-62 

3.12.2 Public Health and Safety 

NRC has the statutory responsibility, under the Atomic Energy Act (AEA), as amended by the 

Uranium Mill Tailings Radiation Control Act, to protect the public health and safety and the 

environment. The NRC regulations in 10 CFR Part 20 specify annual dose limits to members of 

the public of 1 mSv [100 mrem] total effective dose equivalent and 0.02 mSv per hour 

[2 mrem per hour] from any external radiation sources. This public dose limit from NRC 

licensed activities is a fraction of the background radiation dose, as discussed in Section 3.12.1. 

A review of the area within 80 km (50 mi) around the proposed facility indicated that there is one 

current and several potential uranium mining facilities: 

• Smith Ranch-Highland—An operational in-situ uranium facility located approximately 

58 km [36 mi] south of Moore Ranch 

• Christensen Ranch—Irigaray Located approximately 31 and 42 km [19 and 26 mi] 

northwest of Moore Ranch. The Christensen Ranch site was recently granted an NRC 

license amendment to restart in-situ recovery operations. 

• North Butte Project—Located approximately 26 km [16 mi] north of Moore Ranch. This 

is a satellite facility for the Smith Ranch-Highland facility. It is not currently constructed 

or operational. 

• Ruth Project—Located approximately 21 km [13 mi] west of Moore Ranch. This is a 

satellite facility for the Smith Ranch-Highland facility. It is not currently constructed 

or operational. 

• Nichols Ranch-Hank Unit—Located approximately 32 km [20 mi] northwest of Moore 

Ranch. This is a proposed in-situ uranium facility that is currently undergoing 

licensing activities. 

Because of their relative distances, none of these projects are expected to cause an 

appreciable contribution to the background radiation exposures to individuals in the area. Other 

than CBM, there are no major sources of nonradioactive, chemical releases into the atmosphere 

or water-receiving bodies in the immediate area surrounding the proposed site. 

3.12.3 Occupational Health and Safety 

NRC regulates occupational health and safety risks to workers from exposure to radiation, 

mainly through its Radiation Protection Standards contained in 10 CFR Part 20. In addition to 

annual radiation dose limits, these regulations incorporate the principal of maintaining doses “as 

low as reasonably achievable,” (ALARA) taking into consideration the purpose of the licensed 

activity and its benefits, technology for reducing doses, and the associated health and safety 

benefits. To comply with these standards, radiation safety measures are implemented for 

protecting workers at uranium ISR facilities, ensuring radiation exposures and resulting doses 

are less than the occupational limits as well as ALARA. 

Also of concern, with respect to occupational health and safety, are industrial hazards and 

exposure to nonradioactive pollutants, which for an ISR operation can include normal industrial 

airborne pollutants associated with service equipment (e.g., vehicles), fugitive dust emissions 
Affected Environment 

 3-63 

from access roads and wellfield activities, and various chemicals used in the in-situ extraction 

process. Industrial safety aspects associated with the use of hazardous chemicals at the 

proposed Moore Ranch Project would be regulated by the Occupational Safety and Health 

Administration (OSHA). The type of chemicals and permitted levels are discussed in 

Section 4.13.1. 

As an industry, in-situ uranium recovery represents a lower level of health and safety risks to its 

workers, compared with conventional mining, considering the less intrusive mining methods and 

reduced exposure to hazards common with open-pit or shaft mining (IAEA, 2001, EMC, 2007a). 

3.13 Waste Management 

Chapter 2 of this SEIS described the types and volumes of liquid and solid waste that would be 

generated by the operation of the proposed Moore Ranch Project. The disposal options being 

considered include the use of a sanitary landfill for disposal of nonradioactive solid wastes, a 

licensed waste disposal site or mill tailings facility for byproduct material, deep disposal wells for 

liquid effluents, and an onsite septic system for sanitary waste. No mixed waste would be 

generated from implementing the alternatives. The applicant expects that the proposed Moore 

Ranch Project would be classified as a Conditionally Exempt Small Quantity Generator of 

hazardous waste under the Resource Conservation and Recovery Act. The WDEQ will make 

that determination. Section 2.1.1.1.6 of this SEIS discusses the expected annual waste 

volumes that would be generated. This section describes the disposition of the wastes that 

would be generated by the proposed Moore Ranch Project. 

3.13.1 Liquid Waste Disposal 

Liquid wastes generated from operation of the proposed Moore Ranch Project would include 

sanitary waste water, waste water generated from well development and well testing, and liquid 

effluent generated by the ISR process [liquid byproduct material]. Domestic waste water from 

restrooms and lunchrooms would be disposed of in a WDEQ-approved septic system. Except 

for well development and well test waters (which would be uncontaminated and could be 

discharged to the surface), all remaining liquid effluent generated from production bleed and 

plant wash-down water would be byproduct material to be disposed of via deep well injection, as 

described under the proposed action in Section 2.1.1.1.6.2 of this SEIS. 

3.13.2 Solid Waste Disposal 

Solid byproduct material (including radioactively contaminated soils or other media) that does 

not meet NRC unrestricted release criteria must be disposed of at a facility permitted to receive 

byproduct material. As discussed in Section 2.1.1.1.6.3, the proposed action would annually 

generate approximately 76 m3 [100 yd3

] of solid byproduct material (that does not meet NRC 

criteria for unrestricted release). Because the applicant is proposing to construct more than one 

wellfield, the cumulative estimate for byproduct material from decommissioning the plant 

facilities and all wellfields (over a planned 5-year period) is 3,295 m3 [4,310 yd3

], plus 423 t [470 

T] of concrete. The applicant has indicated that its preferred destination for byproduct material 

generated by operations of the proposed Moore Ranch Project would be the Pathfinder Mines 

Corporation Shirley Basin site, located approximately 213 km [132 mi] from the proposed Moore 

Ranch Project. The Pathfinder Mines Corporation site is limited, under an agreement with the 

WDEQ, to receive a total of 37,490 m3

 [49,000 yd3] of waste. A formal disposal agreement 

between the applicant and Pathfinder Mines Corporation is being negotiated but has not yet 

been finalized (Uranium One, 2009a, 2010). This agreement must be in place before the 
Affected Environment 

3-64 

applicant begins its proposed ISR operations. The applicant has identified an alternate location 

for disposal of this waste as the Energy Solutions disposal site in Clive, Utah. The applicant is 

negotiating a draft disposal agreement with this site, as a contingency measure (Uranium 

One, 2010). 

As discussed in Section 2.1.1.1.6.3, solid wastes are materials that are not hazardous and are 

either nonradioactive or comply with NRC unrestricted release limits. Solid wastes generated 

by the proposed Moore Ranch Project would include general facility trash, septic system solids, 

construction/demolition debris, and any solid byproduct material (such as piping, valves, 

instrumentation, or equipment) that has been decontaminated to meet NRC criteria for 

unrestricted release. The proposed operations activities during operations would annually 

generate approximately 1,530 m3

 [2,000 yd3], and decommissioning activities would generate 

about 45,500 m3

 (59,500 yd3) of solid waste (Uranium One, 2010). The applicant has proposed 

disposing of solid wastes at the City of Casper landfill in Casper, Wyoming, approximately 97 

km [60 mi] from the proposed Moore Ranch Project site. The applicant would transport the 

wastes either directly to the Casper facility or to a permitted transfer station located at the 

Midwest/Edgerton landfill, located approximately 39 km [24 mi] from the proposed Moore Ranch 

Project site. The Casper landfill has a permitted capacity of 317,000,000 m3

 [414,000,000 yd3] 

of compacted solid waste and a life expectancy of 1,400 years (Uranium One, 2010). 

 As discussed in Section 2.1.1.1.6.3, the applicant likely anticipates being classified as a 

Conditionally Exempt Small Quantity Generator of hazardous wastes, generating less than 

100 kilograms per month of these wastes. The City of Casper operates a hazardous waste 

collection program for conditionally exempt small quantity generators at its landfill special waste 

and diversion facility. The applicant proposes to transport the small quantities of hazardous 

wastes it generates to this facility (Uranium One, 2010). 

3.14 References 

23 CFR Part 772. Code of Federal Regulations, Title 23, Highways, Part 772, “Procedures for 

Abatement of Highway Traffic Noise and Construction Noise.” 

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

Part 800, “Protection of Historic Properties.” 

69 FR 933, U.S. Fish and Wildlife Service, 2004. “Endangered and Threatened Wildlife and 

Plants; 90-day Finding for a Petition to List the Eastern Subspecies of the Greater Sage-Grouse 

as Endangered.” Federal Register: Vol. 69, No. 4. pp. 933–936. January 7. 

74 FR 66496, EPA (U.S. Environmental Protection Agency), 2009. “Endangerment and Cause 

or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act.” 

Federal Register: Vol. 74, No. 239. pp. 66,496-66,546. December 15. 

75 FR 13909, FWS (U.S. Fish and Wildlife Service), 2010. “Endangered and Threatened 

Wildlife and Plants; 12-Month Findings for Petitions to List the Greater Sage-Grouse 

(Centrocercus urophasianus) as Threatened or Endangered.” Federal Register. Vol. 75, 

No. 55. pp. 13,909–13,959. March 23. 

ACHP (Advisory Council on Historic Preservation), 2010. “National Register Evaluation 

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Affected Environment 

 3-65 

Basin Electric, 2009. “Dry Fork Station – Basin Electric Power Cooperative.” 

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BLM (U.S. Bureau of Land Management, 2010. Instruction Memorandum No. 2010-071. 

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Development (Supplement to National Sage-Grouse Habitat Conservation Strategy). 

Washington, DC: U.S. Department of Interior Bureau of Land Management. 

BLM, 2009. “Sage-Grouse Management.” <http://www.blm.gov/wy/st/en/field_offices 

/Buffalo/wildlife/data.html#SG> (14 April 2009). 

BLM, 2008. “Bureau of Land Management Buffalo Field Office Environmental Assessment for 

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Wyoming: BLM. 

BLM, 2007a. “Raptor Nest Sites 2007 Located Within the Wyoming BLM Buffalo Field Office 

Jurisdiction.” GIS data files from Bureau of Land Management Buffalo field office. Accessed 

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BLM, 2007b. “Visual Resource Management.” Manual 8400. <http://www.blm.gov/nstc/ 

VRM/8410.html> 

BLM, 2004. National Sage-Grouse Habitat Conservation Strategy. U.S. Department of Interior 

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etc/medialib/blm/wy/wildlife.Par.9226.File.dat/02species.pdf> (28 September 2009). 

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Proceedings of the Western Association of Fish and Wildlife Agencies 78: pp. 139–156. 1998. 

Brunette, J.A., 2007. “Class III Cultural Resources Inventory for the Energy Metals Corporation, 

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Campbell County School District, 2009. Gillette, WY. <http://www.campbellcountyschools.net>. 

Chapman, S.S., S.A. Bryce, J.M. Omernik, D.G. Despain, J. ZumBerge, and M. Conrad, 2004. 

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Affected Environment 

3-66 

EMC (Energy Metals Corporation U.S.), 2007a. “Application for USNRC Source Material 

License, Moore Ranch Uranium Project, Campbell County, Wyoming, Environmental Report.” 

Casper, Wyoming: Uranium One Americas Corporation. ADAMS Accession 

Nos. ML072851222, ML072851229, ML072851239, ML07285249, ML07285253, ML07285255. 

EMC, 2007b “Application for USNRC Source Material License, Moore Ranch Uranium Project, 

Campbell County, Wyoming, Technical Report.” Casper, Wyoming: Uranium One Americas 

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Endangered Species Act of 1973. 16 USC 1531–1544. 

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(NAAQS).” < http://epa.gov/air/criteria.html> (06 May 2010). 

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Fertig, W., 2008. “State Species Abstract: Penstemon Haydenii, Blowout Penstemon.” 

Wyoming Natural Diversity Database, University of Wyoming. <http://www.uwyo.edu/ 

wynddsupport/docs/Reports/SpeciesAbstracts/Penstemon_haydenii.pdf> (28 September 2009). 

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FWS, 2008a. Letter from U.S. Fish and Wildlife Service Ecological Services to G.Suber, 

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Status Evaluation.” South Dakota Field Office. Pierre, South Dakota. 

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 3-67 

NCDC (National Climatic Data Center), 2009. “Climatography of the United States No. 20: 

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(6 October 2009). ADAMS Accession No. ML092940037. 

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Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

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Managers, Office of Federal and State Materials and Environmental Management Programs. 

Subject: Informal Meetings with Local, State, and Federal Agencies in Wyoming Regarding the 

Environmental Reviews Being Conducted on the Moore Ranch, Nichols Ranch, and Lost Creek 

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Report.” Washington, DC: NRC. June. 

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Uranium One (Uranium One Americas), 2010. “Responses to NRC Waste Management 

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Uranium One (Uranium One Americas), 2009a. “Responses to Request for Additional 

Information for the Moore Ranch In-Situ Uranium Recovery Project License Application (TAC 

JU011).” ADAMS Accession No. ML092450317. August 31. 
Affected Environment 

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Uranium One, 2009b. “Response to Request for Additional Information for the Moore Ranch 

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No. ML082060527. July 11. 

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Notification (PCN).” Letter to J. Winter from M.A. Bilodeau, Program Manager, Department of 

the Army Corps of Engineers. May 10. 

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for Counties: April 1, 2000, to July 1, 2009, for Wyoming.” 

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USCB, 2009. “State and County QuickFacts for Campbell, Johnson, and Natrona Counties 

Wyoming.” <http://quickfacts.census.gov> (10 September 2009). 

USDA (U.S. Department of Agriculture), 2009. “PLANTS Database.” Distribution of StateListed Plants in Campbell and Johnson Counties, Wyoming. <http://plants.usda.gov/index.html> 

(28 September 2009). 

Wyoming Department of Administration and Information, Department of Economic Analysis, 

2008. “Population of Wyoming, Counties, Cities, and Towns: 2000 to 2013.” July. 

<http://eadiy.state.wy.us/pop/wyc&sc30.htm>. (24 May 2010). 

WDEQ (Wyoming Department of Environmental Quality), 2009. “Wyoming Ambient Air 

Monitoring Annual Network Plan 2009.” <http://deq.state.wy.us/aqd/downloads/AirMonitor/ 

Network%20Plan_2009.pdf> (14 September 2009). 

WDEQ, 2008. “Chapter 2, Ambient Standards.” <http://deq.state.wy.us/aqd/standards.asp> (6 

May 2010). 

WGFD (Wyoming Game and Fish Department), 2010. “Recommendations for Development of 

Oil and Gas Resources Within Important Wildlife Habitats.” Version 6.0. Cheyenne, Wyoming: 

WGFD. April. 

WGFD, 2009. “Big Game Crucial Range Maps, Cheyenne, Wyoming.” <http://gf.state.wy.us/ 

habitat/index.asp> April. 

WGFD, 2006a. “2006 Big Game Job Completion Reports—Job Completion Report, Sheridan 

Wyoming Region.” <http://gf.state.wy.us/wildlife/jobcompetionreports/index.asp> pp. 2-21, 

124–133. 
Affected Environment 

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WGFD, 2006b. “2006 Big Game Job Completion Reports—Job Completion Report, Casper 

Wyoming Region.” <http://gf.stae.wy.us/wildlife/jobcompletionreports/index.asp> pp. 34–44, 

82–91. 

WGFD, 2005a. “Avian Species of Special Concern, Native Species Status List.” Buffalo, 

Wyoming: WGFD. January. 

WGFD, 2005b. “Swift Fox (Vulpes velox)” in Final Comprehensive Wildlife Conservation 

Strategy.” <http://gf.state.wy.us/wildlife/CompConvStrategy/Species/Mammals/ 

PDFS/Swift%20Fox.pdf> (29 September 2009). 

Whicker, et al. “Radiological Site Characterizations, 2008. 27 Gamma Surveys, 

Gamma/Ra-226 Correlations, and Related Spatial Analysis Techniques.” Health Physics 95.

Supplement 5. p. 18 

Winter, J., 2010. Uranium One, Email Communication to Behram Shroff, U.S. Nuclear 

Regulatory Commission, May 12, 2010. ADAMS Accession No. ML101330441. 

Wisdom, M.J., et al., 2002. “Performance of Greater Sage Grouse Models for Conservation 

Assessment in the Interior Columbia Basin, USA.” Conservation Biology. Vol. 16. 

pp. 1,232–1,242. 

Wyoming Department of Education, 2007. “2007 Teacher, Pupil and School Counts.” 

<http://www.k12.wy.us/statistics/stat2/2007_ teacher_pupil_school_counts.pdf> 

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Unemployment Statistics.” <http://doe.state.wy.us/lmi/laus.htm> 

Wyoming Department of Employment, Research and Planning, 2009. Wyoming Unemployment 

Rate Increases to 5.0 percent in May 2009. <http://wydoe.state.wy.us/LMI/news.htm> 

Wyoming Department of Revenue (WDOR), 2001. “State of Wyoming Property Tax System.” 

June 8, 2001. <http://revenue.state.wy.us/PortalVBVS/uploads/propertytaxsystem.pdf> 

Wyoming Department of Revenue and Excise Tax, 2001. Memorandum To all owners and 

lessees of industrial plants and mines in Wyoming <http://revenue.state.wy.us/PortalVBVS/ 

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Affected Environment 

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4-1 

4 ENVIRONMENTAL IMPACTS AND MITIGATIVE ACTIONS 

4.1 Introduction 

The Generic Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities 

(NUREG-1910, GEIS) evaluated the potential environmental impact of implementing in-situ

recovery (ISR) operations in four distinct geographic regions, including the Wyoming East 

Uranium Milling Region, where the proposed Moore Ranch Project is located. This chapter 

evaluates the potential environmental impacts from implementing the proposed action and 

alternative wastewater disposal options and the No-Action alternative at the Moore Ranch site. 

Other reasonable alternatives considered for the proposed Moore Ranch Project included an 

alternative site location, alternate lixiviants, conventional mining and milling, and conventional 

mining and heap leach processing, all of which were eliminated from detailed analysis as 

described in Section 2.2. 

This chapter analyzes the four lifecycle phases of in-situ recovery (ISR) uranium extraction 

(construction, operations, aquifer restoration, and decommissioning/reclamation) at the 

proposed Moore Ranch Project consistent with the analytical approach used in the GEIS 

(NRC, 2009a). The results of the GEIS impact analyses for the Wyoming East Uranium Milling 

Region, as summarized in Table 1-1 of this supplemental environmental impact statement 

(SEIS), were used to focus the site-specific environmental review at the proposed Moore Ranch 

Project. If the GEIS concluded that that there could be a wide range of impacts on a particular 

resource area (e.g., the impacts could range from SMALL to LARGE, for example) then that 

resource area was evaluated in greater detail within this site-specific SEIS. 

Sections 4.2 through 4.14 evaluate the impact from both the proposed action (which includes 

construction, operation, aquifer restoration, and decommissioning/reclamation using a Class I 

injection well for management of process-related liquid waste streams) and the No-Action 

alternative, which means no ISR facility would be built and operated at the proposed Moore 

Ranch Project. The No Action alternative is assessed to provide a baseline to compare the 

potential impacts from the proposed action. 

NRC established a standard of significance for assessing environmental impacts in the conduct 

of environmental reviews based on the Council of Environmental Quality regulations, as 

discussed in NRC (2003a) and summarized as follows: 

SMALL: The environmental effects are not detectable or are so minor that they 

would neither destabilize nor noticeably alter any important attribute of 

the resource. 

MODERATE: The environmental effects are sufficient to noticeably alter, but not 

destabilize, important attributes of the resource. 

LARGE: The environmental effects are clearly noticeable and are sufficient to 

destabilize important attributes of the resource. 

4.2 Land Use Impacts 

A potential environmental impact on land use at the proposed Moore Ranch Project could occur 

during all phases of the ISR facility lifecycle. The impact could be from land disturbance from 
Environmental Impacts and Mitigative Actions 

4-2 

construction and decommissioning, grazing and access restrictions, and competing access for 

mineral rights. Potential impacts on land use could be greater in areas with higher percentages 

of private land ownership and Native American land ownership or in areas with a complex 

patchwork of land ownership. At the end of operations, all lands would be returned to their 

preextraction land use of livestock grazing and wildlife habitat, unless an alternative use is 

justified and approved by the state and the landowner [i.e., the rancher desires to retain roads 

or buildings (EMC, 2007a)]. 

Detailed discussion of the potential environmental impacts on land use from construction, 

operation, aquifer restoration, and decommissioning for the proposed Moore Ranch Project are 

provided in the following sections. 

4.2.1 Proposed Action (Alternative 1) 

4.2.1.1 Construction Impacts 

Section 4.3.1.1 of the GEIS described land use impacts that could occur during construction 

from land disturbances and access restrictions that could limit other mineral extraction, grazing, 

or recreational activities. The GEIS concluded that land disturbances during construction would 

be temporary and limited to small areas within permitted boundaries, and that well sites, staging 

areas, and trenches would be reseeded and restored. The GEIS further noted that changes to 

land use access including grazing restrictions and impacts on recreational activities, would be 

limited because of the small size of the restricted area, the temporary nature of restrictions, and 

the availability of other land for these activities. As summarized in Table 1-1, the GEIS 

determined that potential construction impacts on land use in the Wyoming East Uranium Milling 

Region could range from SMALL to LARGE, depending on the factors described previously 

(NRC, 2009a). The impacts that contributed to a greater than SMALL conclusion in the GEIS 

analysis considered potential alterations to ecological, historical, and cultural resources where 

the impact could range from SMALL to LARGE. For this SEIS, potential impacts to ecological, 

historical, and cultural resources are discussed in Sections 4.6 and 4.9, respectively. 

Section 4.4 of this SEIS evaluates potential impacts to soil from surface disturbances. 

Therefore, the discussion below assesses land use impacts at the proposed Moore Ranch 

Project considering the proposed land disturbances and associated access restrictions that 

could limit other mineral extraction activities, grazing activities, or recreational activities. 

Construction phase activities including drilling, trenching, excavating, grading, and surface 

facility construction would have the largest direct land use impact. As described in 

Section 2.1.1.1.2 of this SEIS, construction related activities would disturb and fence 

approximately 61 ha [150 ac] of the proposed Moore Ranch Project. Constructing the central 

plant would disturb approximately 2.4 ha [6 ac] and developing the wellfields would disturb 

approximately 23 ha [57 ac]. Other land disturbance would be associated with developing the 

infrastructure that includes laying pipeline and constructing access roads. The first phase of 

construction, which would include the first of the two wellfields and the central plant and 

ancillary facilities, is estimated to last for approximately 9 months (Griffin, 2009). Livestock that 

currently reside within the areas proposed for development would be moved and livestock 

access to certain areas would be limited by fences, which could alter current rangeland leases 

within the affected area and could affect rangeland use. Coal bed methane (CBM) and other 

exploratory drilling would be restricted from the 23 ha [57 ac] being developed for the wellfields. 

The applicant has stated that close communication between themselves and CBM operators 

during the laying of pipeline would help to further limit the potential land use impact. Because 
Environmental Impacts and Mitigative Actions 

4-3 

the types of land use activities are similar to those evaluated in the GEIS, and the area of land 

surface disturbance for the proposed action is small and at the low end of the range {50 to 

750 ha [120 to 1,860 ac] was considered in the GEIS} of surface disturbance considered in the 

GEIS, the U.S. Nuclear Regulatory Commission (NRC) staff conclude that land use impacts 

would be SMALL. Furthermore, the staff has not identified any new and significant information 

during its independent review that would change the expected environmental impact beyond 

that discussed in the GEIS. 

4.2.1.2 Operation Impacts 

As discussed in the GEIS (Section 4.3.1.2), land use impacts from operational activities would 

be similar to impacts during the construction phase from access restrictions because the 

infrastructure would be in place. No additional land disturbances would occur from operational 

activities. Because impacts from access restrictions and land disturbances would either be 

similar to, or less than, those for construction, the GEIS concluded that overall potential land 

use impacts from operational activities at an ISR facility would be SMALL. 

During the operations phase of the proposed Moore Ranch Project, land use would be 

restricted, as described in Section 4.2.1.1 of this SEIS. Livestock grazing and natural resources 

extraction and drilling would continue to be restricted from the wellfields and the central plant 

during the operations phase, which the applicant has estimated would last approximately 12 

years (Griffin, 2009). Because the types of land use activities are similar to those evaluated in 

the GEIS, and the amount of land surface disturbance for the proposed action is small and at 

the low end of the range of surface disturbance considered in the GEIS, the NRC staff conclude 

that land use impacts would be SMALL. Furthermore, the staff has not identified any new and 

significant information during its independent review that would change the expected 

environmental impact beyond those discussed in the GEIS. 

4.2.1.3 Aquifer Restoration Impacts 

Section 4.3.1.3 of the GEIS describes aquifer restoration impacts to land use (NRC, 2009a). 

Since aquifer restoration uses the same infrastructure that existed during operations, the land 

use impacts from aquifer restoration would either be similar to, or less than, those from 

operations. As aquifer restoration proceeds and wellfields are closed, operational activities 

would diminish. Therefore, the GEIS concluded aquifer restoration impacts to land use would 

be SMALL. 

The GEIS concluded that land use impacts during aquifer restoration would be similar to those 

during the operations phase because no additional land disturbance would occur. Wellfield 

access during the aquifer restoration phase, estimated to last for approximately 3.5 to 5.25 

years for Wellfields 1 and 2, respectively (Griffin, 2009) would be restricted from other uses 

such as livestock grazing, and CBM and other exploratory drilling, as described in 

Section 4.2.1.1 of this SEIS. Because the types of land use activities are similar to those 

evaluated in the GEIS, and the amount of land surface disturbance for the proposed action is 

small and at the low end of the range of surface disturbance considered in the GEIS as 

discussed in Section 4.2.1.1, the NRC staff conclude that land use impacts from aquifer 

restoration activities would be SMALL. Furthermore, the staff has not identified any new and 

significant information during its independent review that would change the expected 

environmental impact beyond that discussed in the GEIS. 
Environmental Impacts and Mitigative Actions 

4-4 

4.2.1.4 Decommissioning Impacts 

The land use impact from decommissioning is discussed in Section 4.3.1.4 of the GEIS, which 

concluded that the impacts from decommissioning an ISR facility would be comparable to that 

described for the construction phase, with a temporary increase in land-disturbing activities for 

dismantling; removing; and disposing of facilities, equipment, piping, and excavated 

contaminated soils. Access restrictions would remain in place until decommissioning and 

reclamation were completed, although a licensee could decommission and reclaim the site in 

stages. Reclamation of land to preexisting conditions and uses would help to mitigate long-term 

potential impacts. The GEIS concluded that impacts to land use during decommissioning could 

range from SMALL to MODERATE and would be SMALL when decommissioning and 

reclamation were completed (NRC, 2009a). 

At the proposed Moore Ranch Project, the impact from dismantling and decontaminating the 

central plant, roads, and support facilities would be consistent with the conclusions reached in 

the GEIS. The 61 ha [150 ac] potentially disturbed as part of the proposed action (less than 

2 percent of the proposed license area) would be returned to its preextraction condition and 

available for other uses such as livestock grazing, CBM, and other exploratory drilling. Topsoil 

removed and stored as part of the proposed action would be replaced and areas reseeded. The 

areas most directly impacted would include the central plant, wellfields and their infrastructure 

(i.e., pipeline and header houses), and access roads constructed for the proposed action. As 

decommissioning and reclamation proceeded, the area of disturbed and fenced land 

would decrease. 

During decommissioning, the applicant would perform surface reclamation to return disturbed 

land equal to preextraction use. The applicant would perform the following activities. All 

contaminated equipment and materials and structures (including piping) would be removed from 

the site to a licensed facility for disposal or reuse. Equipment decontaminated to levels 

consistent with NRC requirements would be released for unrestricted use. All production, 

injection, and monitoring wells and drillholes would be abandoned, in accordance with 

applicable WDEQ-LQD rules and regulations (EMC, 2007a). Well casing would be cut off at 

least 0.9 m [3 ft] below the ground surface. Final surface reclamation of each wellfield 

production unit would be completed after approval of groundwater restoration stability and the 

completion of well-abandonment activities. Surface preparation would be accomplished as 

needed to blend any disturbed areas into the contour of the surrounding landscape (EMC, 

2007a). Permanent vegetation would be established on disturbed areas (EMC, 2007a). At the 

completion of decommissioning activities, because the reclaimed land would be released for 

other uses and no longer restricted, the land use impacts for disturbed areas would be 

MODERATE until the reestablishment of vegetation in seeded areas. Once vegetation is 

established in reclaimed areas, the NRC staff conclude the land would be returned to a 

condition that would support a variety of land uses and, therefore, land use impacts would 

be SMALL. 

4.2.2 No-Action (Alternative 2) 

Under the No-Action alternative, the proposed Moore Ranch Project would not be licensed and 

the land would be available for other uses such as grazing, CBM, oil, and gas production. No 

construction activities would occur; therefore, the 61 ha [150 ac] of land surface potentially 

disturbed during the proposed action would not be disrupted; no access restrictions would be 
Environmental Impacts and Mitigative Actions 

4-5 

in-place to restrict wildlife usage. No wells would be drilled, no pipeline would be laid, and no 

access roads would be constructed. 

There would be no operations impacts to land use because no ISR facility would have been 

constructed, and no subsurface injection of lixiviant would occur. The current land uses of 

natural resources extraction and grazing lands would continue with no access restrictions within 

the proposed license area. Operations impacts to current land uses from the continued CBM 

and oil and gas extraction activities within the study area could occur from accidental breaks or 

failures in equipment and infrastructure systems; however, the occurrence of such accidents is 

beyond the scope of this SEIS. There would be no impact from operations activities associated 

with the proposed Moore Ranch Project. 

Under the No-Action alternative, there would be no impact from aquifer restoration activities 

such as the injection, production, or monitoring of subsurface fluids from the proposed 

Moore Ranch Project because no wells would have been drilled, nor wellfields developed. 

Aquifer restoration activities that could involve the pumping of wells would not occur, and there 

would be no impact to the current land uses. 

There would be no impact to land use from decommissioning activities because the proposed 

Moore Ranch Project would not be developed. No buildings requiring decontamination and 

decommissioning would exist, no topsoil would need to be reclaimed, no land surfaces would 

need to be revegetated. 

4.3 Transportation Impacts 

Potential environmental impacts from transportation to and from an ISR facility could occur 

during all phases of the facility lifecycle. Impacts would result from workers commuting to and 

from the site and from the shipment of materials and chemicals used in the ISR process. 

Impacts could also occur from fugitive dust emissions, noise, incidental wildlife or livestock kills, 

increased traffic on local roads, and from accident occurrence. Fugitive dust impacts are 

evaluated as air quality impacts in Section 4.7, noise impacts are evaluated in Section 4.8, and 

livestock kills are evaluated as potential ecological impacts in Section 4.6.1.1.2. 

Detailed discussion of the potential environmental impacts from transportation to and from the 

proposed Moore Ranch Project during construction, operation, aquifer restoration, and 

decommissioning is provided in the following sections. 

4.3.1 Proposed Action (Alternative 1) 

4.3.1.1 Construction Impacts 

Section 4.3.2.1 of the GEIS concluded that ISR construction activities would generate low 

volumes of additional traffic (relative to local traffic counts) and would not significantly increase 

traffic or accidents on many of the roads in the region. Roads that have low traffic counts could 

be moderately impacted by additional workers commuting during periods of peak employment. 

Additionally, the GEIS concluded that, depending on site specific conditions, there could be a 

moderate impact from fugitive dust, noise, and incidental wildlife or livestock kills on, or near, 

site access roads. For these reasons, the GEIS determined that the construction phase of ISR 

projects could result in transportation impacts that ranged from SMALL to MODERATE 
Environmental Impacts and Mitigative Actions 

4-6 

(NRC, 2009a). This section of the SEIS discusses the potential impact on the local 

transportation system from implementing the proposed action at the Moore Ranch Project. 

The primary access road to the proposed Moore Ranch Project is Brown Road, a gravel road 

that intersects State Highway (SR) 387 roughly 6.4 km [4 mi] west of SR 50 and 48 km [30 mi] 

east of I-25 (Figure 1-1). As discussed in Section 3.3, SR 387 is the primary transportation 

route to the proposed license area and it connects the site to regional population and economic 

centers along I-25 to the west and SR 59 to the east. These roads were evaluated for potential 

traffic impacts in the GEIS. The applicant estimated the maximum anticipated increase in 

vehicle traffic on SR 387 by phase of the proposed Moore Ranch Project. For this analysis, the 

applicant obtained vehicle traffic counts, from the Wyoming Department of Transportation for 

trucks and automobiles. The daily truck traffic estimate for the proposed action included trucks 

that haul heavy equipment (cranes, bulldozers, graders, track hoes, trenchers, front-end 

loaders) to the construction site. The applicant estimated the average daily increase in auto 

traffic based on workforce levels for each phase of the ISR project and conservatively assumed 

that there would be one employee per vehicle for each vehicle trip in the auto traffic projections. 

The proposed commuter traffic was bounded by the number of workers assumed in the GEIS, 

however, the number of truck shipments during the construction period for the proposed action 

was well above the number of shipments assumed in the GEIS. As shown in Table 4-1, during 

the construction phase of the proposed Moore Ranch Project, when the proposed traffic is 

considered in the context of existing traffic counts, the applicant estimates a maximum 9.1 

percent increase in daily truck traffic and a 4.8 percent increase in automobile traffic along 

sections of SR 387 (Uranium One, 2009a). This magnitude of change in existing traffic is 

considered by staff to be unnoticeable and, therefore, impacts to traffic would be consistent with 

the SMALL traffic-related impacts evaluated in the GEIS. 

Brown Road, the spur road to the central plant, and access roads to the wellfields would be 

periodically graded and cleared of snow, as necessary, to ensure site access was maintained. 

Table 4-1. Estimated Annual Average Daily Traffic on State Highway 387 for the 

Construction Phase of the Proposed Moore Ranch Project 

Section 

Description 

Mile 

Route 

Signs 2007* 

Projected 

Volume 

Percent 

Increase 

Projected 

Volume 

Percent 

Increase 

Begin† 

(mile 

marker) 

All 

Vehicles Trucks 

Percent 

Trucks Trucks Trucks 

Auto 

traffic 

Auto 

traffic 

JohnsonCampbell County 

Line 

118.726 1,500 370 24.7 390 5.4 1,162 2.8 

JCT 300 (WY50 

and Pinetree 

JCT) 

131.793 890 220 24.7 240 9.1 702 4.8 

JCT County 

Roads North & 

South 

137.12 900 220 24.4 240 9.1 712 4.7 

JCT Local Roads 

North & South 149.24 2,000 410 20.5 430 4.9 1,622 2.0 

Wright 150.63 3,390 480 14.2 500 4.2 2,942 1.1 

*Year 2007 used as base for projected traffic volume 

†Begin=Mile Marker Start of Section 

Construction phase traffic: Assuming a construction workforce of 10 plus 6 wellfields staff traveling one round trip per day 

to the site (32 auto traffic trips per day), and 10 truck round trips (20 trips) per day for equipment being hauled to the site. 
Environmental Impacts and Mitigative Actions 

4-7 

The applicant proposes to spray road surfaces with water for dust suppression and conduct 

regular inspections for erosion and sediment control. Figure 2-2 shows the location of the 

proposed spur road, wellfield roads, and other access roads that would be required to support 

the proposed Moore Ranch Project. Because of the limited distance between Highway 387 and 

the central plant, the NRC staff considered the MODERATE potential impacts the GEIS 

concluded could result during construction (e.g., road dust, livestock and wildlife kills) would be 

less likely at the proposed Moore Ranch Project and, therefore, the impact would be SMALL. 

Section 4.7 contains additional analysis of potential impact from fugitive dust emissions, and 

impacts to wildlife are addressed in Section 4.6.1.1.2. 

The applicant estimated that approximately 50 percent of the construction workforce (8 workers) 

would be based in Campbell County (EMC, 2007b). Shorter commuting distances would reduce 

road surface wear and the likelihood of traffic accidents. Traffic interactions between 

commuters and tractor trailers would be minimized because heavy equipment would be 

transported primarily during off-peak hours. 

Because of the small increase in anticipated traffic, transportation impacts during the 

construction phase of the proposed Moore Ranch Project were estimated to be SMALL. 

Furthermore, the staff has not identified any new and significant information during its 

independent review that would change the expected environmental impact beyond that 

discussed in the GEIS. 

4.3.1.2 Operation Impacts 

As discussed in Section 4.3.2.2 of the GEIS, the low level of facility-related traffic would not 

noticeably increase traffic or the occurrence of accidents on most roads, although local, 

less-traveled roads could be moderately impacted during periods of peak employment. There 

could be impacts from fugitive dust emissions, noise, and possible incidental wildlife or livestock 

kills either on or near site access roads as described in Section 4.3.1.1 for the construction 

phase of ISR facilities. 

The GEIS also assessed the potential for and consequence from accidents involving the 

transportation of hazardous chemicals and radioactive materials. The GEIS recognized the 

potential for high consequences from a severe accident involving transportation of hazardous 

chemicals in a populated area. The probability of such accidents occurring was determined to 

be low because of the small number of shipments, comprehensive regulatory controls, and the 

applicant’s use of best management practices (BMP). For radioactive material shipments 

[yellowcake product, ion-exchange (IX) resins, waste materials], compliance with transportation 

regulations was expected to limit radiological risk for normal operations. The GEIS concluded 

there would be a low radiological risk in the unlikely event of an accident. The use of 

emergency response protocols would help to mitigate the consequences of severe accidents 

that involved the release of uranium. The GEIS concluded that the potential environmental 

impact from transportation during operations could range from SMALL to MODERATE 

(NRC, 2009a). 

The operations phase of the proposed Moore Ranch Project would last approximately 12 years 

and involve a peak workforce of approximately 24 employees, which equates to a maximum 

average of 48 auto trips per day, conservatively assuming one employee per vehicle per 

one-way vehicle trip (Uranium One, 2009a). Truck traffic during this phase of the proposed 

Moore Ranch Project would include yellowcake shipments, byproduct material shipment, solid 
Environmental Impacts and Mitigative Actions 

4-8 

waste shipment, and regular operation deliveries. The highest levels of project-related 

automobile traffic would be from the operations workforce commuting to and from the site. The 

proposed workforce and operational truck traffic was bounded by the traffic evaluated in the 

GEIS. The maximum anticipated increase in vehicle traffic on SR 387 was estimated for the 

operations phase of the proposed Moore Ranch Project and is summarized in Table 4-2. The 

maximum expected increase in truck and automobile usage of SR 387 was estimated at 0.5 and 

7.2 percent during the operations phase. This magnitude of change in existing traffic is 

considered by NRC staff to be unlikely to be noticed and therefore impacts to traffic would be 

SMALL, consistent with traffic-related impacts evaluated in the GEIS. 

Onsite road maintenance during the operations phase would consist of the applicant performing 

periodic grading of the primary access roads, snow plowing, applying water or other agents to 

control fugitive dust emissions, and regular inspections to ensure the adequacy of erosion 

control measures. The GEIS concluded there could be MODERATE transportation impacts 

based on the distance traveled, since traveling longer distances on dirt roads could result in 

greater fugitive dust emissions and there would be greater potential for incidental livestock and 

wildlife kills. Because of the short distance traversed by the access road between Highway 387 

and the central plant at the proposed Moore Ranch Project both fugitive dust emissions and the 

potential for incidental livestock and wildlife kills would be reduced. Therefore, the impact would 

be SMALL. Section 4.7 provides additional analysis of potential impacts from fugitive dust 

emissions and potential impacts to wildlife are addressed in Section 4.6.1.1.2. 

Section 4.2.2.2 of the GEIS evaluated yellowcake transportation, assuming shipment volumes 

ranging from 34 to 145 yellowcake shipments per year, which could result in a risk of 0.04 and 

0.003 latent cancer fatalities if an accident were to occur, given the larger number of shipments 

(NRC, 2009a). Considering the annual maximum production rate of yellowcake at the proposed 

Table 4-2. Estimated Annual Average Daily Traffic on State Highway 387 for the 

Operations Phase of the Proposed Moore Ranch Project 

Section 

Description 

Mile 

Route 

Signs 2007* 

Projected 

Volume 

Percent 

Increase 

Projected 

Volume 

Percent 

Increase 

Begin† 

(mile 

marker 

All 

Vehicles Trucks 

Percent 

Trucks Trucks Trucks 

Auto 

traffic 

Auto 

traffic 

JohnsonCampbell County 

Line 

118.726 1500 370 24.7 371 0.3 1178 4.2 

JCT 300 (WY50 

& Pinetree JCT) 131.793 890 220 24.7 221 0.5 718 7.2 

JCT County 

Roads North & 

South 

137.12 900 220 24.4 221 0.5 728 7.1 

JCT Local Roads 

North & South 149.24 2000 410 20.5 411 0.2 1638 3.0 

Wright 150.63 3390 480 14.2 481 0.2 2958 1.6 

*Year 2007 used as base for projected traffic volume 

†Begin=Mile Marker Start of Section 

Operational phase traffic: Assuming a site workforce of 24 (48 auto traffic trips per day), and 1.12 average total 

truck trips per day (yellowcake shipments = 100 round trips per year or 200 truck trips/year = .548 trips/day; 

nonradioactive waste shipments = 100 round trips/year or 200 trucks trips/year = 0.548 trips/day;) byproduct 

material shipments = 5 round trips/year or 10 trips/year = 0.027 trips/day. 
Environmental Impacts and Mitigative Actions 

4-9 

Moore Ranch Project of 4 million pounds and an approximate capacity of 40,000 pounds for 

each yellowcake shipment, (Uranium One, 2009a), a maximum of 100 shipments per year is 

estimated for the proposed action, or an average of one shipment every 3.5 days. Therefore, 

the shipment of yellowcake at the proposed Moore Ranch Project is bounded by the GEIS 

analyses, and the number of shipments would not significantly affect the project-related traffic 

relative to the expected commuting workforce. Therefore, the environmental impact from 

transportation during the operations phase of the proposed Moore Ranch Project would 

be SMALL. 

The GEIS reported that accidents involving yellowcake releases result in up to 30 percent of 

shipment contents being released, which is less than the fraction used in the previous 

calculation (NRC, 2009a). To minimize the risk of an accident involving resin or yellowcake 

transport, all such materials would be transported in accordance with the U.S. Department of 

Transportation (USDOT) and NRC regulations, handled as low-specific activity materials, and 

shipped using exclusive-use-only vehicles. Only properly licensed and trained drivers would 

transport low-specific activity materials. 

Should a transportation accident occur, the staff conclude the consequences of such accidents 

would be limited because the applicant would develop an emergency response plan for 

yellowcake and other transportation accidents that could occur during either shipment to or from 

the proposed Moore Ranch Project, and would ensure their personnel received proper 

emergency response training. Emergency response protocols would include communication 

equipment and emergency spill kits on each vehicle and emergency response kits at shipping 

and receiving facilities. Yellowcake shipments would be made in accordance with USDOT and 

NRC regulations (EMC, 2007a). Section 5.2 of the Moore Ranch Environmental Report 

(EMC, 2007a) and Section 7.5.5 of the technical report (EMC, 2007b) provides additional details 

on the applicant’s emergency response plan. 

The applicant estimated that approximately four bulk chemical, fuel, and supply deliveries would 

be made per day throughout the operations phase of the proposed Moore Ranch Project 

(Uranium One, 2009a). This number of shipments is greater than the daily number chemical 

supply shipments considered in the GEIS, however, the incoming process chemicals are 

commonly used in industrial applications and their transport would be made in accordance with 

the applicable USDOT hazardous materials shipping provisions. The applicant’s plans to use 

an alternative processing chemical to anhydrous ammonia further limits the chemical 

transportation hazards relative to what was considered in the GEIS. As a result, the staff 

concludes the chemical shipments can be executed safely and potential environmental impacts 

of these shipments would be SMALL. 

Similarly, the transportation of byproduct material (including contaminated equipment and soils) 

would pose a small potential for an environmental impact in the event of an accident. This 

conclusion is based on the low number of annual shipments and the potential risk relative to 

concentrated yellowcake product shipments considered previously and in the GEIS. Trip 

frequency and the associated risk of an accident would be curtailed by storing byproduct 

material in a restricted area within the central plant until a full shipment could be transported for 

disposal. The applicant has estimated an annual byproduct material production rate of 76.5 m3

[100 yd3

]. Based on the use of roll-off containers with a nominal capacity of 15.3 m3 [20 yd3], 

there would be 5 shipments annually to a licensed disposal facility. Shipments of nonhazardous 

solid waste either to the Midwest-Edgerton landfill or to a future transfer facility expected to 

operate at that location would be required approximately twice a week (Uranium One, 2010). 
Environmental Impacts and Mitigative Actions 

4-10 

Based on the small increase in anticipated traffic during the operations phase, the low and 

manageable risks associated with yellowcake, chemical, and waste transportation, the impacts 

from the operation phase of the proposed Moore Ranch Project would be SMALL. Furthermore, 

the staff has not identified any new and significant information during its independent review that 

would change the expected environmental impacts beyond those discussed in the GEIS. 

4.3.1.3 Aquifer Restoration Impacts 

Section 4.3.2.3 of the GEIS concluded that the magnitude of transportation activities during 

aquifer restoration would be lower than that for the construction and operations phases of an 

ISR facility. Aquifer restoration-related transportation activities would primarily be limited to 

supply shipments, waste shipments, onsite transportation, and employee commuting. The 

GEIS concluded that transportation impacts from the aquifer restoration phase of an ISR facility 

could range from SMALL to MODERATE, if the roads traveled had less traffic (NRC, 2009a). 

At the proposed Moore Ranch Project, the applicant estimated that the transportation impacts 

during aquifer restoration would be the same as that described for the operations phase but less 

than what would occur during the construction phase. Table 4-3 summarizes the maximum 

anticipated increase in vehicle traffic on SR 387 during aquifer restoration. The applicant 

estimated the expected increase in truck and automobile usage of SR 387 at 0.5 and 

7.2 percent, respectively, (Uranium One, 2009a), comparable to the operations phase impacts. 

Therefore, transportation impacts during the aquifer restoration phase would be SMALL. 

Furthermore, the staff has not identified any new and significant information during its 

independent review that would change the expected environmental impact beyond that 

discussed in the GEIS. 

Table 4-3. Estimated Annual Average Daily Traffic on State Highway 387 for the Aquifer 

Restoration Phase of the Proposed Moore Ranch Project 

Section 

Description 

Mile 

Route 

Signs 2007 

Projected 

Volume 

Percent 

Increase 

Projected 

Volume 

Percent 

Increase 

Begin** 

(mile 

marker 

All 

Vehicles Trucks 

Percent 

Trucks Trucks Trucks 

Auto 

traffic 

Auto 

traffic 

JohnsonCampbell County 

Line 

118.726 1,500 370 24.7 371 0.3 1,178 4.2 

JCT 300 (WY50 

& Pinetree JCT) 131.793 890 220 24.7 221 0.5 718 7.2 

JCT County 

Roads North & 

South 

137.12 900 220 24.4 221 0.5 728 7.1 

JCT Local Roads 

North & South 149.24 2,000 410 20.5 411 0.2 1,638 3.0 

Wright 150.63 3,390 480 14.2 481 0.2 2,958 1.6 

*Year 2007 used as base for projected traffic volume 

†Begin = Mile Marker Start of Section 

Aquifer restoration phase traffic: Assuming a site workforce of 24 (48 auto traffic trips per day) and a maximum of 

1.12 truck trips per day (using operation phase truck traffic data). 
Environmental Impacts and Mitigative Actions 

4-11 

4.3.1.4 Decommissioning Impacts 

Section 4.3.2.4 of the GEIS concluded that transportation activities occurring during 

decommissioning would be similar to those that occurred during the construction and operation 

phases of an ISR facility, except that the magnitude of transportation activities (e.g., number 

and types of waste and supply shipments, no yellowcake shipments) could be lower than that 

during operations (NRC, 2009a). Therefore, the potential transportation impacts would be 

smaller. The accident risk from transportation during decommissioning would be bounded by 

the yellowcake transportation risk during operations. The GEIS concluded that the potential 

environmental impact from transportation activities during the decommissioning phase would be 

SMALL because fewer transportation activities would occur. 

The site-specific analysis at the proposed Moore Ranch Project was in agreement with the 

GEIS conclusions. The maximum anticipated increase in vehicle traffic on SR 387 was 

estimated for the decommissioning phase, as summarized in Table 4-4. During the 

decommissioning phase, the maximum expected increase in automobile traffic on SR 387 was 

estimated at 1.5 percent compared to approximately 9.1 and 7.1 percent during the construction 

and operation phases, respectively, of ISR operations. The increase in truck traffic would be 

2.7 percent. Based on the foregoing analysis, while the details of site-specific waste volumes 

were different than the GEIS assumptions (i.e., less byproduct material generated from 

decommissioning during the proposed action, but more nonhazardous solid waste generated) 

the overall magnitude of the impact from annual transportation during the decommissioning 

phase did not increase to change the proposed action impact conclusion relative to the GEIS 

conclusions. Therefore, transportation impacts during the decommissioning phase of the 

proposed Moore Ranch Project would be SMALL. 

Table 4-4. Estimated Annual Average Daily Traffic on State Highway 387 for the 

Decommissioning Phase of the Proposed Moore Ranch Project 

Section 

Description 

Mile 

Route 

Signs 

2007* Projected 

Volume 

Percent 

Increase 

Projected 

Volume 

Percent 

Increase 

 Begin† 

(mile 

marker 

All 

Vehicles Trucks Percent Trucks Trucks Trucks Auto traffic 

Auto 

traffic 

JohnsonCampbell 

County Line 

118.726 1,500 370 24.7 376 1.6 1,140 0.9 

JCT 300 

(WY50 & 

Pinetree JCT) 

131.793 890 220 24.7 226 2.7 680 1.5 

JCT County 

Roads North 

& South 

137.12 900 220 24.4 226 2.7 690 1.5 

JCT Local 

Roads North 

& South 

149.24 2,000 410 20.5 416 1.5 1,600 0.6 

Wright 150.63 3,390 480 14.2 486 1.2 2,920 0.3 

*Year 2007 used as base for projected traffic volume 

†Begin = Mile Marker Start of Section 

Decommissioning phase traffic: Assuming a site workforce of 5 (10 auto traffic trips per day) and 3 truck round trip 

per day (6 truck trips per day) for equipment and waste shipments. 
Environmental Impacts and Mitigative Actions 

4-12 

4.3.2 No-Action (Alternative 2) 

Under the No-Action alternative, traffic volumes and patterns would remain the same as 

described in Section 3.3 of this SEIS. There would be no transportation of materials to and from 

the site to support licensed activities. There would be no transportation of either radioactive or 

solid waste attributable to the proposed action because the facility would neither be licensed nor 

constructed and operated. The current transportation activities to support ongoing CBM and oil 

and gas exploration and production activities would continue. Existing land use activities would 

persist. Two companies have active CBM claims within the proposed license area. 

4.4 Geology and Soils Impacts 

Potential environmental impacts to geology and soils could occur during all phases of the Moore 

Ranch ISR facility lifecycle. However, these impacts would largely occur during the construction 

phase of the proposed project. 

4.4.1 Proposed Action (Alternative 1) 

4.4.1.1 Construction Impacts 

Section 4.3.3.1 of the GEIS indicated that during construction of ISR facilities, the principal 

impacts on geology and soils would result from earthmoving activities associated with 

constructing surface facilities, access roads, wellfields, and pipelines (NRC, 2009a). 

Earth-moving activities that could impact soils would include clearing of ground or top soil and 

preparing surfaces for the processing plant, satellite facilities, pump houses, access roads, 

drilling sites, and associated structures. Similarly, excavating and backfilling trenches for 

pipelines and cables could impact soils in the proposed project area. 

The GEIS concluded that construction impacts on geology and soils would depend on local 

topography, surface bedrock geology, and soil characteristics. The earth-moving activities are 

normally limited to only a small portion of the proposed project. Consequently, earth-moving 

activities would result in SMALL and temporary (months) disturbance of soils-impacts that are 

commonly mitigated using accepted BMP. Construction activities would also increase the 

potential for erosion from both wind and water from the removal of vegetation and the physical 

disturbance from vehicle and heavy equipment traffic. However, these activities would result in 

SMALL impacts if equipment operators adopt construction BMP to either prevent or 

substantially reduce erosion (NRC, 2009a). 

The GEIS also indicated that ISR extraction activities would not result in the removal of any rock 

matrix or structure and that subsidence would not occur from the collapse of overlying rock 

strata in the extraction zone, which could occur in underground mining operations. No other 

geologic impacts would be anticipated to occur with the ISR extraction method. 

At the proposed Moore Ranch Project, a maximum of 61 ha [150 ac] out of the 2,879 ha 

[7,110 ac] license area, or approximately 2 percent of the total license area, would be disturbed 

by the proposed action. This amount of surface disturbance is at the low end of the range 

evaluated in the GEIS (NRC, 2009a). Soil disturbance would primarily result from the same 

types of practices that were evaluated in the GEIS, and would be limited to the central plant 

area, the wellfields, access roads, and from developing drill sites and laying pipeline. These 

disturbances would be temporary for the duration of the proposed action because the applicant 
Environmental Impacts and Mitigative Actions 

4-13 

would restore affected areas and reclaim the soils as described in Section 2.1.1.1.5 of 

this SEIS. 

As described in Section 2.1.1.1.2.3.3 and 2.1.1.5.2, the applicant has proposed to remove and 

stockpile topsoil from areas that would potentially be disturbed by the proposed action (i.e., the 

central plant and wellfields header houses) prior to the construction of these facilities. 

Conventional rubber-tired, scraper-type earth-moving equipment would typically be used to 

accomplish such topsoil salvage operations. Stockpiles would generally be located on the 

leeward side of hills to minimize wind erosion, drainage channels, or to avoid other locations 

that could result in a loss of material. The applicant may surround large stockpiles by a berm 

and seed them with wheatgrass to control and minimize sediment runoff. The staff conclude the 

applicants proposed measures to remove and stockpile topsoil are adequate to preserve topsoil 

until the site areas are reclaimed and therefore impacts to topsoil would be SMALL. 

The interpretation of soil mapping conducted across the proposed Moore Ranch Project 

indicates the potential for water erosion (see Section 3.4.2 of the SEIS) varies from slight to 

severe, and the potential for wind erosion varies from moderate to severe (EMC, 2007a). Soils 

across the proposed Moore Ranch Project are prone to wind erosion because of their fine loamy 

and sandy texture and the semiarid climate. Within the 2.4-ha [6-ac] central plant fenced area, 

the underlying soils have a slight potential for water erosion and a severe potential for wind 

erosion. The soils within the proposed wellfields have a moderate to severe risk from both wind 

and water erosion. 

The applicant has proposed mitigation measures to limit soil erosion, including reestablishing 

temporary or permanent native vegetation as soon as possible after disturbance and 

implementing BMPs to retain sediment within the disturbed areas [e.g., silt fencing or retention 

ponds (Uranium One, 2009b).] Roads would be constructed to minimize erosion by surfacing 

with a gravel road base, constructing stream crossings at right angles using adequate 

embankment protection and culvert installation, and by providing adequate road drainage with 

runoff control structures. The NRC staff conclude the applicant’s proposed measures to limit soil 

erosion are adequate to limit potential soil erosion impacts and therefore the potential impacts to 

soil would be SMALL. 

During wellfield construction, drilling activities and the installation of piping would impact soils 

because, as described in Section 2.1.1.1.2.3.3, the applicant is planning to use mud pits during 

drilling activities and trenches during wellfield construction. Approximately 970 wells would be 

drilled in the development of Wellfields 1 and 2. Excavating mud pits would result in surface soil 

disturbance and entail first removing topsoil and placing it in a separate location. The subsoil 

would then be removed and deposited next to the mud pit. The applicant stated that when mud 

pit use was completed, subsoil would be replaced and topsoil applied. Mud pits typically remain 

open for less than 30 days. Pipeline trench excavation would follow a sequence similar to mud 

pit excavation, with topsoil stored separately from subsoil and with topsoil deposited on the soil 

after the pipeline ditch has been backfilled. The applicant would mitigate potential soil 

compaction by placing multiple pipelines and/or utilities in the same trench when possible. The 

WDEQ-LQD has guidelines on topsoil and subsoil management at uranium ISR facilities 

(WDEQ, 2000). Following review of the applicant’s proposed use of mud pits and pipeline 

trenching, the staff conclude the potential impacts to soils would be SMALL based on the limited 

size of the wellfield areas, the proposed topsoil removal and stockpiling activities, and the short 

duration of mud pit usage and pipeline trenching that was proposed by the applicant. 
Environmental Impacts and Mitigative Actions 

4-14 

In summary, based on (i) the aforementioned similarities between the proposed action and the 

analysis in the GEIS, (ii) the limited construction area and associated amount of surface 

disturbance expected from the proposed action, (iii) the applicant’s proposed erosion control 

measures, and (iv) the short duration for use of the mud pits and pipeline trenching activities, 

the NRC staff conclude the potential environmental impact to geology and soils from 

construction activities at the proposed Moore Ranch Project would be SMALL. Furthermore, the 

staff has not identified any new and significant information during its independent review that 

would change the expected environmental impact beyond that discussed in the GEIS. 

While the NRC staff conclude impacts to soils from construction are expected to be SMALL, the 

staff recognize that alternative methods are available that the applicant could choose to 

implement to further limit potential impacts from the use of mud pits during well drilling activities. 

Alternatives or mitigating measures to using mud pits during well drilling operations include, for 

example, lining the mud pits with an impermeable membrane, disposing of potentially 

contaminated drilling mud and other fluids off-site, and using portable tanks or tubs to contain 

drilling mud and other fluids. 

4.4.1.2 Operation Impacts 

As discussed in Section 4.3.3.2 of the GEIS, during ISR operations, a nonuranium-bearing 

(barren) solution or lixiviant is injected via wells into the mineralized zone. The lixiviant moves 

through the pores in the host rock, dissolving uranium and other metals. Production wells 

withdraw the resulting “pregnant” lixiviant containing uranium and other dissolved metals, and 

pump it to a processing facility for further uranium recovery and purification. 

The removal of uranium from the target sandstones during ISR operations would result in a 

permanent change to the composition of uranium-bearing rock formations. However, the 

uranium mobilization and recovery process in the target sandstones does not result in the 

removal of rock matrix or structure and; therefore, no significant matrix compression or ground 

subsidence is expected. Therefore, the GEIS concluded the impacts on geology from ground 

subsidence at ISR projects would be SMALL (NRC, 2009a). 

Section 4.3.3.2 of the GEIS also indicated soils could be impacted from ISR operations if 

pipelines were to leak during transfer of barren and pregnant uranium-bearing lixiviant to and 

from the processing facility in aboveground and underground pipelines. If a pipe ruptured or 

failed, lixiviant could be released and (1) pond on the surface, (2) run off into surface water 

bodies, (3) infiltrate and adsorb in overlying-soil and rock, or (4) infiltrate and percolate to 

groundwater. In the case of spills from pipeline leaks and ruptures, licensees would have 

established immediate spill response procedures through onsite, standard operation procedures 

established before operations (e.g., NRC, 2003b, Section 5.7). As part of the monitoring 

requirements at ISR facilities, licensees must report certain spills to the NRC within 24 hours. 

Licensees located in the State of Wyoming must also comply with applicable WDEQ spill 

response and reporting requirements. 

Based on these considerations, the GEIS (Section 4.3.3.2) concluded that impacts to soils from 

spills during operation could range from SMALL to LARGE, depending on the volume of soil 

affected by the spill. Because of the requirement for immediate responses at ISR facilities, spill 

recovery actions, and routine monitoring programs, impacts from spills would be temporary, and 

the overall long-term impact to soils would be SMALL. 
Environmental Impacts and Mitigative Actions 

4-15 

At the proposed Moore Ranch Project, the response to surface releases would be discussed in 

a site-specific Spill Contingency Plan (EMC, 2007a). As described in Section 2.1.1.1.2.1 of this 

SEIS, the plant would be designed to capture and drain spilled liquids from potential process 

tank failures to a sump for transferring spilled solutions to either appropriate tankage or to the 

waste disposal system. As previously noted, the potential also exists for a release from piping 

that transfers fluids between the central plant and the wellfield. Piping system break, leak, or 

separation releases would generally be small because of the applicant’s proposed 

engineering controls to detect pressure changes in the piping system that would alert the plant 

operator. The program to monitor wellfield and pipeline flow and pressure is discussed in 

Chapter 6 of this SEIS. If a release were to occur, the applicant would be required to remediate 

the release, remove contaminated soils, and dispose of contaminated materials at a licensed 

disposal facility. 

Based on these considerations, the potential environmental impacts to soils from spills during 

operation of the proposed Moore Ranch Project could range from SMALL to LARGE, depending 

on whether a release occurred and the volume of soil potentially affected. The central plant and 

shop buildings would be self-contained, and all exterior chemical and fuel tanks would have 

secondary containment (Uranium One, 2009b). Based on the proposed design of the central 

plant, which includes containment, the proposed monitoring capabilities and plans for immediate 

spill response, and proposed spill recovery actions, the impact from a potential spill would be 

temporary, and the long-term impact to soils would be SMALL, consistent with GEIS 

conclusions. Furthermore, the staff has not identified any new and significant information during 

its independent review that would change the expected environmental impact beyond those 

discussed in the GEIS. 

Regarding the potential impacts to the rock matrix, the processes described in the GEIS also 

apply to the planned uranium recovery operations at the proposed Moore Ranch Project. The 

proposed uranium recovery activities would not remove rock matrix; therefore, no significant 

matrix compression or ground subsidence would be expected because the volume of fluid 

(bleed) withdrawn from the formation would typically be one percent or less. No subsidence 

would occur because no collapse of overlying rock strata in the mining zone would result from 

the proposed uranium recovery operations. No other geologic impacts are anticipated to occur 

during ISR extraction at the proposed Moore Ranch site. Therefore, the potential environmental 

impacts to geology from subsidence during operations would be SMALL. 

4.4.1.3 Aquifer Restoration Impacts 

Section 4.3.3.3 of the GEIS describes aquifer restoration, which typically uses a combination of 

(1) groundwater transfer; (2) groundwater sweep; (3) reverse osmosis, permeate injection, and 

recirculation; (4) stabilization; and (5) water treatment and surface conveyance (NRC, 2009a). 

The groundwater sweep and recirculation process does not remove rock matrix or structure 

and; therefore, no significant matrix compression or ground subsidence would be expected. 

The water pressure in the aquifer is decreased during restoration. A negative water balance is 

maintained in the wellfield being restored to ensure that water flows into the wellfield from its 

edges, thus reducing the potential to spread contamination. However, the change in reservoir 

pressure is limited by the recirculation of treated groundwater; therefore, it is very unlikely that 

ISR operations would reactivate any local faults and extremely unlikely that any earthquakes 

would be generated. Therefore, in the Wyoming East Uranium Milling Region, where the 

proposed Moore Ranch Project is located, the potential impact on the geology from aquifer 

restoration would be SMALL. 
Environmental Impacts and Mitigative Actions 

4-16 

For the proposed Moore Ranch Project, the potential for and response to spills would be 

comparable to that described during the operations phase in Section 4.4.1.2 of this SEIS since 

the same plant and wellfield infrastructure and the same spill and leak detection program would 

be used during aquifer restoration. Therefore, the potential impact to soils from spills could 

range from SMALL to LARGE, depending on the magnitude of the spill and the volume of 

affected soil. Based on the proposed design of the central plant which includes containment, the 

proposed monitoring capabilities and plans for immediate spill response, and the proposed spill 

recovery actions, the impact from a potential spill would be temporary, and the long-term impact 

to soils would be expected to be SMALL consistent with GEIS conclusions. Furthermore, the 

staff has not identified any new and significant information during its independent review that 

would change the expected environmental impact beyond those discussed in the GEIS. 

With respect to the potential impact on the rock matrix, the processes described in the GEIS 

also apply to the planned aquifer restoration activities at the proposed Moore Ranch Project. 

The proposed aquifer restoration activities would not remove rock matrix; therefore, no 

significant matrix compression or ground subsidence would occur because the volume of fluid 

(bleed) withdrawn from the formation would typically be one percent or less; therefore, neither 

subsidence nor collapse of the overlying rock strata in the extraction zone would result from the 

proposed aquifer restoration activities. Therefore, the potential impact on geology from 

subsidence during the aquifer restoration phase would be SMALL. 

4.4.1.4 Decommissioning Impacts 

Section 4.3.3.4 of the GEIS discussed decommissioning of ISR facilities, which includes 

(1) dismantling process facilities and associated structures, (2) removing buried piping, and 

(3) plugging and abandoning wells using accepted practices. The main impacts on geology and 

soils at the proposed project site during decommissioning would be from land reclamation 

activities and cleanup of contaminated soils. 

The GEIS also noted that before decommissioning and reclamation activities could begin, the 

licensee would be required to submit a decommissioning plan to NRC for review and approval. 

Any areas potentially impacted by operations would be surveyed to ensure areas with elevated 

soil concentrations are cleaned up, in accordance with NRC regulations at 10 CFR Part 40, 

Appendix A, Criterion 6 (6) (NRC, 2009a). 

The GEIS concluded that the impacts on geology and soils from decommissioning would be 

SMALL. Disruption and/or displacement of existing soils would be temporary and occur for the 

duration of decommissioning activities (NRC, 2009a). 

During the decommissioning phase of the proposed Moore Ranch Project, as described in 

Section 2.1.1.1.5 of this SEIS, the applicant proposes to restore all disturbed lands to their prior 

land use of livestock grazing and wildlife habitat. The magnitude of proposed soil disturbing 

decommissioning activities at the proposed Moore Ranch Project are within the bounds of the 

soil disturbing decommissioning activities evaluated in the GEIS based on the amount of land 

disturbance for the proposed action (Section 2.1.1.1 of this SEIS) relative to the GEIS analyses 

(Section 2.11.1 in NRC, 2009a,). The central plant and storage facilities would be 

decontaminated as required to meet regulatory standards, and either demolished and disposed 

of or turned over to the land owner if desired. Baseline soils, vegetation, and radiological data 

would be used to guide and evaluate final reclamation. As discussed in Section 2.1.1.1.5.3, 

stockpiled topsoil would be redistributed in the disturbed surface areas. These areas would be 
Environmental Impacts and Mitigative Actions 

4-17 

recontoured to match existing topography, and seeding and revegetation activities would be 

conducted. Twelve months prior to the planned decommissioning of either a wellfield or portion 

of the project, a decommissioning plan would be provided to the NRC for review and approval 

(NRC, 2003b). 

Short-term impacts to soil could occur as reclamation progressed; however, the outcome of this 

phase of the proposed Moore Ranch Project would be to return the area to land uses that 

existed prior to the start of proposed ISR activities. Based on the aforementioned analysis, the 

site-specific conditions are consistent with the conditions evaluated in the GEIS, therefore, the 

potential environmental impacts to geology and soils from decommissioning the proposed 

Moore Ranch Project would be SMALL. 

4.4.2 No-Action (Alternative 2) 

Under the No-Action alternative, neither the soils would be disturbed from earth-moving 

activities nor would the subsurface geology potentially be affected by the injection of fluids, 

because no license would be issued to authorize construction, operations, aquifer restoration, 

and decommissioning of the proposed Moore Ranch Project. No buildings would be 

constructed; no wells would be drilled; no wellfields would be developed, including laying 

pipeline to connect the wellfields to the central plant; thus, no soils would be disturbed from 

earth-moving activities that could change the existing topography. 

Grazing and CBM operations in the proposed license area would continue, which could produce 

localized impacts to soil and the existing topography, but there would be no impact from the 

proposed action. 

4.5 Water Resources Impacts 

4.5.1 Surface Water and Wetlands Impacts 

Potential environmental impacts on surface water and wetlands at the proposed Moore Ranch 

Project would be limited because of the lack of surface water bodies and because the channels 

at the site have intermittent flow, depending on the amount of precipitation and the volume of 

CBM discharges in the area. Surface water could potentially be impacted during all phases of 

the ISR facility lifecycle. Impacts could result from road construction and crossings, erosion 

runoff, spills or leaks of fuel and lubricants, stormwater discharges, potentially process-related 

fluids, and discharge of wellfield fluids as a result of pipeline or wellhead leaks. 

The potential environmental impacts to surface water from construction, operation, aquifer 

restoration, and decommissioning are provided in the following sections. 

4.5.1.1 Proposed Action (Alternative 1) 

Section 4.3.4.1.1 of the GEIS identified potential impacts to surface water and wetlands that 

result from construction of road crossings, filling, erosion, runoff, and spills or leaks of fuels and 

lubricants for construction equipment. These potential impacts would be mitigated through 

proper planning, design, construction methods, and BMPs. U.S. Army Corps of Engineers 

(USACE) permits could be required when filling and crossing jurisdictional wetlands. 

Authorization from the WDEQ could also be required when filling or crossing wetlands. The 

GEIS concluded that temporary changes to spring and stream flow from grading and changes in 
Environmental Impacts and Mitigative Actions 

4-18 

topography and natural drainage patterns could be mitigated or restored after the construction 

phase. The GEIS also noted that even though accidental spills of drilling fluids could flow into 

surface water bodies, these flows would be temporary and mitigated, in accordance with an 

NRC-approved contingency plan for spill response (NRC, 2003b) and a Wyoming Pollutant 

Discharge Elimination System (WYPDES) permit. The GEIS concluded that construction 

impacts to surface water would be SMALL in most cases, but could potentially be MODERATE 

if a USACE permit was required. As indicated in Section 3.5.1.4, the USACE determined on 

May 10, 2010, that there would be no jurisdictional areas at Wellfield 1, and an authorization 

would not be required for construction activities within Wellfield 1. Installation of wells and 

associated roads and pipelines within Wellfield 2 are authorized by Nationwide Permit (NP) 12 

(U.S. Army Corps of Engineers, 2010). 

4.5.1.1.1 Construction Impacts 

As noted in Section 2.1.1.1.2 of this SEIS, the ground surface at the proposed Moore Ranch 

Project would be disturbed during construction to build the central plant, develop the wellfields 

(which would include both laying pipeline and drilling the wells), construct access roads, and 

install electric lines. Section 3.5.1 and Figure 2-2 of the SEIS show the location of these 

activities with respect to the intermittent channels and potential wetlands located on the 

proposed Moore Ranch Project. As shown in Figure 2-2, only activities at Wellfield 2 would 

likely have the potential to impact Upper Wash #2 to Simmons Draw (see Figure 3-10) because 

this intermittent channel bisects the proposed wellfield. The applicant indicated that 

construction work would occur during the summer and fall months when the intermittent 

channels were dry. Furthermore, as noted in Table 1-2 of this SEIS, Uranium One would obtain 

construction and industrial stormwater WYPDES permits in accordance with WDEQ 

regulations. The applicant would also implement BMPs to reduce potential erosion impacts as 

described next. 

The central plant and support buildings would be constructed landward of all intermittent 

channels and above their peak flood elevation. The specific plant location was chosen because 

of the relatively flat terrain and the minimum amount of soil movement that would be necessary 

to create a level pad. Surface water runoff from precipitation (rain and snowmelt) would flow 

from the central plant area to natural drainages. Furthermore, the applicant has indicated the 

central plant and chemical and fuel tanks would be located within a bermed area to provide 

secondary containment (Uranium One, 2009b). Locally, surface water drainage would be 

directed away from facilities, roads, and topsoil stockpiles using shallow ditches and berms 

(Uranium One, 2009b). 

One culvert would be installed during the development of the site access roads to maintain 

existing site surface drainage conditions (Uranium One, 2009b). This culvert would be located 

on the access road connecting the central plant to the main access road. The new temporary 

access roads to Wellfields 1 and 2 cross an intermittent channel at several locations in 

Wellfield 2, as noted previously. Within this impacted area, there would be no new road 

crossings. However, there would be one trunkline pipe crossing and 14 small (approximately 

1-in. diameter) pipeline crossings to connect individual injection and production wells to a 

header house. The small lines would be combined into common trenches wherever possible 

(Uranium One, 2009b). Vehicles would only cross channels if either there was low flow or the 

channels were dry (Uranium One, 2009b). The existing culvert crossings would be used when 

the channels were flowing. The applicant would implement sedimentation and erosion-control 
Environmental Impacts and Mitigative Actions 

4-19 

measures and disturbed soil would be reseeded to minimize surface water runoff into channels 

(Uranium One, 2009b). 

Placement of wood poles to support power lines installed to transmit electricity to the central 

plant and other facilities would be installed landward of any intermittent channel. During the 

development of Wellfield 2, no wells would be installed in existing ponds; and, the placement of 

wells directly within the channel, washes, and delineated wetlands would be avoided, if possible 

(Uranium One, 2009b). The USACE has authorized activities in Wellfield 2 under NP 12. As 

previously noted, the applicant has proposed to avoid installing wells in the main channels of the 

ephemeral drainages, thereby avoiding potential impacts to wetlands. Furthermore, the 

applicant has stated that properly-sized culverts and drainage crossings to withstand a 25-year 

flood event and rip rap and rock on embankments and around culverts and drainage crossings 

would be used in drainages in accordance with WDEQ regulations. 

A single trunkline would connect the pipeline network to the header houses. This trunkline 

would traverse uplands and would not bisect any tributary washes or channels. After the 

trunkline was installed, the soil would be backfilled to preconstruction contours and seeded with 

native grass seed to stabilize loose soil. If an accidental spill were to occur during the 

construction phase of the proposed Moore Ranch Project, it would be promptly mitigated in 

accordance with the applicant’s site-specific ERP. 

The proposed construction activities described before would have the potential to generate a 

limited amount of surface water runoff. The activities in Wellfield 2 have been authorized under 

USACE NP 12 indicating the potential impact on surface water could be MODERATE by the 

GEIS criteria. Because the occurrence of surface water at the proposed Moore Ranch Project 

is limited and surface water flow in the channels is intermittent, the USAC, determination 

(USACE, 2010), and because of the applicant’s proposed mitigation measures, the NRC staff 

conclude that the potential impact to surface water and wetlands from the construction phase for 

Wellfield 1 of the proposed Moore Ranch Project would be SMALL. Because the USACE 

determined that construction activities in Wellfield 2 would be authorized by NP 12, the potential 

impacts from installation of wells and development of the related infrastructure to the wetlands 

would be MODERATE; however, the applicant’s implementation of BMPs such as the central 

plant and shop buildings being self-contained and all exterior chemical and fuel tanks having a 

means of secondary containment and the applicant’s commitment to reseed disturbed areas 

after wellfield construction would reduce the impact to SMALL. 

4.5.1.1.2 Operation Impacts 

Section 4.3.4.1.2 of the GEIS stated that federal and state agencies regulate the discharge of 

both stormwater runoff and the discharge of wastewater to surface waters through their 

permitting process (NRC, 2009a). The potential impact from these discharges would be 

mitigated through permit conditions. The expansion of facilities or the addition of pipeline during 

the operations phase would result in impacts comparable to that during the construction phase 

described in Section 4.5.1.1.1. If a spill occurred, the potential impact would depend on the size 

of the spill, the success of remediation, the proximity to and use of surface water, and the 

relative contribution of aquifer discharge to surface water. For these reasons, the GEIS 

concluded that impacts to surface waters during operations could range from SMALL 

to MODERATE. 
Environmental Impacts and Mitigative Actions 

4-20 

No impact to surface water would be expected during the operations phase of the proposed 

Moore Ranch Project because there would be no permitted discharge of wastewater to surface 

waters, the infrastructure would be in place to manage stormwater discharge, and no large 

earth-moving activities that could generate surface water runoff would occur. The occurrence of 

surface water within the proposed license area is limited and there is intermittent surface water 

flow in the channels and washes as previously noted. Lixiviant injection and subsequent 

extraction of the uranium-rich groundwater would occur within a closed and pressurized system 

of pipes at or near the ground surface. Processing of the uranium into yellowcake would be 

performed within the enclosed central plant. Accidental spills would be collected and 

maintained in storage tanks for later disposal via deep well injection, and the applicant would be 

required to have in place a spill prevention and response plan (NRC, 2003b). 

The applicant would construct the central plant on a concrete slab surrounded by a protective 

berm to contain and control accidental spills, and they would implement a stormwater 

management plan in accordance with WDEQ requirements to detain or treat runoff from the 

central plant. Runoff would be diverted away from the facility, where it would be absorbed into 

the soil. No wastewater discharge to surface water channels would occur. 

Because of the limited occurrence of surface water at the proposed Moore Ranch Project, the 

design of the central plant and wetlands to minimize potential spills, the stormwater permit and 

stormwater management plan requirements to ensure that runoff from disturbed areas meets 

Wyoming Pollutant Discharge Elimination System (WYPDES) permit limits, the implementation 

of a site-specific ERP to address accidental spills, and the applicant’s commitment to conduct 

operations in accordance with standard operating procedures for spill prevention and control, 

the potential impact to surface water and wetlands from the operations phase of the proposed 

Moore Ranch Project would be SMALL by the GEIS criteria. The anticipated impacts to surface 

water from operations at the proposed Moore Ranch ISR facility would be SMALL and would be 

further reduced by the applicant’s proposed mitigation measures described above. 

4.5.1.1.3 Aquifer Restoration Impacts 

Section 4.3.4.1.3 of the GEIS identified aquifer restoration activities that could potentially impact 

surface water (NRC, 2009a). These activities included management of produced water, 

stormwater runoff and accidental spills, and management of brine reject from the reverse 

osmosis system. The GEIS concluded the potential impacts from these activities would be 

similar to that which could occur during the operations phase because of the occurrence of 

either the same infrastructure or similar activities (e.g., wellfield operation, transfer of fluids, 

water treatment, stormwater runoff). For these reasons, the GEIS determined aquifer 

restoration impacts to surface water and wetlands could range from SMALL to MODERATE. 

The aquifer restoration phase at the proposed Moore Ranch Project would generate wastewater 

that would be disposed of via deep well injection. Automated sensors would monitor the 

injection process to detect potential leaks or pipe or well ruptures that could result in a surface 

discharge. In addition, the applicant would be required to have an NRC-approved spill response 

plan in place (NRC, 2003b). No wastewater would be discharged to surface water; therefore, 

there would be a SMALL impact to surface water during the aquifer restoration phase of the 

proposed Moore Ranch Project. 
Environmental Impacts and Mitigative Actions 

4-21 

4.5.1.1.4 Decommissioning Impacts 

Section 4.3.4.1.4 of the GEIS discussed impacts from the decommissioning phase of an ISR 

project and concluded the impacts from this phase would be similar to the impacts from 

construction (NRC, 2009a). Cleaning up, recontouring, and reclamation of disturbed lands 

during decommissioning would mitigate long-term impacts to surface water. The GEIS 

concluded that the potential impact to surface water from decommissioning could range from 

SMALL to MODERATE, depending on the site-specific conditions. 

During the decommissioning phase of the proposed Moore Ranch Project, the central plant, 

storage facilities, and pipelines would be removed. The wells would be plugged and 

abandoned. The impact from the removal of the building and infrastructure would have impacts 

similar to those described in Section 4.5.1.1.1. 

Temporary soil disturbances would occur during building and pipeline removal. This work would 

require temporary soil disturbance within the channel that bisects Wellfield 2 and would be 

conducted during the dry season to minimize potential sedimentation. Stockpiled topsoil would 

be returned to the disturbed areas, graded, and revegetated, in accordance with WDEQ-LDQ 

rules and regulations to mitigate soil erosion. 

During the decommissioning phase, the applicant would replace topsoil in previously disturbed 

areas, and the land surface would be recontoured to restore it to a surface configuration to 

blend in with the natural terrain. The replaced topsoil and other disturbed wellfield areas would 

be revegetated with a native seed mix, in accordance with WDEQ regulations and guidelines. 

The proposed decommissioning activities would have the potential to generate a limited amount 

of surface water runoff since the occurrence of surface water at the proposed Moore Ranch 

Project is very limited, surface water flow in the channels is intermittent, and given the USACE 

determination (USACE, 2010) the potential impact to surface water and wetlands from the 

decommissioning phase for Wellfield 1 of the proposed Moore Ranch Project was determined to 

be SMALL. Because the USACE authorized construction activities in Wellfield 2 under NP 12, 

the potential impacts from installation of wells and development of the related infrastructure to 

wetlands would be MODERATE. However, the applicant’s implementation of the mitigative 

measures described previously during the ISR decommissioning phase would reduce the 

impact to SMALL. The NRC staff concludes that site-specific impacts for the proposed Moore 

Ranch Project would be SMALL. No new and significant information was reviewed by NRC staff 

to change the expected environmental impact beyond that discussed in the GEIS. 

4.5.1.2 No-Action (Alternative 2) 

Under the No-Action alternative, there would be no impact to either surface water or wetlands 

from the construction and operation of the proposed Moore Ranch Project. The current land 

use in the proposed license area is primarily livestock ranching and CBM activities, as 

discussed in Section 3.2.1.1 of this SEIS. There are no residences and no recreational 

activities that occur on the proposed license area. The combination of ranching and CBM 

activities could result in specific actions that could potentially affect surface water or wetlands. 

The proposed Moore Ranch Project has an existing network of gravel and two-track roads for 

access to ranching and CBM facilities, which cross channels and washes at various locations. 

Under the No-Action alternative, these two-track roads would continue to be used in their 
Environmental Impacts and Mitigative Actions 

4-22 

current conditions resulting in localized fugitive dust emissions that could potentially settle on 

surface water. Under the No-Action alternative there would be no impact to surface water 

quality from the proposed Moore Ranch Project because the facility would not be licensed and 

no central plant, wellfields, additional access roads would be constructed nor would pipeline 

be laid. 

Livestock would continue to graze in channels and washes and would have unrestricted access 

to those channels and washes that would have limited access under the proposed action. Two 

companies have CBM claims within the proposed Moore Ranch Project (Uranium One, 2008). 

CBM production in the proposed license area would continue. Under the No-Action alternative, 

the 31 CBM wells located within the proposed license area would continue to operate and 

discharge surface water to channels and washes via outfalls permitted through the 

WYPDES program. 

4.5.2 Groundwater Impacts 

Potential environmental impacts to groundwater at the proposed Moore Ranch Project could 

occur during all phases of the ISR facility lifecycle but primarily during operations and aquifer 

restoration. A detailed discussion of the potential environmental impact to groundwater from the 

construction, operation, aquifer restoration, and decommissioning of the proposed Moore Ranch 

Project is described in the following sections. 

ISR activities can impact aquifers that occur at various depths (separated by confining layers, 

also known as aquitards) above and below the uranium-bearing aquifer, as well as adjacent 

surrounding aquifers in the vicinity of the uranium-bearing aquifer. Surface or near-surface 

activities that can introduce contaminants into soils are more likely to impact shallow aquifers 

during ISR operations, and aquifer restoration would have the potential to impact the deeper 

uranium-bearing aquifer and to potentially impact overlying and underlying aquifers and 

adjacent surrounding aquifers. 

ISR facility impacts to groundwater resources can occur from surface spills and leaks releases 

from shallow surface piping, consumptive water use, horizontal and vertical excursions of 

lixiviant from production aquifers, degradation of water quality from changes in production 

aquifer chemistry, and waste management practices involving deep well injection. The potential 

impacts to groundwater resources from construction, operations, aquifer restoration, and 

decommissioning is discussed in the following sections. 

4.5.2.1 Proposed Action (Alternative 1) 

4.5.2.1.1 Construction Impacts 

Section 4.3.4.2.1 of the GEIS concluded that potential impacts to groundwater during 

construction would primarily be from consumptive use of groundwater, injection of drilling fluids 

and mud during well drilling, and the potential spills of fuels and lubricants from construction 

equipment. The GEIS further indicated that groundwater use during the construction phase 

would be limited, and that groundwater would be protected by implementing BMP, such as spill 

prevention and cleanup. The volume of drilling fluids and mud introduced into the environment 

during well installation would be limited. Thus, the construction impacts to groundwater would 

be SMALL, based on the limited nature of construction activities and the implementation of BMP 

to protect shallow groundwater (NRC, 2009a). 
Environmental Impacts and Mitigative Actions 

4-23 

The consumptive water use during construction would be generally limited to routine activities 

such as dust control, drilling support, and cement mixing. The amount of consumptive water 

use in these activities would be small compared to consumptive water uses during ISR 

operation and restoration; therefore, its potential impacts on groundwater resources would be 

temporary and small. 

The volume of drilling fluids and muds used during well installation would be limited; the 

Wyoming UIC Program would require the applicant to implement BMPs to prevent, identify, and 

correct impacts to soils and the surficial 72 Sand aquifer at the proposed Moore Ranch Project. 

Drilling fluids and muds would be placed into mud pits to control the spread of the fluids, to 

minimize the area of soil contamination, and to enhance evaporation. According to 

Figure CR3.4.3.2 in the applicant’s technical report, the depth to the water table in the surficial 

72 Sand at the site ranges from 9 to 61 m [30 to 200 ft] below ground surface (EMC, 2007b). 

Therefore, any leakage from either the pits or spills during drilling would result in a small amount 

of infiltration; however, no changes to the water quality of the 72 Sand surficial aquifer would be 

expected. The introduction of drilling fluids into the 72 Sand, 70 Sand, 68 Sand, and 60 Sand 

aquifers would occur during the drilling of production and monitoring wells but the effect would 

be small, since drilling muds are designed to seal boreholes to set casing. 

As wells are installed, water would be pumped from aquifers for hydrologic testing, such as 

pumping tests. This water would be discharged to the surface in accordance with approved 

WYPDES permits obtained by applicant. The surface discharge permits would protect 

near-surface aquifers by limiting the discharge volume and prescribing concentration limits to 

discharged waters. 

During construction and wellfield installation at the proposed Moore Ranch Project, the 

groundwater quality of near-surface aquifers would be protected both by permit and BMPs that 

would include the applicant’s implementation of a spill prevention and cleanup program, 

extracting water from deeper, more prolific aquifers to minimize consumptive use impacts, and 

complying with WDEQ-approved discharge permits. The potential volume of stored fuels and 

lubricants in the proposed license area is expected to be small, and any leaks or spills would 

result in an immediate cleanup response to prevent soil contamination or infiltration to 

groundwater. 

The types of construction activities for the proposed Moore Ranch Project would have an 

anticipated SMALL impact on groundwater resources, based on the GEIS criteria. Based on this 

analysis, consumptive groundwater use during the construction phase would be limited and 

would have a SMALL and temporary impact. The impact to groundwater resources during 

wellfield and facility construction would be SMALL, based on the limited nature of construction 

activities and the applicant’s implementation of WYPDES permit requirements and the BMPs 

described above to protect soils and shallow groundwater. 

4.5.2.1.2 Operations Impacts 

Section 4.3.4.2.2 of the GEIS discussed potential impacts to shallow (near-surface) aquifers 

during ISR operations. During this phase of an ISR operation, shallow aquifers could potentially 

be affected by lixiviant leaks from pipelines, wells, or header houses and from waste 

management practices such as the use of evaporation ponds and disposal of treated 

wastewater by land application. Potential environmental impacts to groundwater resources in 

the production and surrounding aquifers also include consumptive water use and changes to 

water quality that could result from normal operations in the production aquifer and from 
Environmental Impacts and Mitigative Actions 

4-24 

possible horizontal and vertical lixiviant excursions beyond the production zone. Disposal of 

processing wastes by deep well injection during ISR operations could also potentially impact 

groundwater resources (NRC, 2009a). 

4.5.2.1.2.1 Operations Impacts to Shallow (Near-Surface) Aquifers 

Section 4.3.4.2.2.1 of the GEIS discussed the potential impacts to shallow aquifers during ISR 

operations. A network of buried pipelines is used during ISR operations to transport lixiviant 

between the header house and the satellite or main processing facility and also to connect 

injection and extraction wells to manifolds inside the pumping header houses. Failure of 

pipeline fittings or valves, or failures of well mechanical integrity in shallow aquifers, could result 

in leaks and spills of pregnant and barren lixiviant, which could impact water quality in shallow 

aquifers. The potential environmental impact of such pipeline, valve, or well integrity failure 

depends on a number of factors, including the depth to shallow groundwater, the use of shallow 

groundwater, and the degree of hydraulic connection between shallow aquifers and regionally 

important aquifers. The GEIS concluded that potential environmental impacts could range from 

MODERATE to LARGE, if 

(1) The groundwater in shallow aquifers is close to the ground surface; 

(2) The shallow aquifers are important sources for local domestic or agricultural 

water supplies; and 

(3) Shallow aquifers are hydraulically connected to other locally or regionally 

important aquifers. 

The potential environmental impacts could be SMALL if either shallow aquifers have poor water 

quality or noneconomic production yields and if they are hydraulically separated from other 

locally and regionally important aquifers. 

Hydrogeologic data from the proposed Moore Ranch Project indicates that the 72 Sand is the 

first aquifer encountered below the land surface. In some small areas, isolated occurrences of 

perched water are encountered in the 80 Sand, which overlies the 72 Sand across the proposed 

license area. The 72 Sand is not saturated in the southern portion of the proposed license area. 

In these areas, the 70 Sand is the surficial aquifer. 

Because of the shallow depth to groundwater in the 72 Sand and 80 Sand where they occur, 

they could potentially be impacted by releases at or near the ground surface during operations. 

A surface release could potentially impact groundwater, depending on the depth to the water 

table, the permeability of the materials in the unsaturated zone, the potential adsorption of 

constituents in the unsaturated zone, and the volume of a potential release. The 72 and 

80 Sand aquifers could also be impacted by potential well casing leaks during operations. 

As indicated in the GEIS, the potential impact of a surface release on shallow groundwater 

would be greatly reduced by NRC-required leak detection programs. All wells would be tested 

for mechanical integrity every five years to detect casing leaks. Wells that failed mechanical 

integrity tests would be either corrected or removed from operation. A licensee would also 

follow an aggressive leak-detection and spill-cleanup program during operations. High- and 

low-flow alarms for individual wells would be the primary means for timely identification of a pipe 

rupture. Header houses would be equipped with a “wet building” alarm to detect the presence 

of liquids in building sumps. In addition, daily visual inspections of wellfield monitoring would 
Environmental Impacts and Mitigative Actions 

4-25 

occur. Spills exceeding 1,590 L [420 gal] would be reported to the WDEQ, accompanied by a 

report to NRC. Following repair of wellfield leaks, contamination surveys would be performed; 

and contaminated soils would either be immediately remediated if concentrations exceeded 

regulatory requirements or left in place and cleaned up during decommissioning. The applicant 

would design the concrete curb around the perimeter of the central plant and the underlying 

concrete pad at the proposed Moore Ranch Project to contain the contents of the largest tank 

within the central plant, in the event of a rupture. Plant fluid spills would be contained, drained 

to the sump system, and pumped to the waste disposal system. Thus, the applicant BMP would 

mitigate the impact of a potential release (EMC, 2007a,b) and its potential impact on shallow 

groundwater. 

Because the 72 Sand aquifer overlies the 70 Sand production zone, it would be monitored by 

wells installed to detect vertical excursions. The applicant’s proposed monitoring of the 72 Sand 

would provide an extra level of wellfield surveillance to detect impacts from either potential 

surface spills or casing leaks. The 72 Sand monitoring wells would be spaced at a density of 

one well to every 1.6 ha [4 ac] in the wellfields, and sampled for excursion parameters every 2 

weeks to detect the presence of production fluids. 

No water wells for either domestic or agricultural use are completed in the 72 Sand within the 

proposed Moore Ranch license area. Therefore, the shallow aquifer in the 72 Sand is not an 

important source for local domestic or agricultural water supplies. Furthermore, the 72 Sand is 

a perched aquifer over the majority of the proposed license area; therefore, it is not hydraulically 

connected to other locally or regionally important aquifers. At locations where the 72 Sand 

aquifer is not perched, it is underlain by a sufficiently thick shale layer to prevent a hydraulic 

connection to other significant aquifers. 

Based on the previous analysis, the impact on shallow groundwater in the 72 Sand and on 

groundwater in the perched 80 Sand aquifer from operations at the proposed Moore Ranch 

Project would be SMALL. Impacts to the surrounding aquifer from the 72 Sand would also be 

expected to be SMALL. 

4.5.2.1.2.2 Operations Impacts to Production and Surrounding Aquifers 

The potential environmental impact to groundwater supplies in the production and other 

surrounding aquifers are related to consumptive water use and groundwater quality. 

Water Consumptive Use

Section 4.3.4.2.2.2 of the GEIS discussed groundwater being withdrawn and reinjected into the 

production zone during ISR operations (NRC, 2009a). Most of the water withdrawn from the 

aquifer is returned to the aquifer. That portion of groundwater that is not returned to the aquifer 

is referred to as consumptive use. The consumptive use is primarily from production bleed and 

also includes other smaller losses. Production bleed is the net withdrawal maintained to ensure 

that groundwater flow is toward the production network to minimize the potential movement of 

lixiviant and its associated nonradiological constituents out of the wellfield. 

The portion of an aquifer where production occurs must be designated as an exempt aquifer by 

the EPA, pursuant to the Federal UIC regulations, before any production begins. The exempt 

aquifer designation should be in compliance with 40 CFR 146.4, which states that an aquifer 

may be exempted if it is not, it cannot now, nor would it ever be a source of drinking water in the 
Environmental Impacts and Mitigative Actions 

4-26 

location covered by the exemption, if the total dissolved solids content of the groundwater is 

more than 3,000 ppm and less than 10,000 ppm, and the aquifer is not reasonably expected to 

supply a public water system. Moreover, under the Federal UIC regulation, the exempted 

aquifer would no longer be protected under the Safe Drinking Water Act (SDWA) as an 

Underground Source of Drinking Water (USDW). At the proposed Moore Ranch Project, 

portions of the 70 Sand, where production operations would occur, and typically a buffer zone 

would potentially be exempted by EPA. Groundwater in the aquifer outside the designated 

exempt zone would be considered a possible source of drinking water, if of appropriate quality. 

Consumptive water use during ISR operations could potentially impact local water users who 

also extract water from wells completed in the production aquifer outside the exempted zone. 

This potential impact would result from drawing down water levels in nearby wells, thus 

potentially reducing the well yields. Furthermore, if the production zone was hydraulically 

connected to other aquifers above and/or below, consumptive use could impact the water levels 

in both overlying and underlying aquifers and create a drawdown in water level, thus reducing 

the potential yield from nearby wells completed in these aquifers (NRC, 2009a). 

As discussed in Section 3.5.2, the 70 Sand production zone at the proposed Moore Ranch 

Project is not completely saturated over the proposed license area. Therefore, it is an 

unconfined aquifer. The unconfined conditions in the production zone help to reduce the 

potential impact from the consumptive use anticipated during ISR operations. For a given net 

withdrawal, an unconfined aquifer exhibits substantially less drawdown in water level over a 

smaller area, relative to that exhibited in a confined aquifer. As shown in Figure 4-1, the water 

produced from a well in an unconfined aquifer (water level below overlying aquitard) comes from 

dewatering of the aquifer pore space in the production zone. 

To assess the potential drawdown in the unconfined aquifer at proposed Moore Ranch Project, 

the applicant developed an unsaturated groundwater flow model for the 70 Sand that covered 

the entire proposed license area. The model was created within the Groundwater Vistas 

platform and used MODFLOW–SURFACT Version 3.0, an industry standard unsaturated 

groundwater flow code. The applicant calibrated the model to site-specific conditions and 

Figure 4-1. Difference In Size and Type of Drawdown in an Unconfined Aquifer and 

Confined Aquifer from an Extraction Well Operating at a Same Rate

T

QW u s 114 . 6 ( ) =

Overlying Sand

Overlying Aquitard

Ore Zone

Underlying aquitard

Extraction Well

In Unconfined Aquifer

Flow

Small area of dewatering 

drawdown Water level in ore zone

T

QW u s 114 . 6 ( ) =

Overlying Sand

Overlying Aquitard

Ore Zone

Underlying aquitard

Extraction Well

In Unconfined Aquifer

Flow

Small area of dewatering 

drawdown Water level in ore zone

T

QW u s 114 . 6 ( ) =

Overlying Sand

Overlying Aquitard

Ore Zone

Underlying aquitard

Extraction Well

in Confined Aquifer

Flow

Larger area of pressure 

drawdown

No dewatering

Water level in ore zone

T

QW u s 114 . 6 ( ) =

Overlying Sand

Overlying Aquitard

Ore Zone

Underlying aquitard

Extraction Well

in Confined Aquifer

Flow

Larger area of pressure 

drawdown

No dewatering

Water level in ore zone
Environmental Impacts and Mitigative Actions 

4-27 

verified it by use of site-specific Moore Ranch Project field pumping test data. The modeling, 

which the NRC staff reviewed and found acceptable, is presented in the applicant response to a 

request for additional information dated October 27, 2008, (Uranium One, 2008). 

The model analyzed drawdowns during various phases of ISR production and aquifer 

restoration. For production operations, it assumed production rates of approximately 

11,360 L/min [3,000 gal/min] and production bleeds ranging between 0.8 and 1.3 percent, 

which translates into a production consumptive use rate of 90.9 L/min to 147.6 L/min 

[24 gal/min to 39 gal/min]. 

The model drawdown simulations in the 70 Sand at the end of production operations for the 

previous consumptive use rates were provided in Figure CR4.4.2.1-1b (Uranium One, 2008). 

The end of production provides the best estimate of the maximum drawdown for total 

consumptive use during the operations phase. The results of the drawdown simulations show 

that the cone of depression created by the consumptive use at the end of operations results in a 

drawdown of about 0.30 to 1.2 m [1 to 4 ft] at the proposed license area boundary. The 

drawdown contour of 0.30 m [1 ft] extends outside the proposed license area to the north, 

northwest, west, and southwest for approximately 1.6 to 3.2 km [1 to 2 mi]. 

To estimate the potential impact of the simulated drawdown on private wells, private well users 

with wells completed in the 68–70 Sand, 70 Sand, and 70–72 Sand located within 3.2 km [2 mi] 

of the proposed Moore Ranch Project boundary were identified. Their locations are shown in 

Figure CR4.4.2.1-1a (Uranium One, 2008). The drawdown in each of these private wells was 

simulated and the results shown in Table CR4.4.2-1-2b (Uranium One, 2008). Only one private 

well, located just outside the northwest portion of the proposed license area and drilled to a total 

depth of 108 m [355 ft] below ground surface and completed in the 70 Sand, had a static water 

level of 46 m [150 ft] below ground surface and indicated a drawdown of more than one foot. 

The estimated drawdown in this well was 1.08 m [3.53 ft] at the end of the operations phase; 

this amount of drawdown would have a negligible impact on well yield. 

Given the hydraulic isolation separating the 72 Sand and 70 Sand production zone, there 

appears to be little potential impact on water levels in the 72 Sand resulting from the 

consumptive use in the 70 Sand production zone. However, there appears to be hydraulic 

interconnection between the underlying 68 Sand and the 70 Sand production zone in the portion 

of Wellfield 2 where the 68 and 70 Sands coalesce (see Section 3.5.2). In this portion of 

Wellfield 2, the 68 Sand would be included as part of the production zone, although no 

production wells would be installed. 

To determine the impact of production operations on water levels in the 68 Sand and 

surrounding users, the applicant assumed a worst-case-estimate scenario. In this scenario, the 

drawdown in the 68 Sand, which would have no operating wells completed in it, was assumed 

to be the same as that simulated for the 70 Sand at the end of production operations. This is a 

conservative drawdown estimate because data from pumping tests indicate that there would be 

less drawdown in the 68 Sand where the 70 and 68 Sands coalesce. Using this assumption, 

Table CR4.4.2.1-2b shows that three wells completed in the 68 Sand and located to the 

northeast and southeast outside of the proposed license area would have nominal drawdowns 

of 0.02, 0.07, and 0.003 m [0.08, 0.23, and 0.01 ft] (Uranium One, 2008). This amount of 

drawdown would not be expected to affect well yields. 
Environmental Impacts and Mitigative Actions 

4-28 

Based on the consumptive use and groundwater modeling drawdown predictions in the 70 Sand 

and the 68 Sand during operations, private wells within 3.2 km [2 mi] radius surrounding the 

proposed license area would experience a small or nominal drawdown in their private wells, 

which would not impact well yields. Therefore, the potential environmental impact to 

groundwater supplies and users in the production and other surrounding aquifers would 

be SMALL. 

Excursions and Groundwater Quality 

As discussed in the GEIS (NRC, 2009a), groundwater quality in the production zone would be 

degraded as part of ISR operations. The production portion of the aquifer would be 

recommended for exemption as a USDW by WDEQ to EPA. After production operations are 

completed, the licensee would be required to return water-quality parameters to the standards in 

10 CFR Part 40, Appendix A, Criterion 5B(5). As stated in 10 CFR Part 40, Appendix A, 

Criterion 5B(5), “at the point of compliance, the concentration of a hazardous constituent must 

not exceed─(a) the Commission approved background concentration of that constituent in the 

groundwater; (b) the respective value given in the Table 5C if the constituent is listed in the 

table and if the background level of the constituent is below the value listed; or (c) an alternate 

concentration limit (ACL) established by the Commission.” Only after demonstrating that it 

cannot restore a particular hazardous constituent to the background concentration or maximum 

contaminant level (MCL), a licensee can request a license amendment from the NRC for an 

ACL for a particular hazardous constituent. Appendix C explains the process for granting an 

ACL. For proposed ACLs to be approved, they must be shown to protect public health at the 

site. For these reasons, potential impacts to the water quality of the uranium-bearing production 

zone aquifer as a result of ISR operations would be SMALL. 

In Section 2.11.4 of the GEIS, the NRC staff documented historical information from operating 

ISR facilities at which excursions have occurred. Separately, the NRC staff analyzed the 

environmental impacts from both horizontal and vertical excursions at three NRC-licensed ISR 

facilities (NRC, 2009b). In that analysis, which considered 60 events at three facilities, the NRC 

staff found that the licensees were able to control and reverse the excursions through pumping 

and extraction at nearby wells for most events. Most excursions were short-lived, although a 

few continued for several years. In all cases, environmental impacts were SMALL and 

temporary (NRC, 2009b). 

Poor well integrity involving a cracked well casing or leaking joints between casing sections 

could cause vertical excursions (NUREG–1910, Section 2.4.1.3). The applicant would be 

required to take preventive measures against vertical excursions prior to operations, including 

well integrity tests (Section 1 of NUREG-1910). The applicant is required to conduct 

mechanical integrity testing of each well to check for leaks or cracks in the casing, in 

compliance with 10 CFR 146.8. The conduct of mechanical integrity testing reduces the 

likelihood of poor well integrity and potential excursions. Therefore, the impacts from such 

excursions would be SMALL. 

To prevent horizontal excursions, inward hydraulic gradients are maintained in the production 

aquifer during ISR operations (NRC, 2009a). These inward hydraulic gradients are created by 

the net groundwater withdrawals (production bleeds) maintained through continued pumping 

during ISR operations. Groundwater flows in response to these inward hydraulic gradients, thus 

ensuring that groundwater flow is toward the production zone. This inward groundwater flow 
Environmental Impacts and Mitigative Actions 

4-29 

toward the extraction wells prevents horizontal excursions of lixiviant solutions away from the 

production zone. 

NRC also requires a licensee to take preventive measures to reduce the likelihood and 

consequences of potential excursions. A ring of monitoring wells outside of and encircling the 

production zone is required for early detection of horizontal excursions. If excursions are 

suspected, corrective actions are required. The impacts from these excursions would therefore 

be expected to be SMALL. 

The GEIS also discussed the potential for vertical excursions into aquifers overlying or 

underlying the production zone aquifer. The GEIS concluded that the potential for leaching 

solution to migrate into an overlying or underlying aquifer was SMALL, if the thickness of the 

aquitard separating the production zone from the overlying and underlying aquifer was of 

sufficient thickness and the aquitard has low permeability (NRC, 2009a). The vertical hydraulic 

gradient between the production zone and overlying or underlying aquifers is also used to 

determine the potential for vertical excursions. NRC also requires monitoring in the overlying 

and underlying aquifers. Corrective action is also required if any vertical excursions are 

detected (NRC, 2003b). 

At the proposed Moore Ranch Project, the 70 Sand aquifer would be designated as an exempt 

aquifer before production operations began, in accordance with 40 CFR Part 146. The 

applicant reported that the Sand 70 and the Sand 68 coalesce in Wellfield 2 near the monitoring 

well MW-2 location. Therefore, NRC expects the 68 Sand would also be exempted. However, 

the WDEQ and the EPA would make the decision to exempt the Sand 68 aquifer within the 

proposed license area. The groundwater chemistry would be changed as lixiviant is injected to 

mobilize uranium for extraction. At the end of operations, aquifer restoration using Best 

Practicable Technology would be initiated to return the 70 Sand aquifer to baseline conditions, 

or the maximum contaminant levels provided in Table 5C of 10 CFR Part 40, Appendix A, or to 

ACLs. Restoration to these standards would ensure that groundwater quality within the 

exemption boundary after restoration would not pose a threat to surrounding groundwater. For 

these reasons, potential impacts to the water quality of the 70 Sand production zone aquifer and 

surrounding aquifers as a result of ISR operations would be SMALL. 

The occurrence of an unconfined aquifer in the 70 Sand production zone at the proposed 

Moore Ranch Project requires special consideration when evaluating the appropriate inward 

hydraulic gradient, the reliability of monitoring around the wellfield periphery, and evaluating the 

capability to pull back a potential horizontal excursion. As discussed earlier, the applicant 

developed an unsaturated numerical groundwater model to simulate drawdown in the 

unconfined portion of the 70 Sand production zone. The model was calibrated using sitespecific hydraulic data and presented in Appendix B–4 of the applicant’s technical report (EMC, 

2007b). The model simulations indicate that it would be possible to maintain the necessary 

inward gradient during ISR operations to prevent horizontal excursions (EMC, 2007b). 

To detect horizontal excursions from the proposed wellfields at the proposed Moore Ranch 

Project, monitoring well rings with the wells completed in the 70 Sand production zone would be 

installed at each wellfield. The monitoring wells would be located approximately 152 m [500 ft] 

from the edge of each wellfield and spaced 152 m [500 ft] apart around the perimeter of the 

wellfield. The wells would be sampled biweekly for chloride, alkalinity, and conductivity, the 

excursion parameters that are indicative of the presence of production fluids. Any well samples 

containing more than two of these excursion indicators at prescribed levels (derived based on 
Environmental Impacts and Mitigative Actions 

4-30 

baseline values) would be placed on excursion status and the applicant would notify WDEQ and 

NRC within 24 hours. All wells on excursion status would be monitored every seven days until 

the indicators returned to nonexcursion levels. The applicant would modify wellfield operations, 

as necessary, to correct the excursion. If a well remained on excursion for more than 60 days, 

the applicant would provide a plan to NRC to correct the excursion. The applicant will be able 

to confirm the behavior of the unsaturated aquifer during wellfield testing and before operations 

begin. By license condition, the testing results will be provided to the NRC for review and 

approval in a wellfield hydrologic test data package that NRC will evaluate to ensure the field 

data support the simulation results. 

Given the applicant’s maintenance of an inward hydraulic gradient to prevent excursions, the 

NRC requirement to implement a monitoring well ring to detect excursions, and a plan to correct 

them, the potential impact from horizontal excursions at the proposed Moore Ranch Project 

would be SMALL. 

The 72 Sand aquifer overlies the 70 Sand production aquifer. The water table within the 

72 Sand is perched on the underlying aquitard that separates the 72 Sand from the 70 Sand 

production aquifer. The water levels in the 72 Sand are generally much higher than that in the 

70 Sand. The combination of the perched water table and the high water levels in the 72 Sand, 

relative to the 70 Sand, demonstrate the absence of a hydraulic interconnection between the 

72 and 70 Sands. The unconfined conditions in the 70 Sand further support this conclusion. 

Pumping tests conducted to date have not demonstrated any hydraulic connection between 

the 70 and 72 Sands. When this lack of hydraulic connection is considered along with the 

requirement for the applicant to conduct mechanical integrity testing for all production wells 

(Section 2.1.1.2.3.3), the potential for vertical excursions from the production zone into the 

overlying 72 Sand would be SMALL. 

A relatively thick and low permeability aquitard separates the 70 Sand production aquifer from 

the underlying 68 Sand throughout much of the proposed license area. Pumping tests 

conducted to date indicate that the 68 Sand is hydraulically isolated in Wellfield 1. Therefore, 

the potential for vertical excursions from the production zone into the underlying 68 Sand in 

Wellfield 1 is SMALL. In portions of Wellfield 2; however, the aquitard separating the 68 and 

70 Sand is missing, as previously discussed in Section 3.5.2. The 68 and 70 Sands coalesce 

where the aquitard is missing, and the two aquifers appear to be hydraulically interconnected. 

The 68 Sand would be included as part of the production zone in the area where the 68 and 

70 Sands coalesce. The underlying 60 Sand, which is separated by a continuous shale layer, 

would be treated as the underlying aquifer. The actual well spacing may be adjusted based on 

the results from the Wellfield 2 hydrologic test package discussed previously. The potential for 

vertical excursions from the production zone in Wellfield 2 into the underlying 60 Sand would 

be SMALL. 

To detect potential vertical excursions at the proposed Moore Ranch Project, the aquifers that 

overly and underlie the 70 Sand, which include the 72, 68, and 60 Sands, would be monitored at 

a spacing of 1 well per 1.6 ha [4 ac]. The same sample constituents and process for horizontal 

excursions previously described would be followed to monitor for vertical excursions. 

Given the isolation of the overlying and underlying aquifers from the 70 Sand production zone 

by low permeability shale layers, required mechanical integrity testing for all production wells, 

and the use of monitoring wells to detect excursions and correct them, the impact from a 

potential vertical excursion at the proposed Moore Ranch Project would be SMALL. 
Environmental Impacts and Mitigative Actions 

4-31 

4.5.2.1.2.3 Operations Impacts to Deep Aquifers Below the Production Aquifers 

Potential environmental impacts to confined deep aquifers below the production aquifers could

occur from deep well injection of wastewater into deep aquifers. Under different environmental 

laws, such as the Clean Water Act, the Safe Drinking Water Act, and the Clean Air Act, EPA

has statutory authority to regulate activities that may affect the environment. Underground 

injection requires a permit from EPA or from an authorized state UIC program. The WDEQ has 

been authorized to administer the UIC program in Wyoming and would be responsible for 

issuing permits for deep well disposal at the proposed Moore Ranch Project. 

WDEQ would only permit Class I disposal wells if the groundwater quality in the injection zone 

would not be suitable for domestic or agricultural uses (e.g., high salinity), could not be 

designated as a USDW, and if the injection zone was confined above by sufficiently thick and 

continuous low-permeability layers. 

The GEIS (Section 4.3.4.2.2.3) indicated that in the Wyoming East Uranium Milling Region, 

where the proposed Moore Ranch Project is located, the deep Paleozoic aquifers are 

hydraulically separated from the proposed aquifer sequence where ISR operations would occur. 

The stratigraphic sequence, from shallowest to the deepest, includes the Wasatch Formation, 

the Fort Union Formation, the Lance Formation, and the Fox Hills Formation. Thick, 

low-permeability confining layers separate the aquifer sequence, including the Pierre Shale, the 

Lewis Shale, and the Steele Shale (Whitehead, 1996). Hence, nonkarstic Paleozoic aquifers 

(e.g., Tensleep Sandstone) can be investigated for their suitability for deep well disposal of 

leaching solutions. The GEIS concluded that in the Wyoming East Uranium Milling Region, 

considering the relatively poor water quality in and the reduced water yields from nonkarstic 

Paleozoic aquifers and the occurrence of thick and regionally continuous aquitards confining 

them from above, the potential environmental impacts from deep injection of leaching solution 

into nonkarstic Paleozoic aquifers could be SMALL. Regionally, the Pierre Shale was reported 

to be fractured in some places (Whitehead, 1996). Considering potential heterogeneities in the 

hydrogeologic properties of the Pierre Shale, the potential impacts could range from SMALL to 

MODERATE in locations where the Pierre Shale might be fractured. 

Up to four Class I wells could be drilled at the proposed Moore Ranch Project for deep 

disposal of liquid effluent, depending on the production rates and the capacity of each 

disposal well. The State of Wyoming is reviewing a permit application for up to four Class I 

disposal wells at the proposed Moore Ranch Project. The application includes injection into 

the Teapot-Teckla-Parkman Formation with an injection depth of 2,413 m to 2,929 m 

[7,916 to 9,610 ft]. Injection rates for this interval are expected to be about 30 gal/min. This 

aquifer may be a candidate for exempt aquifer status, if (1) it does not currently serve as a 

source of drinking water, (2) it cannot now, or will not in the future, serve as a source of drinking 

water because of contamination or economic or technical impractability; and (3) the TDS 

concentrations are greater than 3,000 ppm and less than 10,000 mg/L, and not reasonably 

expected to supply a public water system (40 CFR 146.4). The application also includes 

injection into the Lance Formation at depths of 1,615 m to 2,286 m [5,300 to 7,500 ft]; because 

the Lance Formation has a much greater injection capacity, only two Class I disposal wells 

would be required to support the proposed Moore Ranch Project operations. However, the 

water quality in the Lance Formation could be less than 10,000 mg/L TDS, and if the aquifer is 

not exempted, it could potentially be an underground source of drinking water as defined in 

40 CFR 144.3, which would eliminate it from consideration as an injection zone for a Class I 

deep disposal well. 
Environmental Impacts and Mitigative Actions 

4-32 

The WDEQ will evaluate the suitability of the formations proposed for deep well injection and 

would only grant such a permit to the applicant if it can be demonstrated that liquid effluent 

could be safely isolated in a deep aquifer. Consequently, it has been assumed that if WDEQ 

approved the permit application, the potential environmental impact to deep aquifers from deep 

well injection at the proposed Moore Ranch Project would be SMALL. 

4.5.2.1.3 Aquifer Restoration Impacts 

The potential environmental impacts to groundwater resources during aquifer restoration are 

related to groundwater consumptive use and waste management practices, including deep well 

injection of wastewater. In addition, aquifer restoration directly affects groundwater quality in 

the vicinity of the wellfield being restored. As discussed in the GEIS, the impacts of 

consumptive groundwater use during aquifer restoration are generally greater than during ISR 

operations because a larger volume of groundwater is generally withdrawn if groundwater 

sweeps are used during the aquifer restoration phase. Larger withdrawals could produce larger 

drawdowns in the production aquifer, resulting in a greater impact on the yields of nearby wells. 

However, the rate of groundwater consumptive use during aquifer restoration would be lowered 

during the reverse osmosis phase, because up to 70 percent of the pumped groundwater 

treated by reverse osmosis can be reinjected into the aquifer. 

The impact from consumptive use during ISR production operations was previously discussed in 

Section 4.5.2.1.2.2 of this SEIS, which describes the applicant’s use of an unsaturated 

numerical groundwater flow model to estimate drawdown for the production phase consumptive 

groundwater use of the 70 Sand production zone. The same model was used to predict the 

drawdowns in Wellfield 1 and Wellfield 2 at the end of aquifer restoration using assumed 

consumptive use rates for each phase. 

The predicted drawdown in the 70 Sand from model simulation of the end of aquifer restoration 

in Wellfield 1 is shown in Figure CR4.4.2.1-1c of the applicant’s technical report (EMC, 2007b). 

The drawdown simulation results indicate that the cone of depression created by consumptive 

use during aquifer restoration would drawdown the water level about 0.3 to 2.7 m [1 to 9 ft] at 

the proposed license area boundary. The drawdown contour of 0.3 m [1 ft] extends outside the 

proposed license area to the north, northwest, west, and southwest for approximately 1.6 to 

6.4 km [1 to 4 mi]. 

The drawdown-model simulation in the 70 Sand at the end of aquifer restoration in Wellfield 2 is 

shown in Figure CR4.4.2.1-1d of the applicant’s technical report (EMC, 2007b). The drawdown 

simulation results show that the cone of depression created by consumptive use during aquifer 

restoration would result in a drawdown of about 0.3 to 1.8 m [1 to 6 ft] at the proposed license 

area boundary. The drawdown contour of 0.3 m [1 ft] extends outside the proposed license 

area to the north, northwest, west, and southwest for approximately 1.6 to 6.4 km [1 to 4 mi.] 

To estimate the impact of the simulated drawdown on private well users, the applicant identified 

all private wells completed in the 68 to 70 Sand, 70 Sand, and 70 to 72 Sand within 3.2-km 

[2-mi] radius of the proposed Moore Ranch Project. Only one private well, located just 

northwest of the proposed license area and completed in the 70 Sand, would have a drawdown 

of more than 0.3 m [1 ft] during the restoration phases of both Wellfields 1 and 2. The 

drawdown in this well at the end of Wellfield 1 aquifer restoration was predicted at 2.4 m 

[7.87 ft]. The drawdown at the end of Wellfield 2 restoration was predicted at 1.80 m [5.90 ft]. 

The well was completed to a depth of 108 m [355 ft] below ground surface (bgs) with a static 
Environmental Impacts and Mitigative Actions 

4-33 

water level of 46 m [150 ft] bgs, indicating an operating water level of 62 m [205 ft]. A decrease 

of 1.8 to 2.4 m [5.9 to 8.0 ft] would likely have a negligible impact on well yield. 

Given the hydraulic isolation of the overlying 72 Sand from the production zone, there would be 

little potential to impact water levels in the 72 Sand from groundwater consumptive use in the 

production zone during aquifer restoration. However, as previously noted because there is an 

apparent hydraulic interconnection between the underlying 68 Sand and the 70 Sand production 

zone in Wellfield 2 where the 68 and 70 Sands coalesce (see Section 3.5.2), the 68 Sand would 

be included as part of the production zone at this location. 

To determine the impact of restoration operations on water levels in the 68 Sand and to 

surrounding users, the applicant simulated a worst-case scenario in which the drawdown in the 

68 Sand (where no operating wells would be completed), was assumed to be the same as that 

for the 70 Sand at the end of aquifer restoration. The results showed that three wells completed 

in the 68 Sand, located outside of the proposed license area to the northeast and southeast, 

would have nominal drawdowns of 0.21, 0.28, and 0.001 m [0.68, 0.91, and 0.04 ft] in Wellfield 

1 at the end of aquifer restoration, and drawdowns of 0.3, 0.4, and 0.001 m [1.08, 1.20, and 

0.04 ft] in Wellfield 2 at the end of aquifer restoration. These drawdowns would not likely impact 

well yields. 

The potential impacts to groundwater from aquifer restoration could range from SMALL to 

MODERATE based on the GEIS criteria. Based on consumptive use and groundwater modeling 

predictions of drawdown in the 70 and 68 Sands in Wellfield 2 resulting from aquifer restoration, 

private wells within 3.2 km [2 mi] surrounding the proposed license area would experience a 

small or nominal drawdown in water level, which would not likely impact well yields. Therefore, 

the potential environmental impact on groundwater supplies and to other users of both the 

production and other surrounding aquifers would be SMALL. 

Aquifer restoration should directly impact groundwater quality in the production zone. As 

discussed previously,” the purpose of restoration is to return the groundwater quality in the 

production zone to groundwater protection standards in 10 CFR Part 40, Appendix A, Criterion 

5B(5). These standards state the concentration of a hazardous constituent must not exceed 

(a) the Commission approved background concentration of that constituent in groundwater, 

(b) the respective value in the table in paragraph 5C if the constituent is listed in the table and if 

the background level of the constituent is below the value listed, or (c) an alternative 

concentration limit established by the Commission.” 

The restoration of the 70 Sand production zone, including the potentially-impacted portion of the 

68 Sand in Wellfield 2 would restore the groundwater quality to standards that are protective of 

human health and the environment and that do not impact surrounding aquifers. Therefore, the 

impact of aquifer restoration on groundwater quality would be SMALL. 

4.5.2.1.4 Decommissioning Impacts 

Section 4.3.4.2.4 of the GEIS discussed potential impacts to groundwater during construction 

as being primarily from consumptive use of groundwater, potential spills of fuels and 

lubricants, and well abandonment. The consumptive use of groundwater during 

decommissioning would be much less than during either ISR operations or aquifer restoration. 

Fuel and lubricant spills during decommissioning activities could potentially impact shallow 

groundwater. Implementation of BMP as part of an NRC-approved decommissioning plan 
Environmental Impacts and Mitigative Actions 

4-34 

(NRC, 2003b), would reduce the likelihood of such spills and the impact to groundwater 

resources in shallow aquifers from decommissioning would be SMALL. 

Furthermore, prior to NRC termination of the ISR source material license, the licensee must 

demonstrate that there would be no long-term impacts to a USDW. NRC review and approval 

for the completion of wellfield restoration at the site would have determined that the restoration 

standards were protective of public health and safety. 

As part of the restoration and reclamation activities, all monitor, injection, and recovery wells at 

the proposed Moore Ranch Project would be plugged and abandoned in accordance with the 

Wyoming UIC program requirements. If this process was properly implemented and the 

abandoned wells were properly isolated from the flow domain, the potential environmental 

impacts would be SMALL. 

4.5.2.2 No-Action (Alternative 2) 

Under the No-Action alternative, no construction, operations, aquifer restoration, or 

decommissioning activities would occur that could potentially impact shallow groundwater. No 

lixiviant would be injected into the subsurface; therefore, there would be no affect on the aquifer 

and no consumptive use of groundwater. No liquid effluents would be generated; therefore, 

there would be no Class I well constructed for disposal of liquid wastes. Therefore, under the 

No-Action alternative, there would be no impact to groundwater above the baseline described in 

Section 3.5.2. 

4.6 Ecological Resources Impacts 

Potential environmental impacts to ecological resources, including both flora and fauna at the 

proposed Moore Ranch Project, could occur during all phases of the ISR facility lifecycle. 

Impacts could include the removal of vegetation from the site (with the associated reduction in 

wildlife habitat and forage productivity and an increased risk of soil erosion and weed invasion); 

the modification of existing vegetative communities as a result of site activities; the loss of 

sensitive plants and habitats; and the potential spread of invasive species and noxious weed 

populations. Impacts to wildlife could include loss, alteration, or incremental fragmentation of 

habitat; displacement of and stresses on wildlife; and direct and/or indirect mortalities. Aquatic 

species could be affected by disturbance of stream channels, increases in suspended 

sediments, fuel spills, and habitat reduction. 

The potential environmental impacts to ecological resources from construction, operation, 

aquifer restoration, and decommissioning are discussed in the following sections. 

4.6.1 Proposed Action (Alternative 1) 

Section 4.3.5.1 of the GEIS discussed potential impacts to terrestrial vegetation from 

construction through (1) the removal of vegetation from the milling site (and associated 

reduction in wildlife habitat and forage productivity and an increased risk of soil erosion and 

weed invasion), (2) the modification of existing vegetative communities, (3) the loss of sensitive 

plants and habitats as a result of clearing and grading, and (4) the potential spread of invasive 

species and noxious weed populations. Potential impacts to wildlife include (1) habitat loss or 

alteration and incremental habitat fragmentation, (2) displacement of wildlife from proposed 
Environmental Impacts and Mitigative Actions 

4-35 

project construction, and (3) direct or indirect mortalities from proposed project construction and 

operation (NRC, 2009a). 

As further indicated in the GEIS, the percentage of vegetation removed and land disturbed 

by construction activities would disturb a SMALL portion (from less than 1 percent up to 

20 percent) of the total licensed area and surrounding plant communities. The clearing of 

herbaceous vegetation in an open grassland or shrub steppe community would have a shortterm, SMALL impact, given the rapid colonization by annual and perennial species in the 

disturbed areas and restoration of the vegetative cover. The clearing of wooded areas could 

have a long-term impact given the pace of natural succession, and such impacts could range 

from SMALL to MODERATE, depending on the acreage of the surrounding wooded area. 

Noxious weeds would be expected to be controlled with appropriate spraying techniques, and 

therefore, impacts would be SMALL (NRC, 2009a). 

The GEIS also noted that construction impacts to wildlife habitat would be minimized with the 

timely reseeding of disturbed areas following construction. In general, wildlife species would be 

expected to disperse from the proposed license area as construction activities approached, 

although smaller, less mobile species could perish during clearing and grading. Habitat 

fragmentation, temporary displacement, and direct or indirect mortalities would be possible; 

thus, the potential impact from construction could range from SMALL to MODERATE. The 

potential impact to sage-grouse and big-game species could be mitigated using measures such 

as those outlined in the U.S. Bureau of Land Management (BLM) and Wyoming Fish and Game 

Department guidelines. Impacts to raptor species from power distribution lines could be 

mitigated if the Avian Power Line Interaction Committee guidance was followed and disturbing 

areas near active nests and prior to the fledgling of young was avoided. 

In-stream channel activities would temporarily disturb aquatic species; therefore, the impacts 

would be SMALL. Sediment loads would taper off quickly in time and distance; therefore, longterm impacts would be SMALL. The use of the State of Wyoming Game and Fish Department 

(WGFD) standard management practices would help limit impacts to aquatic life. 

If threatened or endangered species were identified on the proposed project site during surveys, 

the impacts could range from SMALL to LARGE, depending on site conditions. Mitigation plans 

to avoid and reduce impacts to potentially affected species would be developed. 

4.6.1.1 Construction Impacts 

As noted previously, ecological resources could be affected by land disturbance during ISR 

facility construction. The construction phase of the proposed Moore Ranch Project could 

potentially impact ecological resources from clearing vegetation; constructing the central plant; 

developing the wellfields, including drilling wells; building header houses; constructing access 

roads; and clearing field laydown areas. The applicant projected construction at the proposed 

Moore Ranch Project would take 9 months to complete, and impacts are considered accordingly 

in the following section. 

4.6.1.1.1 Impacts to Vegetation 

The wellfields and central plant at the proposed Moore Ranch Project would be constructed 

within the upland grassland vegetation communities (see Figure 3-11). Direct impacts would 

include the short-term loss of vegetation (modification of structure, species composition, and 
Environmental Impacts and Mitigative Actions 

4-36 

areal extent of cover types). An estimated 61 ha [150 ac] of upland grassland would be affected 

by construction disturbance under current development plans. Indirect impacts would include 

the short-term and long-term increased potential for nonnative species invasion, 

establishment, and expansion; potential soil erosion; shifts in species composition or changes 

in vegetative density; reduction of wildlife habitat; reduction in livestock forage; and changes in 

visual aesthetics. 

The construction activities, increased soil disturbance, and increased traffic during construction 

could stimulate the introduction and spread of undesirable and invasive, nonnative species 

within the proposed license area. Two State-designated weeds, Canada thistle and field 

bindweed, were observed on the proposed Moore Ranch Project during the baseline surveys 

conducted by the applicant, along with other undesirable annual grass species such as cheat 

grass brome. The applicant would conduct weed control as needed to limit the spread of 

undesirable and invasive, nonnative species on disturbed areas (EMC, 2007a). 

To mitigate the potential impact to vegetation, disturbed areas could be both temporarily and 

permanently revegetated, in accordance with WDEQ-LQD regulations and the WDEQ mine 

permit. The applicant would seed disturbed areas to establish a vegetative cover to minimize 

wind and water erosion and the invasion of undesirable plant species (EMC, 2007b). 

The impact from vegetation removal and surface disturbance would affect approximately 61 ha 

(150 ac) of land, or about 2 percent of the total licensed area and less than 0.05 percent of the 

upland grassland area within the proposed license area; therefore, the impact would be SMALL. 

Some individual plants would be affected, but since construction activities would not affect 61 ha 

[150 ac] contiguous acres and the upland grasslands cover approximately 70 percent of the site, 

the impact would not affect a sizeable segment of the species population over a relatively 

large area. 

4.6.1.1.2 Impacts to Wildlife 

There are three primary impacts of ISR uranium recovery facility construction on terrestrial 

wildlife: (1) habitat loss or alteration and incremental habitat fragmentation; (2) displacement 

of wildlife from project construction; and (3) direct or indirect mortalities from 

project construction. 

ISR facility construction and operation can have direct and indirect impacts on local wildlife 

populations. These impacts are both short-term (lasting until successful reclamation is 

achieved) and long-term (persisting beyond successful completion of reclamation). However, 

substantial long-term impacts would not be expected because of the relatively limited habitat 

disturbance associated with use of the ISR extraction method. The likelihood of injury or 

mortality to wildlife would be greatest during the construction phase because of increased traffic 

levels and physical disturbance during that ISR phase. The applicant would impose and 

enforce speed limits during all construction and maintenance operations to reduce impacts to 

wildlife throughout the year and particularly during the breeding season (EMC, 2007a). 

The applicant estimated the area to be disturbed during the construction phase at 61 ha 

[150 ac] (noncontiguous). This area is comprised of two wellfields covering a combined area of 

23 ha [57 ac], the central plant and associated storage facilities that cover approximately 2.4 ha 

[6 ac], approximately 3.2 km [2 mi] of new access road to the central plant and within the 

proposed wellfields, and the infrastructure supporting the wellfields (e.g., header houses that 
Environmental Impacts and Mitigative Actions 

4-37 

consolidate pipelines from individual wells to a trunkline that connects to the central plant). 

Most of the habitat disturbance would consist of scattered, confined drill sites for wells in the 

wellfields that would not result in large expanses of habitat being dramatically transformed from 

its original character as in surface mining operations. 

Indirect impacts could occur from displacement of wildlife from increased noise, traffic, or other 

disturbances associated with the development of the proposed Moore Ranch Project and from 

small reductions in existing or potential cover and forage due to habitat alteration, 

fragmentation, or loss. Indirect impacts typically persist longer than direct impacts. However, 

ISR uranium extraction does not involve large-scale habitat alteration. 

Certain vegetative communities that exist in the proposed license area could be difficult to 

reestablish through artificial plantings, and natural seeding and recruitment could take many 

years. Consequently, wildlife species associated with specific habitats, such as blue grama 

grasslands, birdsfoot sagebrush, and big sagebrush, could be reduced in number or replaced by 

generalist species with broader habitat requirements until natural reseeding of certain 

vegetation occurs or reclamation matures to its target mix. However, as shown in Figure 3-11, 

most of the proposed applicant activities would occur in upland grass communities that cover 

70 percent of the proposed license area. Therefore, the impact from the construction phase of 

the proposed Moore Ranch Project would have a SMALL impact on wildlife because the 

affected area would be small and noncontiguous, and the primary plant community to be 

affected is widespread throughout the proposed license area. In addition, the applicant would 

use temporary fencing around all open mud pits to protect wildlife from this hazard. 

4.6.1.1.2.1 Impacts to Big Game 

Pronghorn antelope and mule deer are the only two big-game species that regularly occur in the 

proposed license area. No crucial, big-game habitat or migration corridors occur on or within 

several kilometers of the proposed Moore Ranch Project (WGFD, 2009). 

Direct impacts to pronghorn antelope and mule deer from project activities could include the 

disturbance of a portion of yearlong range, loss of forage, and vehicular collision accidents. An 

estimated 61 ha [150 ac] would be incrementally disturbed during the approximate 12-year life 

of the ISR facility. Because of these habitat disturbances, the yearlong range-carrying capacity 

for big game would be reduced over the life of the ISR facility and for several years thereafter, 

until the affected areas had revegetated and become productive enough to support big game. 

No significant increase in the potential for vehicle collision with big game would be expected 

because of the short distances traveled and the applicant enforcement of speed limits on the 

access roads. Direct impacts to pronghorn antelope and mule deer would be SMALL because 

only a few individual animals would be affected and the continued existence of the species 

would not be threatened. 

Indirect impacts to pronghorn antelope and mule deer could include displacement into 

surrounding areas because of increased human activity and the increased potential for 

poaching. Human presence during construction could affect pronghorn antelope and mule deer 

use of adjacent areas. Some short-term disturbance (during the lifecycle of the ISR facility) of 

big-game habitat could occur because of the proposed project construction. However, the 

construction phase of the proposed action has been estimated to last nine months. Adequate 

habitat for pronghorn antelope and mule deer exists in the surrounding area; these species 

could return to the areas affected by construction when these activities were completed 
Environmental Impacts and Mitigative Actions 

4-38 

(EMC, 2007b). The proposed staged reclamation of disturbed areas would provide grass and 

forage within a few years of habitat disturbance. The number of employees and the nature and 

intensity of the proposed activities would be comparable to those occurring from CBM 

production in the same vicinity. The movement of big game through the proposed license area 

would not be impacted by implementing the proposed action. The limited use of security 

fencing to impede ingress to and egress from the restricted area around the central plant and 

the use of fencing around wellfields to limit access to sheep would mitigate the potential impact 

from wildlife use of the area. Fencing that is preferred by the WGFD has been previously 

documented (WGFD, 2004). 

Furthermore, the applicant’s mitigative actions, such as enforcing speed limits, would further 

reduce big-game conflicts associated with the proposed Moore Ranch Project. Because 

pronghorn antelope and mule deer are highly mobile species, the potential impact to these 

species would be SMALL. 

4.6.1.1.2.2 Impacts to Other Mammals 

A variety of small- and medium-sized mammal species occur in the vicinity of the proposed 

license area, although not all have been observed on the proposed Moore Ranch Project itself. 

These mammals include coyotes, red foxes, swift foxes, bobcats, striped skunks, weasels, 

badgers, muskrats, raccoons, rodents (e.g., mice, rats, voles, gophers, ground squirrels, 

chipmunks) and rabbits. 

Medium-sized mammals (e.g., coyotes, foxes) could be temporarily displaced to other habitats 

during construction activities. Direct losses of limited mobility small-mammal species 

(e.g., voles, ground squirrels, mice) could be higher than for other wildlife because of the 

likelihood they would retreat into burrows if disturbed, and thus potentially be impacted by 

topsoil scraping or staging activities. However, given the limited, noncontiguous area that could 

be disturbed, approximately 61 ha [150 ac], no major changes or reductions in small- or 

medium-sized mammalian populations would be expected. The species that occur in the area 

have shown an ability to adapt to human disturbance in varying degrees, as evidenced by their 

occurrence in areas of CBM development (EMC, 2007b). Small-mammal species in the area 

also have a high reproductive potential and tend to reoccupy and adapt to altered or reclaimed 

areas quickly (EMC, 2007b). 

Since only a few individuals would be affected and most mammal species would likely travel to 

suitable habitat adjacent to the construction areas, the proposed Moore Ranch Project would 

have a SMALL impact on these mammals. 

4.6.1.1.2.3 Impacts to Avian Species 

Upland Game Birds. The only upland game bird prevalent in the vicinity of the proposed Moore 

Ranch Project is the mourning dove, which is a relatively common breeder in Campbell County, 

and is the most prevalent upland game bird in the area (EMC, 2007a). The proposed 

construction activities could affect approximately 61 noncontiguous ha [150 ac] of potential 

foraging and nesting habitat for mourning doves. While woody corridors are not abundant in the 

vicinity of the proposed project area, they also are not unique to the Moore Ranch Project 

proposed license area. Habitat that could support mourning doves occurs to the immediate 

south of the proposed license area where no ISR recovery has been proposed; therefore, the 

proposed Moore Ranch Project would not impact the occurrence of mourning doves. 
Environmental Impacts and Mitigative Actions 

4-39 

As discussed in Section 3.6.1.2.2, sage-grouse neither occur nor is the appropriate habitat 

present within the proposed license area to support their occurrence. Therefore, there would be 

no expected impacts to sage-grouse from the proposed action. 

Waterfowl and Shorebirds. Because surface water occurs only intermittently at the proposed 

Moore Ranch Project, little habitat exists to support large groups or populations of either 

waterfowl or shorebirds. Therefore, there would be no impact to these species. 

Raptors. Three species of raptors occur within the proposed license area: the ferruginous 

hawk, the red-tailed hawk, and the great horned owl. The populations of these three species 

are common and are believed to be stable in the local vicinity. Nesting success by resident 

raptors could be reduced from disturbances caused by milling operations and traffic. Two nest 

sites occur within close proximity of the wellfields, but no trees with nests would be removed. 

Other nest sites occur within the southern half of the proposed license area. Use of the nest 

sites may continue as birds habituate to milling activities, and the potential impact to the raptor 

population could range from SMALL to MODERATE. If the applicant adhered to the WGFD and 

BLM seasonal noise, vehicular traffic, and human proximity guidelines (WGFD, 2010; BLM, 

2008a and 2010), these mitigation measures could support the continued nesting success of 

area raptors, and the impact would be SMALL. 

The applicant would conduct a raptor nest survey in late April or early May each year the 

proposed Moore Ranch Project operated to identify new raptor nests and to assess whether 

existing nests were being used (Uranium One, 2009b). The purpose of this program would be 

to protect against unforeseen conditions, such as the construction of a nest in an area that could 

be potentially affected by the operation of the proposed Moore Ranch Project (EMC, 2007b). If 

nests were discovered during these surveys, the applicant would take appropriate mitigation 

measures, such as moving the nest, to ensure the protection of the species.

4.6.1.1.2.4 Impacts to Reptiles and Amphibians 

The only herpetological species recorded within the proposed Moore Ranch Project during the 

applicant’s 2006 and 2007 baseline studies was the common bullsnake. Because the potential 

habitat for reptiles and amphibians is limited within the proposed license area, no impact to 

reptiles or amphibian populations would be expected. 

4.6.1.1.3 Impacts to Aquatic Resources 

Because of the limited occurrence of surface water, the potential habitat for aquatic species is 

also limited within the proposed license area. Aquatic species habitat occurs primarily as 

intermittent habitat in the small, scattered stock ponds or drainages in the area. Portions of 

Pine Tree Draw, Simmons Draw, Ninemile Creek, and their intermittent tributaries, occur within 

the proposed license area, but they are not reliable water sources as discussed in 

Section 3.5.1.2. No aquatic habitat exists on the proposed Moore Ranch Project to support fish 

or macroinvertebrates; therefore, there would be no impact to aquatic wildlife. 

4.6.1.1.4 Impacts to Threatened and Endangered Species 

No federal- or state-listed sensitive plant species, endangered or threatened plant species, or 

designated critical habitats occur within the proposed license area; therefore, there would be no 

expected impact to these species. 
Environmental Impacts and Mitigative Actions 

4-40 

The bald eagle (formerly listed as threatened, currently delisted) and black-footed ferret 

(endangered) are the federally-listed, previously-listed, or candidate wildlife species that could 

occur in the proposed license area (FWS, 2008). However, the potential habitat for bald eagle 

nesting and roosting activities is limited within the proposed license area and a surrounding 1.6-

km [1-mi] perimeter. The nearest documented winter roosting area is approximately 13.7 km 

[8.5 mi] to the north (BLM, 2008b). Project lands disturbed by uranium ISR activities would be 

unavailable for foraging bald eagles until these areas were reclaimed and prey species 

returned. On September 11, 2009, the U.S. Fish and Wildlife Service (FWS) published a rule 

concerning eagle take permits (74 FR 46836). The NRC contacted the FWS on March 15, 

2010, to discuss whether the proposed Moore Ranch Project would require an eagle permit per 

this rulemaking. The FWS concluded that the NRC would neither need to further consult with 

FWS nor obtain an eagle take permit for the proposed Moore Ranch Project because no trees 

with nests would be disturbed (NRC, 2010). 

The black-footed ferret occurs in active prairie dog colonies, none of which occur either on or 

within a 1.6 km [1 mi] radius of the proposed Moore Ranch Project boundary. Therefore, there 

would be no expected impacts to either the bald eagle or black-footed ferret from construction 

activities at the proposed Moore Ranch Project. 

4.6.1.1.4.1 Impacts to Species of Concern 

The proposed Moore Ranch Project has the potential to impact 14 avian species of concern 

(8 Level I species and 6 Level II species) known to occur or potentially be present as seasonal 

or year-round residents. Direct impacts such as injury or mortality could occur from vehicle or 

heavy equipment encounters during construction. Indirect impacts could result from habitat loss 

or fragmentation and increased noise and activity that could deter use of the area by some 

species. Surface disturbance would be limited to a total of approximately 61 noncontiguous ha 

[150 ac] out of 2,879 ha [7,100 ac] and would be greatest during construction. The applicant’s 

enforcement of speed limits during all phases of the proposed Moore Ranch Project would 

reduce wildlife impacts throughout the year, particularly during the breeding season. Impacts to 

avian species of concern could potentially be MODERATE. Since construction would occur for 

only nine months, the potential impact could be reduced to SMALL if the applicant adhered to 

the mitigation measures outlined in the WGFD and BLM guidelines for seasonal noise vehicular 

traffic and human proximity (WGFD, 2010; BLM, 2008a and 2010). Furthermore, the proposed 

activities would not threaten the continued existence of these species in the proposed 

license area. 

4.6.1.2 Operations Impacts 

Section 4.3.5.2 of the GEIS discussed the alteration of wildlife habitats from operations 

(fencing, traffic, noise), and noted that individual takes could occur due to conflicts between 

species habitat and operations. Access to crucial wintering habitat and water could be limited 

by fencing. The WGFD specifies fencing construction techniques to minimize impediments to 

big-game movement. 

The GEIS further noted the occurrence of temporary contamination or alteration of soils from 

operational leaks and spills. However, detection and response to leaks and spills (e.g., soil 

cleanup) and eventual survey and decommissioning of all potentially impacted soil would limit 

the magnitude of overall impacts to terrestrial ecology. Spill detection and response plans 

would reduce the potential impact to aquatic species from spills around wellheads and leaks 
Environmental Impacts and Mitigative Actions 

4-41 

from pipelines. Mitigation measures such as perimeter fencing, netting, leak detection and spill 

response plans, and periodic wildlife surveys would also limit the impact; therefore, the overall 

impact would be SMALL. 

4.6.1.2.1 Impacts to Vegetation 

During the operations phase of the proposed Moore Ranch Project, the wellfields and central 

plant would be frequently accessed using the defined road network. The installation and 

operation of the wellfields would involve the excavation of trenches for trunk lines and utilities. 

Surface disturbance would increase the susceptibility of the disturbed area to invasive and 

noxious weeds. However, surface disturbance would be minimized and vehicular access would 

be restricted to specific roads. Disturbed areas would be reseeded with WDEQ-approved seed 

mixtures to prevent the establishment of competitive weeds. The applicant would monitor 

invasive and noxious weeds; if they became an issue, other control alternatives, such as the 

application of an herbicide, would be considered (EMC, 2007b). 

Impacts to vegetation resulting from spills around wellheads and leaks from pipelines during 

facility operations would be SMALL, and the applicant’s use of BMPs to handle them (EMC, 

2007b), such as leak detection systems and spill response plans to remove affected soils and 

capture released fluids would reduce the impact. 

4.6.1.2.2 Impacts to Wildlife 

Wildlife use of areas adjacent to ISR operations would likely initially decline because of human 

disturbances during milling operations and steadily increase to near-normal levels as animals 

became habituated to the activity. Some wildlife habituation to human activities may have 

occurred in the area because of ongoing CBM activities. Because wildlife may be in close 

proximity to the central plant, roads, and wellfields, some impacts to wildlife would be expected 

from direct conflict with vehicular traffic and the presence of onsite personnel. These impacts 

would be SMALL because only a few individual animals would be affected and the continued 

existence of any particular species in the proposed license area would not be affected. During 

facility operations, spills around wellheads and leaks from pipelines could expose wildlife to 

potentially toxic levels of chemicals. Leak detection systems and spill response plans to remove 

affected soils and to capture released fluids would minimize the impact. The applicant’s use of 

BMP to handle spills or leaks would result in SMALL impact to wildlife. Further mitigation such 

as the applicant’s use of fencing described in Section 4.6.1.1.2 of this SEIS could be used to 

maintain a SMALL impact on wildlife. 

4.6.1.2.2.1 Impacts to Big Game 

The potential impact to big game during the operations phase would either be similar to or less 

than that described for the construction phase because limited earth-moving activities would 

occur. Therefore, there could be SMALL impacts to big-game species during the 

operations phase. 

4.6.1.2.2.2 Impacts to Other Mammals 

The potential impact to other mammals during operations would be similar to or less than that 

described for the ISR construction phase. Because only a few individuals would be affected 
Environmental Impacts and Mitigative Actions 

4-42 

and most mammal species would likely travel to suitable habitat adjacent to the operating areas, 

the proposed Moore Ranch Project would have a SMALL impact on these mammals. 

4.6.1.2.2.3 Impacts to Avian Species 

The potential impact to upland game birds, waterfowl and shorebirds, and to raptors would 

either be the same or less than that described for the construction phase because earth-moving 

activities would be more limited during the operations phase; therefore, the potential impact 

would be SMALL. 

4.6.1.2.2.4 Impacts to Reptiles and Amphibians 

The potential impact to reptiles and amphibians from the operations phase would be 

comparable to that described for the construction phase. Because the potential habitat for 

reptiles and amphibians is limited within the proposed license area, the potential impact would 

be limited and SMALL. 

4.6.1.2.3 Impacts to Aquatic Resources 

Because of the limited occurrence of surface water on the proposed Moore Ranch Project and 

because the operating plans do not require surface water discharge, the potential impact to 

aquatic resources would be SMALL. 

4.6.1.2.4 Impacts to Threatened and Endangered Species 

No impacts to federally-listed threatened and endangered species would occur during the 

operations phase because these species have not been identified within the proposed 

license area. 

Continued mitigation would be implemented to ensure potential impacts to threatened and 

endangered species remain SMALL. Examples of mitigation that would benefit threatened and 

endangered species are applicant spill procedures, fencing around the central plant and 

wellfields, and activity timing restrictions (EMC, 2007b). 

4.6.1.2.4.1 Impacts to Species of Concern 

As described in Section 4.6.1.1.4.1, the operation of the proposed Moore Ranch Project has the 

potential to impact 14 avian species of concern (8 Level I species and 6 Level II species) known 

to either occur or potentially occur as seasonal or year-round residents. Impacts to species of 

concern during facility operation would either be similar to or less than, those impacts described 

during construction because the facilities and infrastructure would remain in place for the life of 

the milling operation. If the applicant continued to follow the BMP described for the ISR 

construction phase in Section 4.6.1.1, the potential impact to species of concern during the 

operations phase would be SMALL. Only a few individual species would be affected during 

operations and the continued existence of any particular species would not be threatened. 

Therefore, the potential impact to avian species of concern would be SMALL. 
Environmental Impacts and Mitigative Actions 

4-43 

4.6.1.3 Aquifer Restoration Impacts 

Section 4.3.5.3 of the GEIS discussed the potential impacts to ecological resources during the 

aquifer restoration phase. These impacts could include habitat disruption, but because existing 

(in-place) infrastructure would be used, little additional ground disturbance would be expected. 

The GEIS also discussed contamination of soils and surface waters that could result from leaks 

and spills. However, detection and response techniques, and eventual survey and 

decommissioning of all potentially impacted soils and sediments, would limit the magnitude of 

overall impacts to terrestrial and aquatic ecology. Implementation of mitigation measures such 

as perimeter fencing, netting, and leak detection and spill response plans would maintain 

SMALL impacts. 

There would be no expected impacts to threatened and endangered species beyond that which 

occurred during the construction phase because the existing infrastructure from the operations 

phase would continue to be used. Therefore, the overall impact to threatened and endangered 

species would be SMALL. 

Because the existing infrastructure would be in place, the potential impact to ecological 

resources from aquifer restoration activities would be similar to that experienced during the 

operations phase; therefore, the potential impact to vegetation and wildlife would be SMALL. If 

the applicant adhered to the WGFD and BLM seasonal noise, vehicular traffic, and human 

proximity guidelines (WGFD, 2010; BLM, 2008a and 2010), these mitigation measures would 

further reduce the potential impact from noise, vehicular traffic, and human proximity. 

4.6.1.4 Decommissioning Impacts 

Section 4.3.5.4 of the GEIS discussed temporary land disturbance during decommissioning and 

reclamation from soil excavation, recovery and removal of buried piping, and the demolition and 

removal of structures. However, revegetation and recontouring would restore habitat previously 

altered during construction and operations. Wildlife would be temporarily displaced, but could 

return upon completion of decommissioning and reclamation and the reestablishment of 

vegetation and habitat. Decommissioning and reclamation activities could result in temporary 

increases in sediment load in local streams, but aquatic species would recover quickly as 

sediment load decreased. For these reasons, the GEIS concluded the overall potential impact 

during decommissioning would be SMALL. 

As stated in the GEIS, with respect to threatened and endangered species, potential impacts 

resulting from individual takes would occur due to conflicts with decommissioning activities 

(e.g., equipment, traffic). Temporary land disturbance would occur as structures are 

demolished and removed and the ground surface recontoured. An inventory of threatened or 

endangered species developed during the site-specific environmental review of the detailed 

decommissioning plan would identify unique or special habitats, and consultation with the FWS 

under the Endangered Species Act would help to minimize impacts. Upon completion of 

decommissioning, revegetation, and recontouring, the habitat would be reestablished; therefore, 

the potential impact to threatened and endangered species could range from SMALL to LARGE, 

depending on site conditions. 

Impacts to ecological resources during decommissioning of the proposed Moore Ranch Project 

would be similar to those experienced during the construction phase with respect to noise, traffic 
Environmental Impacts and Mitigative Actions 

4-44 

flow, and earth-moving activities. However, the decommissioning phase would not disrupt as 

much natural habitat as would have occurred during the construction phase of the ISR process 

since activities would be conducted in the previously disturbed areas of the site. The applicant 

estimated a 12-month duration for the ISR decommissioning phase, which would be reduced 

with time as decommissioning and reclamation progressed. 

Decommissioning would involve abandonment of the central plant, office and maintenance 

buildings, and wellfields and removal of surface equipment consisting of the injection and 

production feed lines and buried wellfield piping. Stockpiled topsoil would be used to regrade 

the land to preconstruction contours, as required, and seeded with native vegetation when the 

buildings are removed. No loss of vegetative communities beyond that disturbed during 

construction would occur. Piping removal would impact vegetation that has reestablished itself, 

although this, too, would be temporary when the disturbed soil is reseeded. The 

decommissioning process would create increased noise and traffic as buildings are taken down 

and hauled away. During this time, wildlife could either come in conflict with heavy equipment 

or could move elsewhere on the property due to higher-than-normal noise. As required, the 

applicant would submit a decommissioning plan for NRC review and approval. Temporarily 

displaced wildlife could return to the area when decommissioning and reclamation 

were completed. 

Decommissioning impacts would be temporary and SMALL. The applicant’s implementation of 

the previously discussed mitigation measures would further reduce the potential impact. 

4.6.2 No-Action (Alternative 2) 

Under the No-Action alternative, there would be no ISR facility construction associated with this 

project, and therefore no land disturbance or vegetation removal associated with construction, 

operation, aquifer restoration, or decommissioning. The area would continue to support 

vegetation communities and wildlife habitat typical of the region. Land would continue to be 

used for pastureland, and grazing leases would continue. Grazing of existing vegetation, 

particularly in the grassland communities, would continue. Existing wildlife within the proposed 

license area could be affected if continued cattle grazing destroyed wildlife habitat or if species 

are displaced by cattle populations due to lack of forage and cover. However, only a few 

individual species would be affected, and they could relocate to suitable adjacent habitats. 

There would be no impacts to ecological resources under this alternative compared to the 

proposed action. 

4.7 Air Quality Impacts 

Potential environmental impacts to air quality at the proposed Moore Ranch Project could occur 

during all phases of the ISR facility lifecycle. Nonradiological air emission impacts primarily 

involve fugitive road dust from vehicles used throughout the facility lifecycle and combustion 

engine emissions from diesel equipment associated with construction, operation, and 

decommissioning activities. Other air emissions may be associated with radon releases from 

well system relief valves, resin transfer, or elution. Potential radiological air impacts, including 

radon release impacts, are addressed in the Public and Occupational Health and Safety 

Impacts analyses in Section 4.13. 

Factors used by the NRC staff in determining the significance of the potential impacts are 

described in Section 1.7.2 of the GEIS and include (1) whether the air quality for the site region 
Environmental Impacts and Mitigative Actions 

4-45 

of influence is in compliance with the National Ambient Air Quality Standards (NAAQS) and 

(2) whether the facility can be classified as a major source under the New Source Review or 

operating (Title V of the Clean Air Act) permit programs. An additional concern would be the 

presence of Prevention of Significant Deterioration (PSD) Class I areas within the region that 

could be impacted by emissions from the proposed action. All three of these criteria would be 

met for the proposed Moore Ranch ISR Project, as discussed in the following paragraphs. 

Air emissions from the proposed Moore Ranch Project would be expected to comply with the 

conditions of a WDEQ-approved construction air permit (application under review at the time of 

writing, as shown in Table 1-2) and a WDEQ minor source operating permit, if required. In 

addition, all of the nonradiological emissions estimates evaluated by the NRC staff 

(Section 2.1.1.1.6.1) support the conclusion that the proposed action would not be comparable 

to, nor considered, a major source of emissions and that such emissions (i.e., well below the 

major source thresholds) in an area with meteorology that is often favorable for dispersion 

(Section 3.7.1.2) would be unlikely to impact attainment of ambient air quality standards in the 

region surrounding the location. The NRC staff expects that emissions at levels well below the 

major source thresholds would not destabilize local air quality, although localized, short-term 

and intermittent visible air emissions would be possible in the surrounding area (i.e., when 

vehicles travel on unpaved roads). 

As described in Section 3.7.2, the air quality of the region where the proposed Moore Ranch 

Project is located is classified as being in attainment for all of the NAAQS primary pollutants. 

The nearest PSD Class 1 area, Wind Cave National Park, located about 188 km [117 mi] east of 

the Moore Ranch site and Cloud Peak Wilderness Area, the closest Class II area located about 

124 km [77 mi] northwest of the Moore Ranch site, are both classified as attainment areas. The 

attainment status of the air quality surrounding the proposed license area provides a measure of 

current air quality conditions and affects considerations for allowing new emission sources. 

Based on construction air quality permits obtained for similar projects (WDEQ, 2009; 2010), the 

NRC staff expects that WDEQ would not consider the proposed facility to be a major source for 

emissions. In addition, the NRC staff estimated mobile nonroad emissions from construction 

equipment (Section 2.1.1.1.6.1) that are not addressed by WDEQ air permitting and found these 

emissions were also well below major source threshold levels. The low magnitude of emissions 

directly affects the potential for air quality impacts and, therefore, the level of detailed review 

NRC considered necessary to adequately evaluate potential impacts. 

All phases of the proposed Moore Ranch Project would also result in greenhouse gas 

emissions, principally carbon dioxide (CO2), however, the majority of these emissions would be 

from the use of diesel-powered equipment (including well drilling rigs) during the construction 

and decommissioning phases (Section 2.1.1.1.6.1 and Appendix D). Based on methods 

described in detail in Appendix D, the NRC staff calculated a maximum annual CO2 emission 

from this diesel-powered equipment of 852 t/yr [940 T/yr] and cumulative CO2 emissions (total 

facility lifecycle emissions) for the proposed facility lifecycle as 2400 t/yr [2600 T/yr]. For 

comparison, these calculated emissions from the proposed action are a small fraction of the net 

total of greenhouse gases produced annually in Wyoming at 20,000,000 t [22,000,000 T] 

(Center for Climate Strategies, 2007) and for the United States at 6,000,000,000 t 

[6,600,000,000 T] (EPA, 2009). Based on its assessment of the relatively small carbon footprint 

of the proposed facility as compared to the annual CO2 emissions in both the State of Wyoming 

and the United States, the NRC staff concluded that the atmospheric impacts of greenhouse 

gases from the proposed facility lifecycle would not be noticeable, and additional mitigation 

would not be warranted. 
Environmental Impacts and Mitigative Actions 

4-46 

In general, nonradiological emissions from pipeline system venting, resin transfer, and elution 

would be rapidly dispersed into the atmosphere and would be small, primarily due to the low 

volume of effluent produced. Such emissions were not considered in the following analysis. 

Detailed discussion of the potential environmental impacts to air quality from construction, 

operation, aquifer restoration, and decommissioning the proposed Moore Ranch Project are 

provided in the following sections. 

4.7.1 Proposed Action (Alternative 1) 

4.7.1.1 Construction Impacts 

As discussed in the GEIS (Section 4.3.6.1), fugitive dust and combustion (vehicle and diesel 

equipment) emissions during land-disturbing activities associated with construction would be 

short term and reduced through BMPs (e.g., wetting of roads and cleared land areas to reduce 

dust emissions). The GEIS also estimated fugitive dust emissions during ISR construction 

would be well below the NAAQS for Particulate Matter2.5 (PM2.5) and for Particulate Matter10

(PM10). Additionally, the GEIS concluded particulate, sulfur dioxide, and nitrogen dioxide 

emissions from ISR facilities would be at a small percentage (1 to 9 percent) of the PSD Class II 

allowable increments. For NAAQS attainment areas, like the area around the proposed Moore 

Ranch Project, nonradiological air quality impacts would be SMALL. 

The proposed Moore Ranch Project would meet the conditions pertaining to air quality specified 

in the GEIS as discussed in Section 4.7, and therefore, impacts would be SMALL. This 

conclusion is further supported by the limited footprint of the construction area relative to the 

proposed project area, the low volume of traffic generated by the proposed action 

(Section 4.3.1.1), and the short length {0.8 km [0.5 mi]} of the facility access road to connect to 

SR 387 (Section 3.3). The applicant proposes to apply water or other agents to control fugitive 

dust emissions (Uranium One, 2009b). Despite the use of controls, short-term and intermittent 

visible air emissions are possible to the local area surrounding the proposed project site when 

vehicles travel on unpaved roads. Therefore, short-term and intermittent MODERATE impacts 

from fugitive road dust are possible, however, the average air quality is expected to remain in 

compliance with ambient standards and overall impacts would be SMALL. 

Emissions from diesel combustion engines in drilling rigs and construction equipment used 

during the construction phase were calculated by the NRC staff and are discussed in 

Section 2.1.1.1.6.1 and Appendix D. These calculations addressed emissions of Nitrogen 

Oxides (NOx), Carbon Monoxide (CO), Sulfur Oxides (SOx), Particulate Matter (PM10), 

Formaldehyde, Volatile Organic Compounds (VOC), and Carbon Dioxide (CO2). The results 

show Nitrogen Oxides and Carbon Monoxide are the highest emissions of the criteria pollutants 

evaluated. Estimated emissions of these pollutants are well below major source threshold 

levels. The calculated annual pollutant emissions for NOx is 18.1 t/yr [20 T/yr] assuming two of 

the four proposed deep disposal wells were drilled in the same year as the first wellfield. If the 

NRC staff assumed all four deep disposal wells were drilled in the same year as the first 

wellfield, the annual NOx emission result increases to 30 t/yr [33 T/yr]. This higher level of 

calculated emissions is still below the 91 t/yr [100 T/yr] major source threshold and is 

considered by the NRC staff to represent a single-year peak while all proposed deep wells 

would be completed. 

The diesel combustion engine emissions calculated by the NRC staff for the proposed action 

are below those reported in the GEIS from a prior NRC Environmental Impact Statement (EIS) 
Environmental Impacts and Mitigative Actions 

4-47 

(NRC, 1997) for a proposed ISR facility in Crownpoint, New Mexico; and therefore, the potential 

impacts to air quality from the proposed action would be less than those reported in the GEIS. 

The NRC staff considers the emissions and associated potential air impacts from constructing 

the Crownpoint facility to bound the emissions from constructing the proposed Moore Ranch 

Project based on the following considerations. First, the Crownpoint facility proposed a higher 

maximum annual production rate than the proposed Moore Ranch Project. The ore deposits at 

the Crownpoint facility are at a much greater depth and, therefore, would require longer drilling 

times per well during wellfield construction. For example, the Crownpoint ISR facility has ore 

occurring at an approximate depth of 561 m [1,840 ft] below ground surface, whereas the 

proposed Moore Ranch Project has ore occurring at depths that range from 76.2 to 91.5 m 

[250 to 300 ft] below the ground surface (EMC, 2007b). 

Second, the meteorology used at the Crownpoint site to estimate average annual air 

concentrations of emitted pollutants is also more stable than at the proposed Moore Ranch 

Project, based on the NRC staff review of available joint frequency data for each site 

(NRC, 1997; EMC, 2007b), which indicated winds that fall within stability classes E and F occur 

about two times as frequently at the Crownpoint site than in the region surrounding the 

proposed Moore Ranch Project. The annual average air concentrations for the Crownpoint 

emissions are also based on a mixing height of 1 km [1.6 mi] (NRC, 1997), which is within the 

range of mixing heights reported for the State of Wyoming of 659 m [718 yd] (morning average) 

and 4,074 m [4,440 yd] (afternoon average) (EPA, 2010). Based on the information reviewed, 

the NRC staff expects the dispersion conditions at the Crownpoint site would be less favorable 

than at the proposed Moore Ranch Project and; therefore, based on the combination of 

dispersion conditions and higher emissions estimates for the Crownpoint facility, the NRC staff 

concluded the calculated annual average air concentration emission values reported in the 

GEIS are conservative and, therefore, applicable to the proposed Moore Ranch Project. As a 

result, the GEIS conclusions that particulate, sulfur dioxide (SO2), and nitrogen dioxide (NO2) 

emissions from ISR facilities would be expected to be well below the major source threshold for 

NAAQS attainment areas and account for a small percentage (1 to 9 percent) of the PSD Class 

II allowable increments would also be applicable to the proposed Moore Ranch Project. 

The NRC staff considered the calculated magnitude of construction emissions, in an area that 

meets current air quality standards, is not sufficient to justify conducting additional detailed 

quantitative air quality modeling analysis of potential consequences. Considering (i) the 

aforementioned analyses in the GEIS, (ii) that other recently proposed ISR facilities have 

received WDEQ construction air quality permits that subject the facility to minor source 

operational permitting (WDEQ, 2009; 2010), and (iii) the conditions of the site area and region, 

the NRC staff concludes that such emissions (i.e., well below the major source thresholds) in an 

area with meteorology that is often favorable for dispersion would be unlikely to impact air 

quality locally, regionally, or in the nearest Class I or II areas. The nearest Class I area, Wind 

Cave National Park, is located approximately 188 km [117 miles] east of the Moore Ranch site. 

While the prevailing wind directions of west-southwest and west (Section 3.7.1.2) could 

transport pollutants in the direction of the Class I area, because of the long distance, the 

potential emissions would disperse. The Cloud Peak Wilderness Area is the closest Class II 

area to the proposed action, located about 124 km [77 mi] northwest of the proposed Moore 

Ranch Project. In addition to the low magnitude of emissions and distance, the prevailing wind 

direction would carry emissions to the northeast and east, away from the direction of this Class 

II area. 
Environmental Impacts and Mitigative Actions 

4-48 

The NRC staff concludes that the site-specific conditions at the proposed Moore Ranch Project 

are comparable to those described in the GEIS for air quality and incorporates by reference the 

GEIS conclusions that the impacts to air quality during construction would be SMALL. The NRC 

staff has not identified any new and significant information during its independent review that 

would change the expected environmental impact beyond those discussed in the GEIS. 

4.7.1.2 Operation Impacts 

The GEIS (Section 4.3.6.2) noted that operating ISR facilities are not major point source 

emitters and are not expected to be classified as major sources under the operation (Title V) 

permitting program. Additionally, the GEIS concluded that although excess vapor pressure in 

pipelines could be vented throughout the system, such emissions would be rapidly dispersed in 

the atmosphere; therefore, potential impacts would be SMALL, due in part to the expected low 

volume of gaseous effluent produced. The GEIS also stated that other potential nonradiological 

emissions during operations include fugitive dust and combustion engine emissions from 

equipment, transport trucks, and other vehicles. For NAAQS attainment areas, the GEIS 

concluded that nonradiological air quality impacts would be SMALL. 

Since the number of commuting vehicles and equipment operating at the proposed Moore 

Ranch Project would not exceed that evaluated in the GEIS, the potential impact would be 

SMALL. The applicant’s proposed mitigative measures described in Section 4.7.1.1 would 

further reduce the potential impact. 

The NRC staff concludes that the site-specific conditions at the proposed Moore Ranch Project 

are comparable to those described in the GEIS for air quality and incorporates by reference the 

GEIS conclusions that the impacts to air quality during operations would be SMALL. The NRC 

staff has not identified any new and significant information during its independent review that 

would change the expected environmental impact beyond that described in the GEIS. 

4.7.1.3 Aquifer Restoration Impacts 

As discussed in the GEIS (Section 4.3.6.3), because the same infrastructure is used during 

aquifer restoration as during operations, air quality impacts from aquifer restoration would be 

similar to, or less than, those during operations (NRC, 2009a). Additionally, fugitive dust and 

combustion engine emissions from vehicles and equipment during aquifer restoration would be 

similar to, or less than, the dust and combustion engine emissions during operations. For 

NAAQS attainment areas, nonradiological air quality impacts would be SMALL. 

Vehicular traffic during the aquifer restoration phase would be limited to delivery of supplies and 

commuting staff, with a decreasing frequency of offsite yellowcake shipments as restoration 

proceeds. Therefore, fewer trips would occur than during the operation phase. 

Air quality at the proposed Moore Ranch Project would not be substantially affected by the 

aquifer restoration activities because fewer vehicles would be required during this phase of the 

project; therefore, the potential impact would be SMALL. The applicant’s proposed mitigative 

measures described in Section 4.7.1.1 would further reduce the potential impact. 

The NRC staff concludes that the site-specific conditions at the proposed Moore Ranch Project 

are comparable to those described in the GEIS for air quality and incorporates by reference the 

GEIS conclusions that the impacts to air quality during aquifer restoration would be SMALL. 
Environmental Impacts and Mitigative Actions 

4-49 

The NRC staff has not identified any new and significant information during its independent 

review that would change the expected environmental impact beyond that discussed in 

the GEIS. 

4.7.1.4 Decommissioning Impacts 

Section 4.3.6.4 of the GEIS noted that fugitive dust, vehicle emissions, and diesel emissions 

during land-disturbing activities associated with decommissioning would come from many of the 

same sources as used during construction. In the short term, emission levels would be 

expected to increase given the activity (demolishing of process and administrative buildings, 

excavating and removing contaminated soils, grading of disturbed areas). However, such 

emissions would decrease as decommissioning proceeds, and therefore, overall impacts would 

be similar to, or less than, those associated with construction, would be short term, and would 

be reduced through BMP (e.g., dust suppression). Based on the NRC staff calculated emission 

estimates discussed in Section 2.1.1.1.6.1 and Appendix D, the emissions from diesel-powered 

construction equipment during the decommissioning phase would be less than the diesel 

emissions during the construction phase. As discussed in Section 4.7.1.1, considering the 

minor source classification of emissions indicated by the WDEQ for other recently proposed ISR 

facilities (WDEQ, 2009, 2010), and the conditions of the site area and region, the NRC staff 

conclude that such emissions (i.e., well below the major source thresholds) in an area with 

meteorology that is often favorable for dispersion would be unlikely to impact air quality locally, 

regionally, or in the nearest Class I or II areas to the proposed action. Therefore, for NAAQS 

attainment areas, nonradiological air quality impacts would be SMALL. 

The NRC staff concludes that the site-specific conditions at the proposed Moore Ranch Project 

are comparable to those described in the GEIS for air quality and incorporates by reference the 

GEIS conclusions that the impacts to air quality during decommissioning would be SMALL. The 

NRC staff has not identified any new and significant information during its independent review 

that would change the expected environmental impact beyond that disclosed in the GEIS. 

4.7.2 No-Action (Alternative 2) 

Under the No-Action alternative, in the next few years, there would be no change in air quality at 

the proposed Moore Ranch Project or at any surrounding receptors. While oil and gas extraction 

activities would continue and perhaps expand in the future (along with CBM operations), these 

activities have been shown to have a small impact – direct, indirect, or cumulative – on air 

quality, regardless of geographic scale (BLM, 2003). The generation of fugitive dust is currently 

limited by the fact that existing roads are shared and maintained by the natural resource 

extraction and ranching operations that occur in the area. Roads are also maintained in good 

repair by these entities and restricted from unpermitted uses. 

This area currently meets the NAAQS for attainment status (Section 3.7.2), and because there 

are no significant air pollution sources at the proposed site, it is expected that this area would 

continue to meet the NAAQS. Current projections of air quality for the broader Powder River 

Basin area and the surrounding region over the next decade are discussed in Section 5.7 of 

this SEIS. 
Environmental Impacts and Mitigative Actions 

4-50 

4.8 Noise Impacts 

Potential environmental impacts from noise at the Moore Ranch site could occur during all 

phases of the ISR facility lifecycle. These impacts would be associated with the operation of 

equipment such as trucks, bulldozers, and compressors; from traffic due to commuting workers 

or material and waste shipments; and wellfield and central processing plant activities and 

equipment. These impacts could affect both humans and wildlife in the vicinity of the site. 

As stated in the GEIS, the Occupational Safety and Health Administration (OSHA) has set 

permissible exposure limits for workplace noise levels (NRC, 2009a). The proposed Moore 

Ranch Project would be required to limit worker exposure in accordance with these regulations; 

therefore, occupational noise exposure is not discussed in this section but rather in 

Section 4.13. Instead, this section discusses the potential dispersion of noise impacts to off-site 

receptors described in Section 3.8 (NRC, 2009a). 

The noise analysis evaluated both mobile and stationary noise sources to assess the potential 

to impact sound levels adjacent to the proposed Moore Ranch Project and to determine the sitespecific impact. The GEIS concluded that the noise impact at an ISR facility could range from 

SMALL to MODERATE during all four phases of an ISR project, depending on the distance 

between the nearest resident and the activities occurring at the ISR facility (NRC, 2009a). 

Detailed discussion of the potential environmental impacts from noise due to construction, 

operation, aquifer restoration, and decommissioning are provided in the following sections. 

4.8.1 Proposed Action (Alternative 1) 

4.8.1.1 Construction Impacts 

As discussed in Section 4.3.7.1 of the GEIS, potential noise impacts would be greatest during 

construction of an ISR facility, because of the heavy equipment involved and given the 

likelihood that these facilities would be built in rural, previously undeveloped areas where 

background noise levels are lower. The use of drill rigs, heavy trucks, bulldozers, and other 

equipment used to construct and operate the wellfields, drill wells, construct access roads, and 

build the production facilities would generate noise that would be audible above the undisturbed 

background levels. Noise levels would likely be higher during daylight hours when construction 

is more likely to occur and more noticeable in proximity to the operating equipment. 

Administrative and engineering controls would maintain noise levels in work areas below OSHA 

regulatory limits and mitigated by use of personal hearing protection. For individuals living in 

the vicinity of the site, ambient noise levels would return to background levels at a distance 

greater than 300 m [1,000 ft] from the construction activities. Wildlife would be expected to 

avoid areas where noise-generating activities were occurring; although for certain wildlife 

(e.g., sage-grouse) continuous elevated noise levels could reduce their breeding success. 

Overall, these types of noise impacts would be SMALL, given the distance to the 

nearest resident. 

Additionally, as stated in the GEIS, traffic noise during construction (e.g., commuting workers; 

truck shipments to and from the facility; and construction equipment such as trucks, bulldozers, 

and compressors) would be localized, and limited to highways in the vicinity of the site, access 

roads within the site, and roads in the wellfields. Relative short-term increases in noise levels 

associated with passing traffic would be SMALL for the larger roads, but could be MODERATE 

for lightly traveled rural roads through smaller communities. 
Environmental Impacts and Mitigative Actions 

4-51 

As noted in Section 3.8 of this SEIS, the construction phase of the proposed Moore Ranch ISR 

Project would involve the use of heavy equipment to create and improve road surfaces, furnish 

supplies, excavate footings, erect buildings, and install the wells and pipelines at the wellfields. 

Equipment such as bulldozers, graders, tractor trailers, excavators, cranes, and drill rigs would 

create noise that would be audible onsite above background noise levels estimated as 40 

decibels. However, since the nearest residence is about 4.5 km (2.8 mi) from the center of the 

proposed Moore Ranch Project (Uranium One, 2009a), they would not notice a change in 

background noise. The applicant would enforce site speed limits to further mitigate traffic noise 

impacts (EMC, 2007a). 

Truck transport of construction materials would be the primary noise source that could 

potentially affect the public. However, because of the limited traffic volume associated with the 

proposed project, as discussed in Section 4.3 of the SEIS, this impact would be minor. The 

incremental increase in project-related traffic on the relatively well-traveled public roadways in 

the area (e.g., I-25, SR 387, SR 50, and SR 59) would not be noticeable. Thus, project-related 

transportation noise impacts would be SMALL. 

The NRC staff concludes that the site-specific conditions at the proposed Moore Ranch Project 

are comparable to that considered in the GEIS. The NRC staff concludes that site-specific 

impacts for the proposed Moore Ranch Project would be SMALL. Furthermore, the NRC staff 

has not identified any new and significant information during its independent review that would 

change the expected environmental impact beyond that discussed in the GEIS. 

4.8.1.2 Operation Impacts 

Section 4.3.7.2 of the GEIS discussed ISR operations activities that could generate noise. 

These activities would occur indoors within the central uranium processing facility; therefore, 

offsite noise from plant operations would be less than could be heard during the construction 

phase of an ISR project. Wellfield equipment (e.g., pumps, compressors) would be contained 

within structures (e.g., header houses, satellite facilities), also reducing the potential for noise to 

be heard by offsite individuals. Traffic noise from commuting workers, truck shipments to and 

from the facility, and facility equipment would likely be localized, limited to highways in the 

vicinity of the site, access roads within the proposed license area, and wellfield roads. Relative 

short-term increases in noise levels associated with this traffic would be SMALL for the larger 

roads, but could be MODERATE for lightly traveled rural roads through smaller communities. 

As noted in the GEIS and described above, the staff assumed that a variety of mechanical 

equipment located at the central plant at the proposed Moore Ranch Project would generate 

noise. However, because the nearest residence is located about 4.5 km [2.8 mi] from the center 

of the proposed Moore Ranch Project, this person would not notice any change in sound from 

the operations phase. Taking into account the relatively small increase in traffic (see Section 

4.3.1.2), the potential noise impacts during operations at the proposed Moore Ranch Project 

would be SMALL. 

4.8.1.3 Aquifer Restoration Impacts 

Section 4.7.3.3 of the GEIS stated that general noise levels during aquifer restoration would be 

expected to be similar, or less than, noise levels during operations. Additionally, workplace 

noise exposure during aquifer restoration would use the same administrative and engineering 

controls used during operations. Pumps and other wellfield equipment contained in buildings 
Environmental Impacts and Mitigative Actions 

4-52 

would reduce sound levels to offsite receptors. Existing operational infrastructure would be 

used, and traffic levels would be expected to be less than during construction and operation 

phases of an ISR facility. Therefore, the potential impacts could range from SMALL 

to MODERATE, depending on the location of the nearest resident. 

The types of activities described in the GEIS would occur at the proposed Moore Ranch Project. 

Vehicular traffic would be limited to delivery of supplies and staff travel to and from the site; 

therefore, fewer trips would occur than during the operations phase. Because the nearest 

residence is located about 4.5 km (2.8 mi) from the center of the proposed Moore Ranch Project 

(Uranium One, 2009a), this person would not notice a change in background noise. Taking into 

account the relatively small increase in traffic, (see Section 4.3.1.3), the potential noise impacts 

during aquifer restoration at the proposed Moore Ranch Project would be SMALL. 

4.8.1.4 Decommissioning Impacts 

Section 4.7.3.4 of the GEIS discussed the potential noise impact from decommissioning 

activities at an ISR facility. Noise levels generated during decommissioning and reclamation 

would be expected to be similar to or less than, noise levels during the ISR construction phase. 

Equipment used to dismantle buildings and milling equipment, remove potentially contaminated 

soils, or for surface grading during reclamation would generate above background noise levels. 

This noise would be temporary and once decommissioning and reclamation activities were 

complete, noise levels would return to baseline, with occasional vehicle traffic for any longer 

term monitoring activities. Like the construction phase of an ISR project, noise levels would be 

higher during daylight hours when decommissioning and reclamation would be more likely to 

occur, and would be more noticeable in proximity to the operating equipment. Workplace noise 

exposure would be managed using the same administrative and engineering controls 

implemented for the construction phase, and given the likely distance to nearby residents 

(i.e., greater than 300 m [1,000 ft ]), the GEIS concluded that the noise from decommissioning 

activities would not be discernable to offsite residents or communities. 

The noise during decommissioning of the proposed Moore Ranch Project would be similar to 

that experienced during construction activities and would be generated by earthmoving, 

excavation, and building demolition activities. Therefore, the noise impacts would either be 

similar to, or less noise than, during the construction activities at the site. Decommissioning 

activities would result in a large, but temporary noise impact onsite and just beyond the plant 

boundary. At the location of the nearest resident, located at a distance of about 4.5 km (2.8 mi) 

from the center of the proposed Moore Ranch Project (Uranium One, 2009a), there would be no 

change in background noise; therefore, anticipated noise impacts during decommissioning 

would be SMALL. As noted in Section 4.3.1.4 of this SEIS, the increase in truck traffic 

associated with decommissioning activities would be less than 2 percent. Therefore, 

transportation related noise impacts associated with the transfer of solid waste to the 

Midwest-Edgerton Landfill or transfer station and of byproduct material to a licensed facility 

would result in a SMALL impact above background noise levels. 

4.8.2 No-Action (Alternative 2) 

Under the No-Action alternative, there would be no change in the sound levels either within the 

proposed license area or to surrounding receptors. While natural resource exploration activities 

would continue and could potentially expand in the future, they would typically be of short 

duration and would involve few vehicles and no permanent, noise emitting infrastructure. The 
Environmental Impacts and Mitigative Actions 

4-53 

rural setting of the proposed project area and the continuation of ongoing natural resource 

exploration activities would result in sound levels remaining at or below 40 dBA. 

4.9 Impacts to Historical and Cultural Resources 

Potential environmental impacts to historic and cultural resources at the proposed Moore Ranch 

Project could occur during all phases of the ISR facility lifecycle. These impacts would 

predominantly result from the loss of or damage to historical, cultural, and archaeological 

resources and from temporary access restrictions to these resources. 

Detailed discussion of the potential environmental impacts to historic and cultural resources 

from construction, operation, aquifer restoration, and decommissioning of the proposed 

Moore Ranch Project are provided in the following sections. 

4.9.1 Proposed Action (Alternative 1) 

Under the proposed action, NRC would issue a license for ISR uranium milling and processing 

at the proposed Moore Ranch Project. The area that could be directly disturbed by the 

proposed action would be within approximately 61 ha [150 ac] of the 2,879 ha [7,110 ac] 

proposed license area. For archaeological sites, the impacts from various actions are linked to 

the physical footprints associated with the proposed action. The potentially impacted areas are 

described in detail in Section 2.1.1.1.2 and discussed in the following paragraphs. At the 

proposed Moore Ranch Project, a central plant, two wellfields and access roads would be 

constructed and pipeline would be laid. 

The construction of the central plant and storage facilities would disturb approximately 2.4 ha 

[6 ac]. Construction of the wellfields and a new access road would disturb approximately 23 ha 

[57 ac]. An existing two-track access road would connect SR 387 to service both Wellfields 1 

and 2. However, a new secondary access road would be constructed to connect Brown Road 

to the central plant (Figure 2-1). This new road would extend east from the main two-track road 

(Brown Road) to service the central plant. This secondary access road would encompass about 

0.7 ha [1.77 ac]. An ISR trunkline would connect Wellfield 2 and the central plant. Various 

wellfield-specific service roads also exist and they would connect the header houses, injection 

wells, and monitoring wells. 

4.9.1.1 Construction Impacts 

Section 4.3.8.1 of the GEIS discussed the potential impact to historic and cultural resources 

from excavation during the construction phase of an ISR facility (NRC, 2009a). Access to 

historical, cultural, and archaeological resources could also be temporarily restricted during the 

construction phase. 

An applicant would be expected to conduct the appropriate historic and cultural resource 

surveys as part of prelicense application activities. The GEIS also noted that eligibility 

determination for listing in the National Register of Historic Places (NRHP) under criteria in 

36 CFR 60.4(a)–(d) or as traditional cultural properties (TCPs), or both, would be conducted as 

part of the site-specific review. 

TCPs are historic and cultural resources that are important for a group to maintain its cultural 

heritage and are most often associated with Native American religious or cultural practices. 
Environmental Impacts and Mitigative Actions 

4-54 

Most TCPs can be identified only through consultation with federally-recognized Native 

American Tribes. To determine the presence of significant cultural resources and to mitigate 

potential impacts, consultation amongst the NRC, the applicant, the State Historic Preservation 

Offices (SHPO), other government agencies (e.g., BLM and State Environmental Departments), 

and Native American Tribes [Tribal government or designated Tribal Historic Preservation Office 

(THPO)] would be conducted as part of the site-specific review. In order for a property to be 

eligible as a TCP (National Register Bulletin 38, Guidelines for Evaluating and Documenting 

Traditional Cultural Properties), it must be eligible under one of the four eligibility criteria 

stipulated in 36 CFR 60.4. In addition, as discussed in the GEIS, an NRC licensee shall be 

required (under conditions in its license), to stop work upon discovery of previously 

undocumented historic or cultural resources and to consult with the appropriate federal, tribal, 

and state agencies with regard to the appropriate mitigation measures. The GEIS concluded 

that the potential impact to historic and cultural resources during the construction phase of an 

ISR project could range from SMALL to LARGE, depending on the site-specific conditions. 

Brunette (2007) reported the results of various Class III surveys that have been conducted at 

the proposed Moore Ranch Project. The archaeological sites and isolated finds that could be 

affected during construction were determined to be ineligible for listing on the NRHP 

(Brunette, 2007). No sites recommended as eligible for listing on the NRHP would be affected 

by the proposed action. The Wyoming SHPO concurred that the sites located within the project 

area are ineligible for listing on the NRHP (Wyoming SHPO, 2009). It is recommended by the 

Wyoming SHPO that the NRC allow the proposed project to proceed in accordance with State 

and Federal laws, subject to the following stipulation: If any cultural materials are discovered 

during construction, work in the area shall halt immediately, the federal agency and SHPO staff 

be contacted, and the materials be evaluated by an archaeologist or historian meeting the 

Secretary of the Interior’s Professional Qualification Standard (48 FR 22716, Sept. 1983). 

Additionally, if any future disturbance is planned at the locations of sites 48CA964, 48CA6694, 

48CA6696 that evaluative testing be completed and submitted to our office with a determination 

of site eligibility and project effect. If eligible and adversely affected, a Memorandum of 

Agreement implementing appropriate mitigative measures would be required (Wyoming 

SHPO, 2009). 

The applicant has agreed to condition the license, if issued, to include a stop-work provision 

should resources be encountered during construction. Since no sites potentially eligible for 

listing on the NRHP were identified that could be affected by construction phase activities at the 

proposed Moore Ranch Project, the potential impact to historical and cultural resources would 

be SMALL. 

4.9.1.2 Operation Impacts 

Section 4.3.8.2 of the GEIS concluded that potential impacts to historical, cultural, and 

archaeological resources from the operations phase of an ISR project would be less than during 

construction because the infrastructure would be in place and less land disturbance would 

occur. Upon the discovery of any previously undocumented historic or cultural resources, the 

licensee would stop work and notify the appropriate federal, tribal, and state agencies with 

regard to mitigation and because of the limited land disturbance during the operations phase, 

the GEIS concluded that impacts to historic and cultural resources from ISR operations would 

be SMALL. 
Environmental Impacts and Mitigative Actions 

4-55 

There would be no impacts to historic properties from operations at the proposed Moore Ranch 

Project. Therefore, the potential impact to historical and cultural resources from operations at 

the proposed Moore Ranch Project would be SMALL. In accordance with the stipulations 

identified by the Wyoming SHPO, should ground-disturbing activities (maintenance activities) 

occur outside of previously surveyed areas, then archaeological surveys would be conducted 

prior to the activity. 

4.9.1.3 Aquifer Restoration Impacts 

Section 4.3.8.3 of the GEIS concluded that impacts to historical and cultural resources from 

aquifer restoration would be either similar to, or less than, potential impacts during the 

operations phase because aquifer restoration activities would generally be limited to the existing 

infrastructure and previously disturbed areas (e.g., access roads, central processing facility). 

Therefore, the GEIS concluded that the potential impact to historic and cultural resources from 

aquifer restoration activities would be SMALL. 

As noted in Section 4.9.1.2 of this SEIS, the impact to historic and cultural resources during the 

aquifer restoration phase would be similar to that during operations. There would be no impacts 

on historic properties from the aquifer restoration phase of the proposed Moore Ranch Project; 

therefore, the impact would be SMALL. 

4.9.1.4 Decommissioning Impacts 

Section 4.3.8.4 of the GEIS discussed the potential impact to historic and cultural resources 

from decommissioning. Since decommissioning and reclamation activities would focus on 

previously disturbed areas, the historic and cultural resources would be known from the 

investigations conducted prior to construction. Therefore, the GEIS concluded that the potential 

impacts to historical, cultural, and archaeological resources from decommissioning and 

reclamation actions would be SMALL. 

As noted in Section 4.9.1.2 of this SEIS, the impact to historical and cultural resources during 

the decommissioning phase would be similar to that during operations. There would be no 

impacts to historic properties from decommissioning actions; therefore, the impact would 

be SMALL. 

4.9.2 No-Action (Alternative 2) 

If the No-Action alternative is selected, there would be no impacts to subsurface or surface 

historic and cultural resources. 

The impact to the resources resulting from the selection of the No-Action alternative considers 

only the consequences of the proposed action. It does not evaluate impacts to the resource 

categories that may be occurring from other, nonrelated actions. Other actions that are ongoing 

in the general area include oil and gas exploration and production and cattle ranching. The 

impact from cattle ranching on the cultural resources is ongoing. Cultural and ethnographic 

resources do not have to be inventoried or evaluated for this action to occur. This is not the 

case, however, for oil and gas exploration and production. State and Federal permits are 

required and cultural and ethnographic resources are routinely identified and evaluated as part 

of the permitting process. 
Environmental Impacts and Mitigative Actions 

4-56 

One of the archaeological sites identified within the proposed project area (48CA970) has been 

impacted by oil and gas exploration and production. However, it is likely that most of the 

archaeological sites have been disturbed by routine cattle grazing. Some sites had been 

obviously disturbed by two-track roads and cattle fences, for example. If the proposed action is 

not selected, then impacts to the cultural and historical resources would continue as they have 

in the past. 

4.10 Visual and Scenic Resources Impacts 

Potential visual and scenic impacts from the proposed Moore Ranch Project could occur during 

all phases of the ISR facility lifecycle. These impacts primarily would be associated with the use 

of equipment such as drill rigs, dust and other emissions from such equipment; construction of 

the central plant and storage structures, site and wellfield access roads; land clearing and 

grading activities, and lighting for nighttime operations. Such impacts could be mitigated by 

rolling topography, color considerations for structures, and dust suppression techniques. 

As described in Section 3.10, the BLM Visual Resource Management (VRM) classification of the 

proposed Moore Ranch Project was VRM Class IV, which allows an activity to contrast with 

basic elements of the characteristic landscape to a much greater extent (BLM, 2007). 

4.10.1 Proposed Action (Alternative 1) 

The proposed action would result in temporary, SMALL impacts to the visual and scenic 

resources of the area. The nature of the impacts would be in keeping with the BLM VRM 

classification as a Class IV area (see Section 3.10 of this SEIS). 

4.10.1.1 Construction Impacts 

As discussed in Section 4.3.9.1 of the GEIS, visual impacts during construction can result from 

equipment (drill rig masts and cranes), dust and diesel emissions from construction equipment, 

and hillside and roadside cuts. Depending on the location of a proposed ISL facility relative to 

viewpoints such as highways, process facility construction and drill rigs could be visible. For 

nighttime operation, the drill rigs would be lighted, and this would create a visual impact 

because the drill rigs would be most visible and provide the most contrast if they were located 

on elevated areas. Most impacts would be short term because the construction and drilling 

equipment would be removed when activities conclude at a specific location. Additionally, 

because these sites are expected to be in sparsely populated areas and there would be 

generally rolling topography of the region, most visual impacts during construction would not be 

expected to be visible from more than about 1 km [0.6 mi]. As previously discussed, Prevention 

of Significant Deterioration (PSD) Class I areas require more stringent air quality standards that 

can affect visual impacts; however, there are no PSD Class I areas in the Wyoming East 

Uranium Milling Region. Finally, proposed ISR facilities are expected to be located more than 

16 km [10 mi] from the closest VRM Class II area, and the visual impacts associated with ISR 

construction would be consistent with the predominant VRM Class III and IV classifications. 

Therefore, visual impacts associated with ISR construction would be SMALL. 

Since the land use surrounding the proposed Moore Ranch Project currently is a VRM Class IV 

area that has pipelines, wellfields, and utility lines that have previously disturbed the landscape, 

implementing the proposed action would not change the existing character of the landscape. 

Because more than 900 wells would be installed to support the ISR operations in Wellfields 1 
Environmental Impacts and Mitigative Actions 

4-57 

and 2, multiple drill rigs would likely be operating during wellfield construction. Once a well was 

completed and conditioned for use, the drill rig would be moved to a new location to drill the 

next hole. Because temperatures drop below freezing during the winter, the applicant would 

cover the wellheads for completed wells to prevent freezing and protect the well. These covers 

would be small, low structures {1 m [3 ft] high and 0.6 m [2 ft] in diameter} and present only a 

slight contrast with the existing landscape. Unless the topography is extremely flat and void of 

vegetation, it is likely that these structures would not be visible from distances about 1 km 

[0.6 mi] or more. 

Visual and scenic impacts associated with earthmoving activities during construction would be 

short term. Roads and structures would be more long lasting but would be removed and 

reclaimed after operations cease. As noted in Section 3.10, the proposed license area has 

been classified as BLM VRM Class IV, which allows an activity to have higher contrast with 

basic elements of the characteristic landscape. Wellfield development would occur first in 

Wellfield 2 and then in Wellfield 1. Restoration in Wellfield 2 would occur concurrently with 

operations in Wellfield 1. 

The visible surface structures for the proposed Moore Ranch Project include wellhead covers, 

13 header houses, electrical distribution lines {6 m [20 ft] wooden poles}, and the central plant 

{122 × 30 m [400 × 100 ft]}. The proposed project would use both existing and new roads to 

access each header house and the central plant. Temporary and short-term visual impacts 

from dust emissions during the construction period in each wellfield would result from header 

house construction, well drilling, and construction of access roads and electrical distribution 

lines. Following completion of wellfield installation, temporarily disturbed areas would be 

reclaimed. The applicant has indicated it would spray water to reduce dust emissions 

(Uranium One, 2009b), but short-term visibility from dust emissions could be MODERATE 

(see Section 4.7.1.1). In the longer term (>1 year), however, as major construction activities are 

completed, dust emissions would decrease. Taking into consideration the VRM Class IV 

classification for the area surrounding the proposed Moore Ranch Project, overall longer-term 

construction impacts to visual and scenic resources would be SMALL. 

4.10.1.2 Operation Impacts 

Section 4.3.9.2 of the GEIS stated that visual impacts during operations would be expected to 

be less than those associated with construction. Most of the wellfield surface infrastructure 

would have a low profile, and most piping and cables would be buried. The tallest structures 

would be expected to include the central uranium processing facility {10 m [30 ft]} and power 

lines {6 m [20 ft]}. Because these sites are in sparsely populated areas and the topography is 

typically generally rolling, most visual impacts during operations would not be visible from more 

than about 1 km [0.6 mi] away. Irregular layout of wellfield surface structures such as wellhead 

protection and header houses would further reduce visual contrast. The uranium districts in the 

four regions evaluated in the GEIS are all located more than 16 km [10 mi] from the closest 

VRM Class II region, and the visual impacts associated with ISR construction would be 

consistent with the predominant VRM Class III and IV classification. Therefore, the GEIS 

considered visual and scenic impacts from operations to be SMALL. 

Because uranium deposits are typically irregular in shape, the network of pipes, wells, and 

powerlines (6 m [20 ft] tall) would not be regular in pattern or appearance (i.e., not a grid), 

reducing visual contrast and associated potential impacts. Each wellhead cover approximately 

0.9 m [3 ft] high and 0.6 m [2 ft] in diameter typically consists of a weatherproof structure placed 
Environmental Impacts and Mitigative Actions 

4-58 

over the well and each header house would be a small metal building. The central plant at the 

proposed Moore Ranch Project would be approximately 122 m [400 ft] by 30 m [100 ft] in size. 

In addition, maintenance, warehouse, and office structures would be constructed. A 

disturbance area around each header house would be necessary to provide an adequate area 

for turnaround of operations and maintenance vehicles. Electrical distribution lines would 

connect header houses to existing electrical distribution lines. 

Extensive CBM development has occurred in the vicinity of the proposed Moore Ranch Project 

and future development is planned. CBM installations are similar in visual impact to those 

associated with ISR uranium extraction. CBM wells are installed in a network of approximately 

3 wells/km2

 [8 wells/mi2] connected by underground pipelines to collection and pumping 

structures that appear similar to ISR header houses. Overhead power lines are installed to 

each well. As a result of this activity, the BLM has identified the area in the vicinity of the 

proposed Moore Ranch project as VRM Class IV. 

Even though the operations phase of the proposed Moore Ranch Project is estimated to take 

12 years, the impacts to visual and scenic resources would be SMALL because of the BLM 

VRM Class IV classification, the existing natural resource extraction activities ongoing in the 

area, and the remoteness of the area. 

4.10.1.3 Aquifer Restoration Impacts 

Section 4.3.9.3 of the GEIS addressed visual and scenic impacts from aquifer restoration. The 

GEIS stated that aquifer restoration activities would be expected to take place some years after 

the facility had been in operation and that restoration activities would use in-place infrastructure. 

As a result, potential visual impacts would be similar to, or less than, those experienced during 

operations. Therefore, such impacts were expected to be SMALL (NRC, 2009a). 

Visual resource impacts from aquifer restoration at the proposed Moore Ranch Project would be 

similar to those seen in the operations phase described in Section 4.10.1.2 of this SEIS 

because the buildings and equipment the applicant would use to support restoration would be 

the same as those used for the operations phase. No modifications to either scenery or 

topography would occur during restoration. Therefore, impacts to visual and scenic resources 

from aquifer restoration would be SMALL. 

4.10.1.4 Decommissioning Impacts 

Section 4.3.9.4 of the GEIS discussed the impact to visual and scenic resources from 

decommissioning. Because similar equipment use and decommissioning activities would be 

conducted as those occurring during the construction phase, the potential impact to visual and 

scenic resources would be similar to, or less than, those experienced during construction. Most 

potential visual impacts during decommissioning would be temporary and would diminish as 

equipment removal proceeded and disturbed surfaces became revegetated. NRC licensees are 

required to conduct final site decommissioning and reclamation under an NRC-approved 

decommissioning plan, with the goal of returning the landscape to preconstruction conditions. 

While some roadside cuts and hill slope modifications may persist beyond decommissioning 

and reclamation, the GEIS analysis determined that visual and scenic impacts from 

decommissioning would be SMALL (NRC, 2009a). 
Environmental Impacts and Mitigative Actions 

4-59 

No modifications to scenery or topography would persist after restoration was complete. When 

project operations cease (the lifecycle of the proposed Moore Ranch Project is estimated at 

about 12 years), the applicant would return all lands disturbed by the facility to their 

preoperation land use for livestock grazing and wildlife habitat unless an alternative use (should 

the landowner wish to retain any structures) is justified and is approved by the State and the 

landowner. Reclamation would return the visual landscape to baseline contours and would 

reduce the visual impact by removing buildings and the associated infrastructure. After 

reclamation activities were completed, there would be no restrictions on surface use. The 

applicant would submit a decommissioning plan to the NRC, in accordance with 

10 CFR Part 40, prior to final site decommissioning. 

During decommissioning and reclamation, temporary impacts to the visual landscape would be 

similar to, or less than, those during the construction period. For example, equipment used to 

dismantle buildings and milling equipment, remove contaminated soil, or grade the surface as 

part of reclamation activities would generate temporary visual contrasts. Visual and scenic 

resources could also be affected by fugitive dust emissions from decommissioning activities. 

The applicant has indicated it would spray water to reduce dust emissions (Uranium One, 

2009b). Overall impacts to the visual landscape would be temporary, and short-term impacts to 

visibility from dust emissions could be MODERATE (see Section 4.7.1.1). Once 

decommissioning and reclamation activities were complete, however, the visual landscape 

would be returned to baseline except for any required monitoring. Therefore, long-term 

decommissioning impacts to visual and scenic resources would be SMALL. 

4.10.2 No-Action (Alternative 2) 

Under the No-Action alternative, there would be no ISR facility construction and, therefore, no 

change to existing visual and scenic resources at the proposed project area or in the region. 

The existing pipelines, wellfields, and utility lines within the proposed project area from CBM 

and gas extraction activities would remain. No additional structures or uses associated with the 

proposed Moore Ranch Project would be introduced to affect the existing viewscapes and the 

existing scenic quality would be unchanged. The visual resource classification would remain as 

BLM Class IV, as defined in Section 3.10 of this SEIS. 

Because there would be no ISR facility construction under the No-Action alternative, there 

would also be no facility operation, restoration, or decommissioning. The existing visual and 

scenic resources would remain. 

4.11 Socioeconomic Impacts 

Socioeconomic impacts are defined in terms of changes to the demographic and economic 

characteristics and social conditions of a region. For example, the number of jobs created by 

the proposed action could affect regional employment, income, and expenditures. Job creation 

is characterized by two types: (1) construction-related jobs, which are transient, short in 

duration, and less likely to have a long-term socioeconomic impact on the region; and 

(2) operation-related jobs in support of facility operations, which have the greater potential for 

permanent, long-term socioeconomic impacts in the region. 

The socioeconomic region of influence (ROI) represents a geographic area where ISR facility 

employees and their families would reside, spend their income, and use their benefits, thereby 

affecting the economic conditions of the region. As previously discussed, the focus of the 
Environmental Impacts and Mitigative Actions 

4-60 

analysis in this SEIS is on the impacts of constructing and operating the proposed ISR facility in 

Campbell County. 

Socioeconomic impacts would occur from the construction, operation, aquifer restoration, and 

decommissioning of the proposed Moore Ranch Project. A discussion of the potential 

socioeconomic impacts from these actions is presented in the following sections. 

4.11.1 Proposed Action (Alternative 1) 

4.11.1.1 Construction Impacts 

Construction of the proposed Moore Ranch Project is expected to last 9 months and employ 

50 workers (EMC, 2007a). Section 4.3.10.1 of the GEIS describes the potential socioeconomic 

impact from construction of an ISR facility (NRC, 2009a). The GEIS estimated total peak 

construction employment at an ISR facility to be about 200 people. The GEIS also estimated an 

additional 140 indirect jobs could be created to support the construction of an ISR facility. The 

NRC staff concludes that the site-specific impacts of constructing the proposed Moore Ranch 

Project would be smaller than the impacts described in the GEIS. 

It was assumed in the GEIS that most construction workers would stay in larger communities 

with access to more services. Although some construction workers would commute from 

outside the county to the construction site, skilled employees (e.g., engineers, accountants, 

managers) would come from outside the local work force. During construction, workers would 

temporarily relocate to the proposed project area and contribute to the local economy through 

the purchase of goods and services and the payment of taxes. 

4.11.1.1.1 Demographics 

Because of the short duration (9 months) and small size of the construction workforce 

(50 workers), the impact on demographic conditions in Campbell County from the proposed 

Moore Ranch Project would be SMALL. 

4.11.1.1.2 Income 

It is expected that construction workers would be paid at rates typical of the region. Therefore, 

impacts would be SMALL. 

4.11.1.1.3 Housing 

The number of construction workers would cause a short-term increase in the demand for 

temporary (rental) housing units in the county. However, the number of available housing units 

has been keeping pace with the increase in county population (see SEIS Sections 3.11.1, 

Demographics, and 3.11.3, Housing). Any changes in employment would have little to no 

noticeable effect on the availability of housing in Campbell County. Due to the short duration of 

the construction activity and the availability of housing in the region, there would be little or no 

employment-related housing impacts. Therefore, the impact would be SMALL. 
Environmental Impacts and Mitigative Actions 

4-61 

4.11.1.1.4 Employment Structure 

Construction of the proposed Moore Ranch Project would create employment opportunities for 

50 construction workers, with the potential of up to 35 jobs being generated to support this 

activity in the local economy. Because of the short duration (9 months) and small size of the 

construction workforce (50 workers), employment impacts from the construction of the proposed 

Moore Ranch Project would be SMALL. 

4.11.1.1.5 Local Finance 

Construction of the proposed Moore Ranch Project would generate some tax revenue in the 

local economy through the purchase of goods and services as well as contributing to county and 

State tax revenues. Because of the short duration (9 months) and small size of the construction 

workforce (50 workers), construction of the proposed Moore Ranch Project would have a 

SMALL impact on local finances. 

4.11.1.1.6 Education 

Because of the short duration of the construction activity (9 months; the GEIS assumed 12 to 

18 months), workers would not be expected to bring families and school-age children with them, 

and therefore, there would be no impact on educational services during construction of the 

proposed Moore Ranch Project. 

4.11.1.1.7 Health and Social Services 

The number of construction workers would cause a short-term increase in the demand for 

health and social services in the county. However, because of the short duration of the 

construction activity and the small size of the construction workforce (50 workers), there would 

be little or no impact on health and social services. 

4.11.1.2 Operation Impacts 

Operation of the proposed Moore Ranch Project is expected to last 12 years and employ from 

40 to 60 workers (EMC, 2007a). Section 4.3.10.2 of the GEIS discussed employment levels 

during ISR facility operations and assumed 50 to 80 workers would support this phase of the 

ISR lifecycle (NRC, 2009a). 

According to the GEIS, the effects on community services (e.g., education, healthcare, utilities, 

shopping, and recreation) during facility operations would be similar to the effects experienced 

during construction, except fewer people would be employed but for a longer duration 

(NRC, 2009a). 

The operations phase of the proposed Moore Ranch Project is expected to last for 

approximately 12 years, although each wellfield would be operational for about 3.25 years each. 

The operations workforce would impact the local economy through creating jobs, purchasing 

local goods and services, as well as increasing county and State tax revenues. Severance tax 

on the uranium extracted would also be collected at the State level and would contribute to the 

State of Wyoming general fund. 
Environmental Impacts and Mitigative Actions 

4-62 

The NRC staff concludes that the site-specific impacts of operating the proposed Moore Ranch 

Project would be comparable to the impacts described in the GEIS. The potential impact to 

each component of the socioeconomic system is discussed in the following paragraphs. 

4.11.1.2.1 Demographics 

Because of the small size of the operations workforce (40 to 60 workers) and the potential 

addition of 30 to 40 (indirect) workers in support of facility operations, demographic conditions in 

Campbell County are not likely to change. The combined effect of 70 to 100 new jobs in the 

region (assuming that all of the direct and indirect workers would relocate to the ROI) 

constitutes less than one percent of the current civilian labor force in Campbell County. 

Therefore, the impact on demographic conditions would be SMALL. 

4.11.1.2.2 Income 

The average annual salary for all full-time employees would be roughly $50,000. The total 

annual payroll is estimated at $2,900,000. This is slightly above the Wyoming average of 

$48,205 (USCB, 2008). Impacts to income during ISR facility operations are expected to 

be SMALL. 

4.11.1.2.3 Housing 

Demand for permanent housing is anticipated to increase in the communities surrounding the 

proposed Moore Ranch Project leading up to the startup of ISR facility operations. The 

surrounding towns of Wright, Edgerton, and Midwest, as well as larger cities such as Gillette 

and Casper, are within commuting distance. Vacancy rates are currently low in some of the 

nearby towns and cities (EMC, 2007a), and the added workforce could have an impact on the 

small housing inventory. Residents earning less than the median income and those on fixed 

incomes could be affected by the increased demand for housing. Because of the small size of 

the operations workforce (40 to 60 workers) and the potential addition of 30 to 40 (indirect) 

workers in support of facility operations, impacts to housing during ISR facility operations could 

range from SMALL to MODERATE. 

4.11.1.2.4 Employment Structure 

As previously discussed, ISR facility operations at the proposed Moore Ranch Project would 

generate 40 to 60 new jobs such as project managers, plant operators, lab technicians, and drill 

contractors. Some skilled positions are likely to be filled by people moving into the area rather 

than providing employment opportunities for people living in nearby communities. The 

proposed Moore Ranch Project could provide some jobs in the local economy. However, since 

it is likely that most skilled workers would be drawn from areas outside of the ROI, ISR facility 

operations at the Moore Ranch Project would not noticeably affect employment rates in 

Campbell County. Therefore, the impact on the employment structure would be SMALL. 

4.11.1.2.5 Local Finance 

Campbell County would receive tax revenue during ISR facility operations. Personal property 

tax would be applied to the value of all equipment used by the project. In addition, a State 

mineral severance tax would be applied to the milled uranium; however, this tax would not be 
Environmental Impacts and Mitigative Actions 

4-63 

directly returned to Campbell County. A county ad valorem tax for production would also 

contribute to local government revenue. 

Campbell County would indirectly benefit from the increased sales tax revenue from the 

increased number of workers relocating to the ROI and from increased demand for goods and 

services. The tax revenue-related impact from ISR facility operations on Campbell County is 

expected to be SMALL. 

4.11.1.2.6 Education 

An increase in the number of school-aged children because of 40 to 60 workers and their 

families relocating to Campbell County during ISR facility operations could have an impact on 

local public schools and education-related services. The average family size in Wyoming is 

2.97; therefore, a conservative estimate for the number of school-aged children that could 

relocate to the ROI would be 40 to 60 children. Children of various ages spread across 24 

schools and classrooms (kindergarten and grades 1–12). This small number of children is not 

likely to have a noticeable effect on student-to-teacher ratios in Campbell County School District 

#1. However, county planners indicated that the schools could accommodate a small increase 

in the number of students. Schools and education-related service impacts during ISR facility 

operations are expected to be SMALL. 

4.11.1.2.7 Health and Social Services 

A small increase in demand would be expected for health and social services during ISR facility 

operations from workers and their families relocating to the ROI. Operational impacts are not 

expected to differ significantly from those during the construction phase of the ISR facility. 

Impacts to health and social services during operations would be SMALL. 

4.11.1.3 Aquifer Restoration Impacts 

Section 4.3.10.3 of the GEIS indicated that the socioeconomic impact from aquifer restoration 

would be similar to the impacts experienced during ISR facility operations. This is because 

employment levels and demand for services would not change. The GEIS determined potential 

impacts to socioeconomics would be SMALL. 

Socioeconomic impacts from the aquifer restoration phase at the Moore Ranch Project would be 

similar to those experienced during ISR facility operations. Because aquifer restoration would 

be short-term and would not require specialized skills, some ISR facility operations workers 

would likely remain and other workers may be drawn from the local area. Impacts on 

demographics, income, housing, employment, tax revenue, as well as, health, social and 

educational services would remain unchanged because workers would likely have already 

relocated their families to the area and temporary workers would not relocate their families. The 

overall socioeconomic impact of aquifer restoration would be SMALL. 

The NRC staff concludes that the site-specific conditions at the proposed Moore Ranch 

Project are comparable to those described in the GEIS and incorporates by reference the 

GEIS conclusions that the socioeconomic impacts on the ROI from aquifer restoration would 

be SMALL. 
Environmental Impacts and Mitigative Actions 

4-64 

4.11.1.4 Decommissioning Impacts 

The applicant projects that during the 15 years following the completion of the operations and 

aquifer restoration, the number of direct employees at the proposed Moore Ranch Project would 

be about 27, with another 26 indirect and induced jobs (EMC, 2007a). The applicant anticipates 

that decommissioning the central plant would require about the same number of workers as the 

construction phase (50 workers). Both of these phases of the ISR lifecycle would require fewer 

employees than the workforce of 200 considered in the GEIS. 

NRC has regulations and guidance for decommissioning. These regulations are found in 

10 CFR Part 40.42. Additional guidance on how to decommission a nuclear facility is available 

in the Consolidated NMSS Decommissioning Guidance, NUREG–1757. Decommissioning of 

the proposed ISR facility would be subject to a separate safety and environmental review. The 

decommissioning process commences when the licensee informs NRC that it intends to 

decommission the facility or has ceased principal activities at the entire site or in any building or 

outdoor area. The licensee prepares a decommissioning plan and submits it to NRC for review. 

Upon approval of the decommissioning plan, NRC amends the existing license to allow 

decommissioning to proceed. At the completion of decommissioning, the licensee conducts a 

final status survey to demonstrate compliance with criteria established in the decommissioning 

plan. When NRC confirms that the criteria in the decommissioning plan for releasing the site or 

any part of the site, has been met, NRC either terminates or amends the license, depending on 

the intended use of the site. 

Socioeconomic impacts from decommissioning the proposed Moore Ranch Project are 

expected to be SMALL, especially if a number of the ISR facility operations workers remain to 

assist in this activity. 

The NRC staff concludes that the number of workers (20 to 30) anticipated during the 

decommissioning phase of the proposed Moore Ranch Project is less than the number (200) 

considered in the GEIS. Therefore, the anticipated socioeconomic impacts would be SMALL, 

within the range of impacts discussed in the GEIS. 

4.11.2 No-Action (Alternative 2) 

Under the No-Action alternative, the ISR facility would not be constructed and operated at the 

proposed Moore Ranch Project. Socioeconomic conditions in Campbell County would 

not change. 

4.12 Environmental Justice Impacts 

Under Executive Order 12898, Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations, federal agencies are responsible for identifying and 

addressing, as appropriate, disproportionately high and adverse human health and 

environmental impacts on minority and low-income populations. In 2004, the Commission 

issued a Policy Statement on the Treatment of Environmental Justice Matters in NRC 

Regulatory and Licensing Actions (69 FR 52040), which states, “The Commission is committed 

to the general goals set forth in Executive Order 12898, and strives to meet those goals as part 

of its NEPA review process.” 
Environmental Impacts and Mitigative Actions 

4-65 

The Council of Environmental Quality (CEQ) provides the following information in Environmental 

Justice: Guidance Under the National Environmental Policy Act (1997): 

Disproportionately High and Adverse Human Health Effects. Adverse health effects are 

measured in risks and rates that could result in latent cancer fatalities, as well as other fatal 

or nonfatal adverse impacts on human health. Adverse health effects may include bodily 

impairment, infirmity, illness, or death. Disproportionately high and adverse human health 

effects occur when the risk or rate of exposure to an environmental hazard for a minority or 

low-income population is significant (as employed by NEPA [National Environmental Policy 

Act]) and appreciably exceeds the risk or exposure rate for the general population or for 

another appropriate comparison group (CEQ 1997). 

Disproportionately High and Adverse Environmental Effects. A disproportionately high 

environmental impact that is significant (as defined by NEPA) refers to an impact or risk of 

an impact on the natural or physical environment in a low-income or minority community that 

appreciably exceeds the environmental impact on the larger community. Such effects may 

include ecological, cultural, human health, economic, or social impacts. An adverse 

environmental impact is an impact that is determined to be both harmful and significant 

(as employed by NEPA). In assessing cultural and aesthetic environmental impacts, 

impacts that uniquely affect geographically dislocated or dispersed minority or low-income 

populations or American Indian tribes are considered (CEQ 1997). 

The environmental justice analysis assesses the potential for disproportionately high and 

adverse human health or environmental effects on minority and low-income populations that 

could result from the construction and operation of the proposed ISR facility at Moore Ranch 

Project. In assessing the impacts, the following CEQ (1997) definitions of minority individuals 

and populations and low-income population were used: 

Minority individuals. Individuals who identify themselves as members of the following 

population groups: Hispanic or Latino, American Indian or Alaska Native, Asian, Black or 

African American, Native Hawaiian or Other Pacific Islander, or two or more races meaning 

individuals who identified themselves on a Census form as being a member of two or more 

races, for example, Hispanic and Asian. 

Minority populations. Minority populations are identified when (1) the minority population 

of an affected area exceeds 50 percent or (2) the minority population percentage of the 

affected area is meaningfully greater than the minority population percentage in the general 

population or other appropriate unit of geographic analysis. 

Low-income population. Low-income populations in an affected area are identified with 

the annual statistical poverty thresholds from the Census Bureau’s Current Population 

Reports, Series PB60, on Income and Poverty. 

4.12.1 Methodology 

NRC addresses environmental justice matters for license reviews through (1) identification of 

minority and low-income populations that may be affected by the proposed construction and 

operation of the proposed Moore Ranch Project and (2) examining any potential human health 
Environmental Impacts and Mitigative Actions 

4-66 

or environmental effects on these populations to determine if these effects may be 

disproportionately high and adverse. 

The 2000 Census provides race and poverty characteristics for Census Tracts and Block 

Groups in Campbell County. The proposed Moore Ranch Project and a 3.2-km [2-mi] perimeter 

are contained within five Census Tracts and one additional Block Group that encompass 

portions of Campbell, Converse, Johnson, and Natrona Counties. 

Campbell County was selected as the geographic area for comparison of demographic data for 

the affected Census Tract populations. This comparison was made to determine the 

concentration of minority or low-income populations in the affected Census Tracts relative to 

the State. 

Census Block Group data are available from the 2000 Census. Table 4-5 shows the percent of 

people living in poverty and the minority population in the United States, Wyoming, 

Campbell, Johnson and Natrona Counties and the block groups closest to the proposed 

Moore Ranch Project. 

The 2008 population of Campbell County has been estimated at 41,473 residents 

(see Table 3-11). Eleven percent of the Wyoming population is classified as being minority 

(Table 4-5). For the 2000 census, the minority population in the census tracts surrounding the 

proposed Moore Ranch Project ranged from 3.3 to 5.9 percent, approximately 5.3 to 7.9 percent 

below the state average of 11 percent. The U.S. population living below the poverty level was 

identified as 13 percent, and 11.4 percent of the population in Wyoming was determined to be 

living below poverty level. The percentage of people living below the poverty level within the 

census block groups surrounding the proposed Moore Ranch Project ranged from 12.4 to 

15.9 percent. 

The percentage of minority populations living in the affected block groups are similar to the 

percentage of minority populations recorded at the State and county level and well below the 

national level. No minority populations were identified as residing near the proposed 

Moore Ranch Project; most of the minority population block groups are located near Gillette, 

about 80 km [50 mi] to the northeast, and communities along the I-25 corridor to the south 

of Gillette. 

The environmental justice impact analysis evaluates the potential for disproportionately high and 

adverse human health and environmental effects on minority and low-income populations that 

could result from the construction and operation of the proposed Moore Ranch Project. Adverse 

health effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on 

human health. Disproportionately high and adverse human health effects occur when the risk or 

rate of exposure to an environmental hazard for a minority or low-income population is 

significant and exceeds the risk or exposure rate for the general population or for another 

appropriate comparison group. Disproportionately high environmental effects refer to impacts or 

risk of impact on the natural or physical environment in a minority or low-income community that 

are significant and appreciably exceeds the environmental impact on the larger community. 
Environmental Impacts and Mitigative Actions 

4-67 

Table 4-5. Percent Living in Poverty and Percent Minority in 2000 

Geographic Unit 

Percent Living in 

Poverty Percent Minority 

U.S 13.0 30.9 

Wyoming 11.4 11.2 

Campbell County 7.6 6.5 

Campbell County 

Project Block Group 1-1 12.4 3.3 

Johnson County 10.1 3.8 

Johnson County 

Project Block Group 9551-1 12.5 4.0 

Natrona County 11.4 9.1 

Natrona County 

Block Group14.01-2 15.9 5.9 

Source: US Census Bureau, 2009

Such effects may include biological, cultural, economic, or social impacts (CEQ, 1997). Some 

of these potential effects have been identified in resource areas discussed in Chapter 4 of this 

SEIS. For example, increased demand for rental housing during construction of the ISR facility 

could disproportionately affect low-income populations. Minority and low-income populations 

are subsets of the general public residing around the proposed Moore Ranch site, and all would 

be exposed to the same health and environmental effects generated from construction, 

operations, decommissioning, and aquifer restoration activities. 

4.12.2 Proposed Action (Alternative 1) 

Potential impacts to minority and low-income populations due to the construction and operation 

of the proposed Moore Ranch Project would mostly consist of environmental and 

socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and 

dust impacts would be short-term and limited to onsite activities. Minority and low-income 

populations residing along site access roads could experience increased commuter vehicle 

traffic during shift changes. As construction and operations employment increases at the 

proposed Moore Ranch Project, employment opportunities for minority and low-income 

populations may also increase. Increased demand for rental housing during peak construction 

could disproportionately affect low-income populations. However, according to the latest 

census information, there were over 1,000 vacant housing units in Campbell County 

(see Section 3.11.3). 

As part of addressing environmental justice associated with license reviews, NRC also analyzed 

the risk of radiological exposure through the consumption patterns of special pathway receptors, 

including subsistence consumption of fish, native vegetation, surface waters, sediments, and 

local produce; absorption of contaminants in sediments through the skin; and inhalation of plant 

materials. The special pathway receptors analysis is important to the environmental justice 

analysis because consumption patterns may reflect the traditional or cultural practices of 

minority and low-income populations in the area. 

Subsistence Consumption of Fish and Wildlife 

Executive Order 12898 (1994) directs federal agencies, whenever practical and appropriate, to 

collect and analyze information on the consumption patterns of populations who rely principally 

on fish or wildlife, or both, for subsistence and to communicate the risks of these consumption 
Environmental Impacts and Mitigative Actions 

4-68 

patterns to the public. In this SEIS, NRC considered whether there were any means for minority 

or low-income populations to be disproportionately affected by examining impacts to American 

Indian, Hispanic, and other traditional lifestyle special pathway receptors. Special pathways that 

took into account the potential levels of contaminants in native vegetation, crops, soils and 

sediments, surface water, fish, and game animals on or near the proposed Moore Ranch 

Project were considered. 

Potential impacts to minority and low-income populations would mostly consist of radiological 

effects; however, radiation doses from ISR facility operations are expected to be well below 

regulatory limits (see Section 4.13). Based on this information and the analysis of human health 

and environmental impacts presented in this SEIS, the proposed construction, operation, and 

decommissioning of the proposed ISR facility and aquifer restoration would not have 

disproportionately high and adverse human health and environmental effects on minority and 

low-income populations residing in the vicinity of the proposed Moore Ranch Project. 

4.12.3 No-Action (Alternative 2) 

Under the No-Action alternative, the ISR facility would not be constructed and operated at the 

proposed Moore Ranch Project. The relative conditions affecting minority and low-income 

populations in the vicinity of the Moore Ranch Project would remain unchanged. Therefore, 

there would be no disproportionately high and adverse impact to minority and low-income 

populations under the No-Action alternative. 

4.13 Public and Occupational Health and Safety Impacts 

Potential radiological and nonradiological impacts to public and occupational health and safety 

from ISR activities at the proposed Moore Ranch Project could occur during all phases of the 

ISR facility lifecycle. Such impacts could occur from normal operations or from accidents. 

Detailed discussion of the potential environmental impacts to public and occupational health and 

safety from construction, operation, aquifer restoration, and decommissioning the proposed 

Moore Ranch Project are provided in the following sections. 

4.13.1 Proposed Action (Alternative 1) 

4.13.1.1 Construction Impacts 

Section 4.3.11.1 of the GEIS discussed construction activities at an ISR facility, which would 

include installation of wellfields (and associated piping) and construction of surface processing 

structures, access roads, and supporting utilities. Fugitive dust generated from construction and 

vehicle traffic is expected but would likely be of short duration. The construction phase at the 

proposed Moore Ranch Project has been estimated to last 9 months. Based on radiological 

environmental monitoring data for the proposed Moore Ranch Project (see discussion in 

Section 6.2 of the SEIS), no significantly elevated levels of radioactive materials in soils above 

natural background levels have been identified (EMC, 2007b). Therefore, inhalation of fugitive 

dust with these background levels does not pose a radiological dose significantly different than 

that from natural background exposure (NRC, 2009a). 

Construction equipment would likely be diesel powered and would result in diesel exhaust that 

includes small particles. The impacts and potential human exposures from these emissions 
Environmental Impacts and Mitigative Actions 

4-69 

would be SMALL because the releases are usually of short duration and are readily dispersed 

into the atmosphere (NRC, 2009a). Appendix D of the final SEIS describes the emissions 

inventory evaluated for the proposed Moore Ranch Project. 

The NRC staff has not identified any new and significant information during its independent 

review of the proposed Moore Ranch Project environmental report, the site visit, or evaluation of 

other available information. Therefore, the NRC staff has determined that there would be no 

significant impacts to public and occupational health and safety from construction beyond those 

discussed in the GEIS. The construction phase of the proposed Moore Ranch Project would 

have a SMALL impact on workers and the general public. 

4.13.1.2 Operation Impacts 

Section 4.3.11.2 of the GEIS discussed potential occupational radiological impacts from normal 

operations that could result from (1) exposure to radon gas from the wellfields, (2) IX resin 

transfer operations, and (3) venting during processing activities. Workers could also be 

exposed to airborne uranium particulates from dryer operations and maintenance activities. 

Potential public exposures to radiation could occur from radon releases from the wellfields and 

uranium particulate releases (i.e., from facilities without vacuum dryer technology). Both worker 

and public radiological exposures are addressed in NRC regulations at 10 CFR Part 20, which 

require licensees to implement an NRC-approved radiation protection program. Measured and 

calculated doses for workers and the public are commonly only a fraction of regulated limits. 

For these reasons, the GEIS determined that potential radiological impacts to workers and the 

public would be SMALL (NRC, 2009a). 

Nonradiological worker safety would be addressed through occupational health and safety 

regulations and practices. 

Radiological accident risks could involve processing equipment failures leading to yellowcake 

slurry spills, or radon gas or uranium particulate releases. The GEIS stated that the 

consequences of these accidents to workers and the public would generally be low, except for a 

dryer explosion, which could result in a worker dose above NRC limits. The likelihood of such 

an accident would be expected to be low, due to design considerations and operational 

monitoring, and therefore the GEIS concluded the risk would also be low. 

The potential impact from nonradiological accidents include high consequence chemical release 

events (e.g., of ammonia) that could expose workers and nearby populations. However, the 

GEIS stated that the likelihood of such a release would be low, based on historical operating 

experience at NRC-licensed facilities, primarily because operators follow chemical safety and 

handling protocols. Therefore, the GEIS concluded that radiological and nonradiological 

impacts from accidents during operations could range from SMALL to MODERATE. 

4.13.1.2.1 Radiological Impacts to Public and Occupational Health and Safety From 

Normal Operations 

As discussed in the GEIS, some amount of radioactive materials would be released to the 

environment during ISR operations. The potential impact for these releases can be evaluated 

by the MILDOS-AREA computer code (MILDOS), which was developed by Argonne National 

Laboratory for calculating radiation doses to individuals and populations from releases that 

occur at uranium recovery facilities. MILDOS uses a multipathway analysis for determining 
Environmental Impacts and Mitigative Actions 

4-70 

external dose; inhalation dose; and dose from ingestion of soil, plants, meat, milk, aquatic foods, 

and water. The primary radionuclide of interest at an ISR facility is radon-222; other key 

radionuclides that may also be released, which are also in the uranium decay scheme, include 

uranium, thorium-230, radium-226, and lead-210. MILDOS uses a sector-average Gaussian 

plume dispersion model to estimate downwind concentrations. This model typically assumes 

minimal dilution and provides conservative estimates of downwind air concentrations and doses 

to human receptors. 

The GEIS presented historical data for ISR operations, providing a range of estimated offsite 

doses associated with six current or former ISR facilities. For these operations, doses to 

potential offsite exposure (human receptor) locations range between 0.004 mSv [0.4 mrem] 

per year for the Crow Butte facility located in Nebraska and 0.32 mSv [32 mrem] per year for the 

Irigaray facility located in Johnson County, both well below the 10 CFR Part 20 annual radiation 

dose limit of 1 mSv/yr [100 mrem/yr] (NRC, 2009a). 

The GEIS also provides a summary of doses to occupationally exposed workers at ISR 

facilities. As stated, doses would be similar regardless of the facility’s location and are well 

within the 10 CFR Part 20 annual occupational dose limit of 0.05 Sv [5 rem] per year. The 

largest annual average dose to a worker at a uranium recovery facility over a 10-year period 

[1994–2006] was 7 mSv [700 mrem]. More recently, the maximum total dose equivalents 

reported for 2005 and 2006 were 6.75 mSv [675 mrem] and 7.13 mSv [713 mrem]. 

The license application for the proposed Moore Ranch Project addresses several normal 

operations activities that have the potential to expose workers and members of the public to 

sources of radiation. The primary source of exposure would be from the release of radon-222 

during operations, which include extraction of the uranium onto IX columns from the pregnant 

lixiviant from the wellfield extraction, the elution of the uranium from the IX columns and 

subsequent precipitation of uranium, followed by the drying and packaging of the yellowcake for 

shipment to an offsite facility for further processing. 

As described in the GEIS, and discussed in Section 2.1.1.1.6.1 of this SEIS, the drying and 

packaging of the precipitated uranium would be conducted under vacuum, thereby limiting 

release of airborne radioactive materials (uranium and short-lived particulate progeny) to zero or 

near zero. The applicant has proposed to dispose of radioactive and potentially toxic liquid 

effluent from the operations phase via deep well injection. Therefore, there would be no 

anticipated routine liquid releases or pathways of exposure from routine operations. Leaks and 

spills are evaluated as abnormal conditions in Section 4.13.1.2.2. No routine releases of 

radioactive liquids during operations have been reported. 

For normal operations, radon-222 would be the only significant radionuclide anticipated to be 

released; the primary sources would be from wellfield venting and releases from within the 

central plant for process operations (predominantly via vent stacks on the IX columns and 

various tanks). As discussed in Section 2.1.1.6.1 the applicant has proposed using pressurized 

downflow IX columns that are expected to significantly reduce the radon emissions from the 

processing circuit. 

The potential source term (i.e., radiological releases to the atmosphere) for normal operations 

were calculated by the applicant using the NRC approved methodology of Regulatory 

Guide 3.59 for releases from the production fluids and NUREG–1569 for the processing of 

resins from satellite facilities. The application of this methodology for the Moore Ranch Project 
Environmental Impacts and Mitigative Actions 

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and the resultant source term is discussed in Section 4.12 of the applicant’s environmental 

report (Uranium One, 2009a,b). Table 4-6 summarizes these releases. 

Based on this source term, radiation doses at the site boundary in each of the 16 meteorological 

sectors (e.g., N, NNE, NE, ENE, and E) and at the locations of nearby residences were 

calculated using the MILDOS-AREA code (Argonne National Laboratory, 1989). The MILDOSAREA code was also used to assess radiation dose in the GEIS. The principal exposure 

pathways modeled include inhalation, ingestion, and direct exposure. The highest dose at the 

site boundary was 0.008 mSv [0.8 mrem] per year TEDE at the northwest property boundary, 

which is 0.8 percent of the 1 mSv [100 mrem] per year dose limit for a member of the public 

specified in 10 CFR 20.1301. The maximum exposed individual for a resident located 

4.5 km [2.8 mi] to the east of the facility is calculated to be 0.007 mSv [0.7 mrem] per year, also 

a small fraction of the 1 mSv per year regulatory limit. These doses are consistent with the 

doses identified for other ISR facilities considered in the GEIS, where the range was from a high 

Table 4-6. Estimated Radon-222 Releases (Ci yr−1

)* from the Proposed 

Moore Ranch Project 

Location Production Restoration Drilling Resin Transfer 

Wellfield 1 85.3 20 0 0 

Wellfield 2 85.3 20 0 0 

Main Plant Stack 230 53 0 5.3 

New wellfield 0 0 0.43 0 

*Based on the phased approach to wellfield development, production, and restoration the annual emissions for 

any specific year would vary based on the degree of overlap in planned activities 

Source: EMC, 2007a 

of 0.317 mSv [31.7 mrem] per year for the Crow Butte facility to 0.004 mSv [0.4 mrem] per year 

for the Irigaray facility. 

The applicant also calculated the collective dose using MILDOS-AREA for the population 

residing within 80 km [50 mi] of the facility. This dose, which is a measure of the total 

radiological impact from routine operations for the potentially affected communities, was 

estimated at 0.0009 person-Sv [0.09 person-rem] per year. 

The applicant also evaluated the deposition of the radon-222 particulate decay products 

(polonium-210, lead-210, bismuth-214, and lead-210) and the potential exposure to flora and 

fauna. The calculated soil concentrations were less than 0.01 pCi/g at the surface, which is a 

small fraction of that normally present in the soil from the natural background levels of uranium 

and decay products. Therefore, any impact from increased soil radioactivity levels from 

airborne releases of radon during normal operations would be SMALL. 

Based on typical occupational injury and illness rates for the Wyoming mining industry, the 

applicant estimated that operations at the proposed Moore Ranch Project could potentially 

result in 1.9 nonfatal occupational injuries and illnesses per year of operation (EMC, 2007a). 
Environmental Impacts and Mitigative Actions 

4-72 

In summary, potential radiation doses to occupationally exposed workers and members of the 

public from operation of the proposed Moore Ranch Project would be SMALL. Calculated 

radiation doses from the modeling of releases of radioactive materials to the environment are 

small fractions of the limits of 10 CFR Part 20 that have been established for the protection of 

the public health and safety. The NRC staff have not identified any new and significant 

information during its independent review of the Moore Ranch environmental report, the site 

visit, or evaluation of other available information. Therefore, the NRC staff have determined that 

there would be no significant radiological impacts from normal operations to the public or 

occupational exposed workers beyond those discussed in the GEIS. 

4.13.1.2.2 Radiological Impacts to Public and Occupational Health and Safety from Accidents 

The GEIS provides an identification, discussion, and consequence assessment for accident 

conditions that could occur with an ISR operation (NRC, 2009a). As discussed, a radiological 

hazard assessment (Mackin, et al., 2001) considered three types of accidents, representing the 

sources containing the higher levels of radioactivity for all aspects of operation: 

• Thickener failure and spill 

• Pregnant lixiviant and loaded resin spills (radon release) 

• Yellowcake dryer accident release 

Table 4-7. Generic Accident Dose Analysis for ISR Operations 

Accident Scenario Maximum Dose to Workers Maximum Dose to Public 

Thickener spill 50 mSv [5,000 mrem] 0.25 mSv [25 mrem] 

Pregnant lixiviant, resin spill 13 mSv [1,300 mrem] <0.13 mSv [<13 mrem] 

Yellowcake dryer release 0.088 Sv [8.8 rem] Generic 

<0.01 Sv [1 rem] 

Moore Ranch Project 

<1 mSv [<100 mrem] 

Data adapted from GEIS (NRC, 2009a) 

The following discussion presents an overview for each of these accident scenarios, as 

evaluated in the GEIS, along with a specific application to the proposed Moore Ranch Project. 

Table 4-7 summarizes the potential dose to workers and the public from the accident scenarios 

described in the following paragraphs. 

Thickener Failure and Spill. Thickeners are used to concentrate the yellowcake slurry before it 

is transferred to the dryer or packaged for off-site shipment. Radionuclides could be 

inadvertently released to the atmosphere through a thickener failure or spill. The accident 

scenario evaluated in the GEIS assumed a tank or pipe leak that releases 20 percent of the 

thickener outside of the processing building. The analyses included a variety of wind speeds, 
Environmental Impacts and Mitigative Actions 

4-73 

stability classes, release durations, and receptor distances. A minimum receptor distance of 

152 m [500 ft] was selected because it was found to be the shortest distance between a 

processing facility and an urban development for current operating ISR facilities. Off-site, 

unrestricted doses from such a spill could result in a dose of 25 mrem, or 25 percent of the 

annual public dose limit of 100 mrem y−1

 with negligible external doses based on sufficient 

distance between the facility and receptor (NRC, 2009a). Because the nearest resident to the 

proposed Moore Ranch Project is located 4.5 km [2.8 mi] east of the proposed license area, the 

potential dose would be even less. 

As discussed in the GEIS, doses to unprotected workers inside the facility have the potential to 

exceed the annual dose limit of 5 rem y−1

 if timely corrective measures were not taken for 

protecting workers and remediating the spill. Typical protection measures, such as monitoring, 

respiratory protection, and material control, which would be a part of the applicant Radiation 

Protection Program, would reduce worker exposures and the resulting doses to a small fraction 

of those evaluated. 

Pregnant Lixiviant and Loaded Resin Spills. Process equipment (IX columns, drying and 

packing facilities) would be located on curbed concrete pads, as discussed in Section 2.1.1.2, to 

prevent any liquids from spills or leaks from exiting the building and contaminating the outside 

environment. Therefore, except for wellfield leaks, as further evaluated, the potential for an 

accidental liquid release with exposure from a liquid pathway was not considered realistic. The 

primary radiation source for liquid releases within the facility would be the resulting airborne 

radon-222 as released from the liquid or resin tank spill. 

The radon accident release scenario assumes a pipe or valve of the IX system, containing 

pregnant lixiviant, develops a leak and releases (almost instantaneously) all present radon-222 

at a high activity level (8 × 105

 pCi L−1). For a 30-minute exposure, the dose to a worker located 

inside the central plant performing light activities without respiratory protection was calculated to 

be 13 mSv [1,300 mrem], which is below the 10 CFR Part 20 occupational annual dose limit. 

The analysis did not evaluate public dose; however, because atmospheric transport offsite 

would reduce the airborne levels by several orders of magnitude, any dose to a member of 

thepublic would be less than the 1 mSv [100 mrem] public dose limit of 10 CFR Part 20. 

Radiation Protection Program controls and monitoring measures would be expected to minimize 

the magnitude of any such release and further reduce the consequences of this type accident. 

Yellowcake Dryer Accident Release. Dryers used to produce yellowcake powder from 

yellowcake slurry are another source for accidental release of radionuclides. A multiple-hearth 

dryer is capable of releasing yellowcake powder inside the processing building as a result of an 

explosion and was evaluated in the GEIS as a bounding condition for this type of accidental 

scenario. The analysis assumes about 4,300 kg [9,500 lb] of uranium yellowcake is released 

within the building area housing the dryer and of this, 1 kg [2.2 lb] is subsequently released as 

an airborne effluent to the outside atmosphere as a 100 percent respirable powder. Due to the 

nature of the material, most of the yellowcake would rapidly fall out of airborne suspension. For 

the occupationally exposed worker using respiratory protection, which is the normal mode 

during dryer access and drum-filling operations, the dose was calculated to be 0.088 Sv 

[8.8 rem], which exceeds the annual occupational dose limit of 0.05 Sv [5 rem)]. The amount 

assumed to remain airborne and to be transported outside the building for atmospheric 

dispersion to an offsite location would be 1 kg [2.2 lbs] of yellowcake. The rapid fallout within 

the building and the atmospheric dispersion to an offsite location would significantly reduce the 

exposure to members of the public, where the calculated dose was less than 100 mrem. 
Environmental Impacts and Mitigative Actions 

4-74 

The applicant proposes to use two rotary vacuum dryers with the use of heat-transfer fluid that 

circulates through the dryer shell. This configuration separates the heater combustion source 

from the dryer itself, thereby mostly eliminating the possibility of an explosion, which is the 

initiating event for the assumed catastrophic failure and significant release of dryer radioactive 

content. The removal of the driving force for the resuspension of the yellowcake greatly 

reduces consequences. Additionally, the applicant would have emergency response 

procedures in place to provide proper directions for mitigating worker exposures; and 

emergency training drills, dosimetry, respiratory protection, and contamination control and 

decontamination are required as part the applicant Radiation Protection program. Both of these 

would further reduce the consequences of this type accident. 

Accident Analysis Conclusions. With the addition of site-specific consideration for the 

yellowcake dryer accident, the GEIS evaluations appropriately encompass the type of accidents 

and consequences for the proposed Moore Ranch Project. The NRC Staff has not identified 

any new and significant information during its independent review of the Moore Ranch 

environmental report, the site visit, or evaluation of other available information. Therefore, there 

would be no significant radiological impacts from potential accidents to the public or 

occupationally exposed workers beyond those considered in the GEIS. The impacts to workers 

would be SMALL, if radiation safety and incident response procedures in the applicant’s NRC 

approved radiation protection plan were followed; the impacts to the general public would also 

be SMALL. 

4.13.1.2.3 Nonradiological Impacts to Public and Occupational Health and Safety From 

Normal Operations 

The GEIS identified the various chemicals, hazardous and nonhazardous, along with typical 

quantities that are generally used at ISR facilities. The use of hazardous chemicals at ISR 

facilities are controlled under several regulations that are designed to provide adequate 

protection to workers and the public. The primary regulations applicable to the use and 

storage include: 

• 40 CFR Part 68, Chemical Accident Prevention Provisions. This 

regulation includes a list of regulated toxic substances and threshold 

quantities for accidental release prevention. 

• 29 CFR 1910.119, OSHA Standards (which includes Process Safety 

Management [PSM]). This regulation provides a list of highly hazardous 

chemicals, including toxic and reactive materials that have the potential 

for a catastrophic event at or above the threshold quantity. 

• 40 CFR Part 355, Emergency Planning and Notification. This regulation 

contains a list of extremely hazardous substances and their threshold 

planning quantities (TPQs) for the development and implementation of 

ERPs. A list of reportable quantity (RQ) values is also provided for 

reporting releases. 

• 40 CFR 302.4, Designation, Reportable Quantities, and Notification–

Designation of Hazardous Substances. This regulation provides a list of 

Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA) hazardous substances compiled from the Clean Water 
Environmental Impacts and Mitigative Actions 

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Act, Clean Air Act, Resource Conservation and Recovery Act, and the 

Toxic Substances and Control Act. 

The following lists the hazardous chemicals and their associated protective provisions expected 

to be used at the proposed Moore Ranch Project (EMC, 2007a; 2007b): 

• Sulfuric acid (H2SO4)–Due to the quantities that would be used, ERPs 

would be required per 40 CFR Part 355. The storage tank would be 

located away from other process tanks to preclude accidental mixing with 

other chemicals. 

• Oxygen (O2)–Oxygen would be stored near, but a safe distance from, the 

central plant or within wellfield areas. The oxygen storage facility would 

be designed to meet industry standards contained in National Fire 

Protection Association 50–Standards for Bulk Oxygen Systems at 

Consumer Sites. (National Fire Protection Association, 2001) Procedures 

would be developed for spills or fires in the oxygen system. 

• Liquid hydrogen peroxide–50 percent (H2O2)–Because the concentration 

would be <52 percent, no additional regulatory protective measures would 

be required. 

• Carbon dioxide (CO2)–Carbon dioxide would be stored adjacent to the 

central plant. Floor-level ventilation and low-point carbon dioxide 

monitors would be installed to preclude a buildup of carbon dioxide in 

occupied areas. 

• Sodium carbonate (Na2CO3) and Sodium Chloride (NaCl)–Systems 

utilizing these chemicals would be designed to industry standards. 

• Sodium Sulfide (Na2S)–Sodium Sulfide would be stored outside of 

process areas and separate from hydrogen peroxide and sulfuric acid 

• Hydrochloric acid (HCl)–Due to the quantities that would be used, 

reporting quantities would be required per 40 CFR Part 302.4. The 

hydrochloric acid storage tank would be located away from other process 

tanks to preclude accidental mixing with other chemicals. 

The typical on-site quantities for some of these chemicals exceed the regulated, minimum 

reporting quantities and trigger an increased level of regulatory oversight regarding possession 

(type and quantities), storage, use, and disposal practices. Compliance with applicable 

regulations reduces the likelihood of a release. Off-site impacts would be SMALL and do not 

typically pose a significant risk to the public, while workers involved in a response and cleanup 

could experience MODERATE impacts if the proper emergency and cleanup procedures and 

worker training was not available or was inadequate. 

In general, the handling and storage of chemicals at the facility would follow standard industrial 

safety standards and practices. As identified in Section 4.12.1.2.1 of the applicant’s 

environmental report, industrial safety aspects associated with the use of hazardous chemicals 

at Moore Ranch Project are regulated by OSHA (EMC, 2007a). Section 3.2.3 of the applicant 

technical report provides an overview of storage practices (EMC, 2007b). Chemical storage 

facilities would include hazardous and nonhazardous material storage areas. Bulk hazardous 

materials would be stored outside and segregated from areas where licensed materials are 
Environmental Impacts and Mitigative Actions 

4-76 

processed and stored to minimize potential impact on radiation safety. Bulk storage of 

hazardous chemicals would be separated to avoid mixing of incompatible materials; and outside 

storage areas would be located at a sufficient distance from facilities to minimize hazards to 

people during an accidental release. Other nonhazardous bulk process chemicals (e.g., sodium 

carbonate) that do not have the potential to impact radiological safety could be stored within the 

central plant facilities. 

The applicant has proposed an overall chemical safety program that includes: 

• Risk Management Planning, as required in 40 CFR Part 68 

• Process Safety Management of Highly Hazardous Chemicals standard 

contained in 29 CFR 1910.119 

• Threshold Planning Quantities as contained in 40 CFR Part 355 

• Reportable quantities for spills from CERCLA in 40 CFR 302.4 

In the State of Wyoming, industrial safety at ISR operations is regulated by the Wyoming State 

Mine Inspector. 

The types and quantities of chemicals (hazardous and nonhazardous) for proposed use at 

Moore Ranch Project do not differ from those evaluated in the GEIS. Information provided for 

the proposed Moore Ranch Project does not contain any new or significant information that is 

either contrary to or varies from the information in the GEIS conclusions regarding potential 

impacts to the public or occupational health and safety. Therefore, the nonradiological impacts 

during normal operations at Moore Ranch Project would be SMALL. 

4.13.1.2.4 Nonradiological Impacts to Public and Occupational Health and Safety 

From Accidents 

The risks from accidents associated with the use of the typical hazardous and nonhazardous 

chemicals for an in-situ uranium recovery operation are not different than those for other typical 

industrial applications. In general, these risks are deemed acceptable as long as design and 

facility safety policies and practices meet industry and regulatory standards. Past history at 

current and former ISR facilities has shown these facilities can be designed and operated with 

appropriate measures to ensure proper safety for workers and the public. 

Appendix E of the GEIS, Hazardous Chemicals, provides an accident analysis for the more 

hazardous chemicals (NRC, 2009a). That analysis indicates chemicals commonly used at ISR 

facilities can pose a serious safety hazard if not properly handled. The GEIS does not evaluate 

potential hazards to workers or the public due to specific types of high-consequence, 

low-probability accidents (e.g., a fire or large magnitude sudden release of chemicals from a 

major tank or piping system rupture). The application of common safety practices for handling 

and use of chemicals would be expected to lower the likelihood of these severe release events 

and therefore lower the risk to acceptable levels. 

Spills of reportable quantities from chemical bulk storage areas would be reported to the 

WDEQ in accordance with WDEQ-WQD Rules and Regulations, Chapter 17, Part E and 

40 CFR 302 (CERCLA). 
Environmental Impacts and Mitigative Actions 

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The types and quantities of chemicals (hazardous and nonhazardous) for proposed use at 

Moore Ranch Project do not differ from that evaluated in the GEIS. Information provided for the 

proposed Moore Ranch Project does not contain any new or significant information that is either 

contrary to or varies from the information and conclusions in the GEIS regarding potential 

nonradiological impacts on public and occupational health and safety from chemical accidents. 

Offsite impacts would be SMALL and do not typically pose a significant risk to the public, while 

workers involved in a response and cleanup could experience MODERATE impacts. Based on 

this finding and the GEIS conclusions, the impacts from potential accidents for both 

occupationally exposed workers and members of the public would be SMALL. 

4.13.1.3 Aquifer Restoration Impacts 

Section 4.3.11.3 of the GEIS discussed potential radiological and nonradiological impacts from 

aquifer restoration. Activities occurring during aquifer restoration would overlap similar activities 

occurring during operations (e.g., operation of wellfields, wastewater treatment and disposal). 

Therefore, the potential impact on public and occupational health and safety would be bound by 

the operational impacts. The GEIS also stated that the reduction of some operational activities 

(e.g., yellowcake production and drying, remote IX) as aquifer restoration proceeded would be 

expected to limit the relative magnitude of potential worker and public health and safety 

hazards. The GEIS concluded that the overall impacts from aquifer restoration would 

be SMALL. 

Aquifer restoration activities for the proposed Moore Ranch Project involve activities similar to 

those during operations (e.g., operation of wellfields, wastewater treatment and disposal); 

therefore, the potential impact on public and occupational health and safety would be expected 

to be similar to the operational impacts. The reduction or elimination of some operational 

activities (e.g., yellowcake production and drying, remote IX) would further limit the relative 

magnitude of potential worker and public health and safety hazards. The radiation doses 

associated with restoration are included in the operations assessment in Section 4.13.1.2.1. 

Similarly, nonradiological hazards during aquifer restoration are assessed in Section 4.13.1.2.3. 

Accident consequences would be expected to be smaller than those evaluated in 

Sections 4.13.1.2.2 and 4.13.1.2.4. Therefore, aquifer restoration would be expected to have a 

very localized SMALL occupational impact to workers (primarily from radon gas) and to the 

general public for the duration of the aquifer restoration phase, which is estimated to last for 

3.5 years at Wellfield 1 and 5.25 years at Wellfield 2. 

4.13.1.4 Decommissioning Impacts 

Section 4.3.11.4 of the GEIS discussed potential radiological and nonradiological impacts to 

public and worker health and safety during the decommissioning phase of an ISR facility. 

Worker and public health and safety would be addressed in an NRC-required and approved 

decommissioning plan. This plan would be prepared in compliance with 10 CFR Part 40.42 and 

discusses implementation of the safety program to ensure worker safety and protection of the 

public during decommissioning and compliance with applicable safety regulations. An ISR 

licensee would conduct decommissioning activities in accordance with the approved plan, and 

compliance would be enforced through NRC inspections. 

The GEIS also assumed that as decommissioning proceeded, the potential environmental 

impact would be expected to decrease because the hazard would be removed, soils and 

structures would be decontaminated, and disturbed lands would be reclaimed. 
Environmental Impacts and Mitigative Actions 

4-78 

As discussed in the GEIS, the environmental impact from decommissioning an ISR facility 

would be SMALL. The degree of potential impact would decrease as the hazards were either 

reduced or removed, soils and facility structures were decontaminated, and lands were restored 

to preoperational conditions. Typically, the initial decommissioning steps would include removal 

of hazardous chemicals. As such, the majority of safety issues to be addressed during the 

decommissioning phase would involve radiological hazards at the facility. 

To ensure the safety of the workers and the public during decommissioning, NRC requires 

licensed facilities to submit a decommissioning plan for review. The plan would include details 

of the radiation safety program that would be implemented during decommissioning to ensure 

that the workers and public would be adequately protected and that their doses are compliant 

with 10 CFR Part 20, Subpart C and Subpart D limits. An approved plan would also provide 

ALARA provisions to further ensure best safety practices are being use to minimize radiation 

exposures. Finally, adequate protection of workers and the public during decommissioning is 

further ensured through NRC plan approval, license conditions, and inspection and 

enforcement. 

The decommissioning of the proposed Moore Ranch Project and any subsequent NRC approval 

for release of the site for unrestricted access would have to be in conformance with the NRC 

radiation protection standards for decommissioning of uranium recovery facilities. Therefore, 

any potential radiation dose to members of the public would also be in conformance with 

standards established for protecting public health and safety. 

Applicant-provided information does not contain any new or significant information that is 

contrary to or varying significantly from the GEIS information and conclusions regarding the 

potential impact to public and occupational health and safety. Therefore, the potential impact 

from and following decommissioning would be short term and SMALL. 

4.13.2 No-Action (Alternative 2) 

Under the No-Action alternative, there would be no occupational exposure. There would be no 

additional radiological exposures to the general public from project related effluent releases, and 

there would be no impact on long-term environmental radiological conditions. Radiation 

exposure and risk to the general public would continue to be determined by exposure from 

natural background, medical-related exposures, consumer products, and exposures from 

existing residual contamination. Under the No-Action alternative, the existing residual 

radioactivity would remain in these areas and would not be remediated. 

4.14 Waste Management Impacts 

Potential environmental impacts from waste management at the proposed Moore Ranch Project 

could occur during all phases of the ISR facility lifecycle. ISR facilities generate radiological and 

nonradiological liquid and solid wastes that must be handled and disposed of properly. The 

types of waste streams to be disposed of at the proposed Moore Ranch Project are discussed in 

Section 2.1.1.1.6 of this SEIS. See the text box in Section 2.1.1.1.6 for a list of liquid and solid 

waste types. The primary radiological wastes to be disposed of at the proposed Moore Ranch 

Project are process-related liquid wastes and process-contaminated structures and soils all of 

which are classified as byproduct material. Before operations could begin, NRC requires an 

ISR facility to have an agreement in place with a licensed disposal facility to accept byproduct 

material. The applicant has committed to disposing of byproduct material at a licensed disposal 
Environmental Impacts and Mitigative Actions 

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site. This disposal agreement would be in place prior to the start of operations as required by a 

license condition. 

Detailed discussion of the potential environmental impacts from waste management actions 

during the construction, operations, aquifer restoration, and decommissioning phases of the 

proposed Moore Ranch Project are discussed as follows. Discharges of storm water runoff and 

wastewater discharges to surface waters are discussed in Section 4.5.1. 

4.14.1 Proposed Action (Alternative 1) 

Under the proposed action, the applicant would dispose of liquid effluent via a Class I injection 

well discussed in Section 4.14.1.1. Alternative wastewater disposal options, including 

evaporation ponds, surface water discharge, land application, and disposal via Class V 

injections wells, are discussed in Section 4.14.1.2. 

4.14.1.1 Disposal Via Class I Injection Well 

4.14.1.1.1 Construction Impacts 

Section 4.3.12.1 of the GEIS concluded that waste management impacts from the construction 

phase of an ISR facility would be SMALL. Because construction activities would be on a 

relatively small scale and the wellfields would be developed incrementally, a low volume of 

construction waste would be generated. The primary wastes to be disposed of during this 

phase of the ISR lifecycle would be expected to be nonhazardous solid wastes, such as building 

materials and piping. As discussed in Section 3.13.2, the applicant has proposed to dispose of 

nonhazardous solid wastes at the City of Casper landfill in Casper, Wyoming, approximately 

97 km [60 mi] from the proposed Moore Ranch Project site. The applicant would transport the 

wastes either directly to the Casper facility or to a permitted transfer station located at the 

Midwest/Edgerton landfill, located approximately 39 km [24 mi] from the proposed Moore Ranch 

Project. Any small amounts of hazardous wastes generated during construction (e.g., batteries, 

solvents, waste equipment oil) would be stored, in accordance with WDEQ regulations, and 

ultimately transported to the Casper landfill special waste and diversion facility for disposal. 

The relatively small scale of construction activities and incremental development of the 

wellfields at ISR facilities generate low volumes of construction waste. No byproduct material 

would be generated during the construction phase at Moore Ranch Project. Therefore, impact 

on waste management during the construction phase would be SMALL. 

The NRC staff concludes that the site-specific conditions at the proposed Moore Ranch Project 

are comparable to the generic conditions described in the GEIS for waste management. 

Therefore, this SEIS incorporates by reference the GEIS conclusions that the impacts to waste 

management during construction are expected to be SMALL. Furthermore, the NRC staff has 

not identified any new and significant information during its independent review that would 

change the environmental impacts estimated in the GEIS. 

4.14.1.1.2 Operation Impacts 

Section 2.7 of the GEIS indicated that wastes generated during the operations phase would 

primarily be liquid waste streams consisting of process bleed (1 to 3 percent of the process flow 

rate). Wastes would also be generated from flushing of eluant to limit impurities, resin transfer 
Environmental Impacts and Mitigative Actions 

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wash, filter washing, uranium precipitation process wastes, and plant washdown water. The 

method used to handle and process these wastes (disposal by deep well injection) reduces the 

solid waste volume that must be disposed of at an approved facility. State permitting actions, 

NRC license conditions, and NRC inspections ensure proper practices would be used to comply 

with safety requirements to protect workers and the public; therefore, the waste management 

impact would be SMALL (NRC, 2009a). 

At the proposed Moore Ranch Project, liquid wastes from operations (Section 2.1.1.1.6.2) are 

classified as byproduct material and would be disposed of via deep well injection, which is 

regulated by WDEQ. The WDEQ permit and approval process would specify the concentrations 

of hazardous constituents to maintain acceptable safe levels for discharge through deep well 

injection and to ensure the feasibility of deep well disposal in the selected geologic formations. 

Proper installation and operating procedures would be used to ensure adequate protection of 

the public and environmental health and safety. Class I disposal wells are designed to protect 

all potentially useable underground sources of drinking water, and injection of liquid waste 

would isolate liquid effluent from the accessible environment. By definition, the WDEQ could 

not issue a permit for Class I injection if a complete exposure pathway existed that could result 

in public consumption. 

Nonhazardous solid wastes generated during operations could include facility trash, septic 

solids, and other uncontaminated solid wastes (e.g., piping, valves, instrumentation, and 

equipment). As appropriate, solid wastes would be reused, recycled, or disposed of at the 

Casper landfill, as discussed in Section 3.13.2. The potential impact would be SMALL because 

a small volume of material would be disposed of in comparison to the size of the Casper landfill. 

This is consistent with the discussion of solid waste generation and disposal impacts in 

the GEIS. 

Solid byproduct material that could be generated during operations (i.e., material that does not 

meet NRC criteria for unrestricted release) would likely include maintenance and housekeeping 

rags and trash, packing materials, replacement components, filters, protective clothing, and 

solids removed from process pumps and vessels. The applicant has estimated approximately 

77 m3

 [100 yd3] of this solid byproduct material would be generated per year and stored onsite 

within a restricted area until sufficient volume was generated for disposal. The applicant has 

identified the Pathfinders Mines Corporation–Shirley Basin site, located approximately 213 km 

[132 mi] from the proposed Moore Ranch Project, for disposal of byproduct material. The 

applicant is negotiating an NRC-required preoperational disposal agreement with the Pathfinder 

Mines facility. The applicant has identified the Energy Solutions disposal site in Clive, Utah, as 

an alternate location, and is also negotiating a disposal agreement with this site, as a 

contingency measure (Uranium One, 2010). Based on the disposal options currently available, 

and the disposal agreement that NRC requires prior to operations, the staff concludes that the 

potential waste management impacts associated with the generation of byproduct material 

would be SMALL. 

As discussed in Section 2.1.1.1.6.3, the applicant indicated that it would likely be classified as a 

Conditionally Exempt Small Quantity Generator (CESQG) of hazardous waste. A CESQG: 

(1) must determine if their waste is hazardous; (2) must not generate more than 100 kilograms 

of hazardous waste per month or, except with regard to spills, more than 1 kilogram of acutely 

hazardous waste; (3) may not accumulate more than 1,000 kilograms of hazardous waste 

onsite at any time; and (4) must treat or dispose of their hazardous waste either in a nonsite or 

offsite U.S. treatment storage or disposal facility that meets specific requirements of 
Environmental Impacts and Mitigative Actions 

4-81 

40 CFR 261.5. The applicant would transport its hazardous wastes to the Casper landfill 

special waste and diversion facility (Uranium One, 2010). 

Based on the type and quantity of expected waste generation, and the availability of disposal 

options, the operations phase of the proposed Moore Ranch Project would have a SMALL 

impact on waste management. 

Furthermore, the NRC staff has not identified any new and significant information during its 

independent review that would change the environmental impacts estimated in the GEIS. 

4.14.1.1.3 Aquifer Restoration Impacts 

Section 4.3.12.3 of the GEIS discussed waste management activities that would occur during 

the aquifer restoration phase of an ISR project and noted that the same treatment and disposal 

options would be implemented as used during operations. Therefore, the waste management 

impacts would be similar to that during the operations phase of an ISR project. Some increase 

in wastewater volumes could be experienced, but the increase in volume would be offset by the 

decrease in production capacity. The impact to waste management from aquifer restoration 

would be SMALL. 

At the proposed Moore Ranch Project, produced water from aquifer restoration 

(Sections 2.1.1.1.4.1.2; and 2.1.1.1.6.2) would be treated through the combination of ion 

exchange and reverse osmosis processes and injected back into the production aquifer. The 

proposed water treatment and reinjection into the aquifer would help limit the amount of water 

that is permanently withdrawn from the production aquifer. The concentrated waste solutions 

resulting from this treatment would be classified as byproduct material and would be disposed of 

in the deep disposal wells. The potential impacts associated with the use of the deep disposal 

wells during aquifer restoration would be the same as previously discussed for the operations 

phase in Section 4.14.1.1.2. Other waste management activities during aquifer restoration 

would also be similar to what is done for the operations phase, and therefore impacts would be 

SMALL. Furthermore, the NRC staff has not identified any new and significant information 

during its independent review that would change the environmental impacts estimated in 

the GEIS. 

4.14.1.1.4 Decommissioning Impacts 

Section 2.6 of the GEIS indicated wastes generated from decommissioning an ISR facility would 

be predominantly byproduct material and nonhazardous solid waste (NRC, 2009a, Section 2.6). 

Section 4.3.12.4 of the GEIS stated that decommissioning byproduct material (including 

contaminated facility demolition materials, process and wellfield equipment, and contaminated 

soils) would be disposed of at a licensed facility (NRC, 2009a). As discussed previously, NRC 

requires a preoperational agreement with a licensed disposal facility to accept radioactive 

wastes to ensure that sufficient disposal capacity is available for byproduct material generated 

by decommissioning activities. Safe handling, storage, and disposal of decommissioning 

wastes would be addressed in a decommissioning plan required for NRC review prior to the 

initiation of decommissioning. The decommissioning plan would describe how a 10 CFR Part 

20-compliant radiation safety program would be implemented to ensure the safety of workers 

and the public. The GEIS concluded that volumes of radioactive, chemical, and solid wastes 

generated during decommissioning would be SMALL, and the waste management impacts 

would also be expected to be SMALL (NRC, 2009a). 
Environmental Impacts and Mitigative Actions 

4-82 

For decommissioning the proposed Moore Ranch ISR facility, the applicant proposes to recycle 

or reuse a large portion of the process equipment and materials. Materials would be surveyed 

for residual radioactivity. Materials that are not radiologically contaminated or that meet NRC 

release limits would be removed for reuse, recycling, or disposal. Contaminated materials 

would be decontaminated, transferred to another licensed facility for use, or disposed of as 

byproduct material. The NRC staff expects the applicant proposed use of wellfield monitoring 

instrumentation and wellfield visual inspection to support timely identification and remediation of 

potential leaks and spills, thereby reducing the potential for generating large volumes of 

contaminated soil that would need to be excavated and disposed of as byproduct material at a 

licensed facility. Any hazardous wastes generated during decommissioning would be stored, in 

accordance with WDEQ regulations, and transported to the Casper landfill special waste and 

diversion facility for proper disposal (Uranium One, 2010). 

As discussed in Section 2.1.1.1.6.3, the staff’s cumulative estimate for byproduct material from 

decommissioning the plant facilities and all wellfields (over a planned 2 year period) is 

11,010 m3 [14,390 yd3

] plus 512 t [565 T] of concrete. This estimate is above the 

decommissioning byproduct material volume evaluated in the GEIS. As discussed in the draft 

SEIS Section 2.1.1.1.6.3, the applicant does not presently have an agreement in place with a 

licensed site to accept its solid byproduct material for disposal. The applicant preferred 

destination for disposal of byproduct material is at the Pathfinder-Shirley Basin site in Mills, 

Wyoming. If that facility does not have sufficient capacity at the time the request for an 

agreement is made, then the applicant could engage other low-level radioactive waste disposal 

facilities that are licensed to accept byproduct material. Another existing NRC-licensed facility 

to accept byproduct material for disposal is the Rio Algom Ambrosia Lake uranium mill tailings 

impoundments near Grants, New Mexico. Additionally, three sites are licensed by NRC 

Agreement States to accept byproduct material for disposal (i.e., the Energy Solutions site in 

Clive, Utah; the White Mesa uranium mill site in Blanding, Utah; and the Waste Controls 

Specialists site in Andrews, Texas). Based on the disposal options currently available, and the 

disposal agreement that NRC requires prior to operations, NRC concludes that the potential 

waste management impacts associated with the generation of byproduct material would 

be SMALL. 

The staff’s cumulative estimate of nonhazardous solid waste that would be generated from 

decommissioning is 482 m3

 [630 yd3] plus 6,102 t [6,730 T] of concrete. This material would be 

generated in a single year when the plant facilities are decommissioned. Assuming 1.96 T/yd3

for the concrete waste, the annual solid waste volume would be approximately 4,064 yd3

. This 

estimated volume of solid waste is higher than what was analyzed in the GEIS and, therefore, 

the NRC staff considered additional site-specific information to evaluate potential impacts. 

While local disposal capacity is limited based on the planned closing of the Midwest-Edgerton 

landfill in year 2010, that facility has been permitted to continue to accept waste and transfer the 

material to a much larger regional balefill facility (i.e., a landfill that bales the waste) near 

Casper, Wyoming, in Natrona County. Considering year 2005 estimates of waste disposed of at 

the Casper balefill from the Wyoming Office of State Lands and Investments (2007) of 93,804 t 

[103,466 T], the aforementioned cumulative decommissioning nonhazardous solid waste 

volume resulting from the proposed action would constitute approximately 4 percent of the 

annual volume of waste disposed at the Casper balefill. Based on this comparison, the NRC 

staff concludes the region has sufficient capacity to dispose of the nonhazardous solid waste 

generated from the proposed action. Therefore, the waste management impacts for disposal of 

decommissioning nonhazardous solid waste would be SMALL. 
Environmental Impacts and Mitigative Actions 

4-83 

4.14.1.2 Alternative Wastewater Disposal Options 

In most of the alternative wastewater disposal options considered in the following sections, the 

footprint of the disposal system would increase, as compared to disposal via a UIC Class I 

injection well (Section 4.14.1.1). Increasing the size of the proposed facility would lead to more 

land disturbance and a heavier use of construction equipment, with an anticipated increase in 

potential impacts to resource areas such as ecological and wetland systems, cultural and 

historical resources, and nonradiological air quality. The applicant would have to amend their 

license application to select one of these alternative wastewater disposal options. The NRC 

would perform an additional environmental and safety review prior to deciding whether to grant 

or deny the licensing application with the new wastewater disposal option. The applicant would 

survey the areas to be affected prior to construction, and the applicant and NRC would consult 

with agencies such as the Wyoming SHPO, the WGFD, and the FWS. Mitigation measures, 

such as avoidance of sensitive areas or documentation of cultural resources, would be 

established as part of these consultations, as necessary. With these mitigation measures in 

place, it is anticipated that potential adverse impacts would be SMALL. 

4.14.1.2.1 Evaporation Ponds 

The types of waste streams and the infrastructure necessary for using evaporation ponds as a 

wastewater disposal option are described in Section 2.1.1.2. The types and amounts of 

wastewater that would be disposed in an evaporation pond would be the same as described in 

the previous section for disposal by deep injection into a Class I UIC well. Before the applicant 

could begin disposing wastewater into an evaporation pond system, the NRC staff would 

review the design and construction of the ponds and monitoring system against the criteria in 

10 CFR Part 40, Appendix A (NRC, 2003; 2008), taking into consideration EPA criteria in 

40 CFR Part 61, Subpart W. The applicant would be required to demonstrate that the 

evaporation ponds could be designed, operated, and decommissioned to prevent migration of 

wastewater to subsurface soil, surface water, or groundwater. Applicants would also be 

required to demonstrate that monitoring requirements would be established to detect any 

migration of contaminants to the groundwater. The NRC staff would establish any license 

conditions needed to ensure that the applicant meets the necessary requirements. 

Individual evaporation ponds could have a surface area of up to 2.5 ha [6.25 ac], and the total 

pond system could be as much as 40 ha [100 ac]. During the period of operations for the 

proposed Moore Ranch ISR facility, this area would be fenced to exclude wildlife and livestock. 

This would provide a footprint that is less than about 1.5 percent of the total permitted area 

{2,873 ha [7,100 ac]} for the proposed Moore Ranch ISR facility, but it would be much larger 

than the footprint {2.4 ha [6 ac]} for a central processing plant without evaporation ponds 

(see Section 4.2.1). The additional land disturbance required to install an evaporation pond 

system for wastewater disposal would be similar in scale to the current proposed action {61 ha 

[150 ac]} for the proposed Moore Ranch ISR facility (Section 4.2.1). It is also anticipated that 

the applicant would need to have at least one other wastewater disposal option or additional 

storage capacity during the winter months in Wyoming when evaporation rates would be low. 

Although a wastewater disposal option that uses an evaporation pond system would roughly 

double the facility footprint relative to UIC Class I injection wells, the total amount of disturbed 

and fenced land would be small compared to the permitted area and comparable to the generic 

conditions evaluated in the GEIS with respect to land use. For these reasons, the overall 

impacts to land use associated with an evaporation pond system would be SMALL. 
Environmental Impacts and Mitigative Actions 

4-84 

Construction of an evaporation pond system would require earthmoving equipment such as 

bulldozers, backhoes, and trucks, and to prepare the site and construct the impoundment. The 

equipment would produce diesel emissions and fugitive dust emissions during construction that 

could have a temporary and adverse effect on nonradiological air quality. Depending on how 

the applicant elected to phase in the pond system, these effects could extend into the 

operational phase of the facility as well. BMP such as wetting unpaved roads would 

minimize fugitive dust, and the anticipated impacts to nonradiological air quality would be 

SMALL. The applicant may also need to obtain a National Emission Standards for Hazardous 

Air Pollutants review to evaluate whether the anticipated radiological releases to air from the 

evaporation ponds would meet the criteria in 40 CFR Part 61, Subpart W. The applicant would 

also be required to have an NRC-approved air monitoring system for the wastewater disposal 

system. Keeping the pond wet to reduce dust and radon emissions would effectively reduce 

potential air emissions, and the anticipated impacts to radiological air quality would be SMALL. 

As described in NRC (2008), the evaporation ponds would be designed and constructed with 

clay or geotextile liners to reduce the potential for infiltration into the subsurface. An 

NRC-approved monitoring system would be installed to detect leaks from the ponds, and the 

applicant would also implement an NRC-approved inspection plan for the ponds (NRC, 2008). 

Based on these measures, it is anticipated that potential impacts to surface water and 

groundwater resources would be SMALL. As described in Section 4.6, the proposed Moore 

Ranch Project with one or more UIC Class I injection wells could potentially have MODERATE 

impacts on avian species of concern. A wastewater disposal option that uses an evaporation 

pond system would roughly double the facility footprint. The evaporation ponds, however, 

would be constructed at the same time and with the same mitigation measures described in 

Section 4.6 for the construction of the rest of the facility. Additional measures such as netting 

could be used to prevent birds from landing on the ponds. For these reasons, the potential 

impact from an evaporation pond disposal system would be the same as identified in 

Section 4.6 and could be reduced to SMALL. 

At the end of the operational phase of the facility, all of the pond liners and berms, as well as 

accumulated precipitates and sludges, would be classified as solid byproduct material. For 

example, the GEIS indicates that about 52 m3

 [68 yd3] of byproduct material would be generated 

during evaporation pond decommissioning. These solids would need to be transported to a 

licensed facility for disposal as part of the decommissioning program. This would increase the 

total amount of byproduct decommissioning wastes, increasing the number of truck trips needed 

to transport the materials to a disposal facility. Given the potential limitations on available 

byproduct waste disposal capacity in the local area, it is anticipated that the impacts from an 

evaporation pond wastewater disposal system to waste management would be SMALL to 

MODERATE during the decommissioning phase of the facility. It is important to note that at the 

conclusion of operations, the licensee would be required to provide a decommissioning plan for 

NRC review that demonstrates it has a disposal path for any decommissioning wastes, including 

those related to the wastewater disposal system. The NRC staff would conduct detailed 

technical and environmental reviews of the proposed decommissioning program for the facility 

at that time. 

4.14.1.2.2 Land Application 

For the land application of process wastewater, the applicant would be required to meet the 

regulatory provisions in 10 CFR Part 20, Subparts D, K, and Appendix B (NRC, 2003). The 

applicant would also be required to analyze the chemical toxicity of radioactive and 
Environmental Impacts and Mitigative Actions 

4-85 

nonradioactive constituents, including an assessment of projected concentrations of radioactive 

contaminants in the soil and projected impacts on groundwater and surface-water quality and on 

land uses, especially crops and vegetation. The applicant would also be required to obtain NRC 

approval of a monitoring program that would include periodic soil surveys to verify that 

contaminant levels in the soil would not exceed those projected, and it should also include a 

remediation plan that can be implemented if projected levels are exceeded. The applicant 

would also need to treat the wastewater to quality requirements for surface discharge under a 

WYPDES permit from WDEQ. Finally, the applicant would also need to demonstrate that the 

soils in the land application area would meet the criteria in 10 CFR Part 40, Appendix A, at the 

time of decommissioning. Practices would be subject to NRC license conditions and enforced 

through the NRC inspection program to ensure protection of public health and safety and 

the environment. 

Land application typically requires large areas to ensure that soil concentrations do not exceed 

regulatory levels. Typical land application areas are on the order of about 40 ha [100 ac]. 

During the period of operations for the proposed Moore Ranch ISR facility, this area would be 

fenced to exclude wildlife and livestock. Like a wastewater disposal system using evaporation 

ponds, land application would provide a footprint that is less than about 1.5 percent of the total 

permitted area {2,873 ha [7,100 ac]} for the proposed Moore Ranch ISR facility, but it would be 

much larger than the footprint {2.4 ha [6 ac]} described in the proposed action (Section 4.2.1) for 

a central processing plant without land application (Uranium One, 2009). The additional land 

disturbance required to install a land application system for wastewater disposal would be 

similar in scale to the current proposed action {61 ha [150 ac]} for the proposed Moore Ranch 

ISR facility (Section 4.2.1). It is also anticipated that the applicant would need to have at least 

one other wastewater disposal option or additional storage capacity during the winter months in 

Wyoming when evaporation rates would be low and the ground would be covered by snow. 

Like the evaporation pond system discussed in the previous section, a wastewater disposal 

option that uses land application would roughly double the facility footprint relative to the 

proposed action using UIC Class I injection wells. The amount of disturbed and fenced land, 

however, would be small compared to the permitted area and comparable to the generic 

conditions evaluated in the GEIS with respect to land use. For these reasons, the overall 

impacts to land use associated with w2astewater disposal by land application would be SMALL. 

Establishing the land application area would not require extensive use of earthmoving 

equipment other than to install pipelines, small berms, access roads, and fencing, and the 

potential impacts to land use would be anticipated to be SMALL. The wastewater, however, 

would likely require additional treatment to meet WYPDES standards, including facilities such as 

an IX circuit, reverse osmosis, one or more radium settling basins {0.1 to 1.6 ha 0.25 to [4 ac]}, 

purge storage reservoirs {4 ha [10 ac] or more}. Constructing these treatment facilities, basins, 

and storage reservoirs would require earth moving equipment such as bulldozers, scrapers, 

backhoes, and trucks to prepare the site and construct the impoundments. The equipment 

would produce diesel emissions and fugitive dust emissions during construction that could have 

a temporary and adverse effect on nonradiological air quality. BMP such as wetting unpaved 

roads would minimize fugitive dust, and the anticipated impacts to nonradiological air quality 

would be SMALL. The applicant may also need to consider potential radiological releases to air 

from the land application area(s). Given the low radionuclide content anticipated for the 

wastewater, and low calculated radon fluxes for similar application areas (NRC, 1997, 2003b), 

the anticipated impacts to radiological air quality would be SMALL. As described in Section 4.6, 

the proposed Moore Ranch Project with one or more UIC Class I injection wells could potentially 

have MODERATE impacts on avian species of concern. A wastewater disposal option that 
Environmental Impacts and Mitigative Actions 

4-86 

uses a land application system would roughly double the facility footprint. The land application 

system, however, would be constructed at the same time with the same mitigation measures 

described in Section 4.6 for the construction of the rest of the facility. For these reasons, the 

potential impact associated with wastewater disposal by land application would be the same as 

identified in Section 4.6 and could be reduced to SMALL. 

As described previously, the applicant would be required to demonstrate that the soil in a land 

application area would meet 10 CFR Part 20 requirements. In addition, during operations the 

applicant would be required to routinely monitor the soil to ensure that predicted concentrations 

were not exceeded. For these reasons, it is not anticipated that decommissioning the land 

application area would produce any additional solid byproduct material for disposal, and the 

potential impacts on waste management would be SMALL during the decommissioning phase 

of the facility. For decommissioning the wastewater treatment facility, all pond liners and berms 

associated with radium settling basin(s), as well as accumulated precipitates and sludges 

generated at an estimated rate annual of about 22.4 m3

/yr [29.3 yd3/yr] (see Section 2.1.1.2.2), 

would be classified as solid byproduct material. These solids, as well as any other solid 

byproduct material generated by the wastewater treatment process (e.g., spent resins, 

contaminated building debris) would need to be transported to a licensed facility for disposal as 

part of the decommissioning program. This would increase the total amount of byproduct 

decommissioning wastes, increasing the number of truck trips needed to transport the materials 

to a disposal facility. Given the potential limitations on available byproduct waste disposal 

capacity, the potential impacts to waste management from decommissioning the radium-settling 

basin(s) and other storage facilities associated with treating wastewater for disposal by land 

application would be SMALL to MODERATE. 

It is important to note that at the conclusion of proposed operations, the licensee would be 

required to provide a plan for decommissioning any wastewater treatment facilities for NRC 

review (NRC, 2003b). The decommissioning plan would include final radiological surveys to 

identify whether there were any areas of soil contamination that would require disposal as 

byproduct material. The NRC staff would conduct detailed technical and environmental reviews 

of the proposed decommissioning program for the facility at that time. 

4.14.1.2.3 Surface Water Discharge 

For the surface discharge wastewater, the applicant would be required to meet the regulatory 

provisions in 10 CFR Part 20, Subparts D, K, and Appendix B. The applicant would also be 

required to obtain a zero-release WYPDES permit from WDEQ. The applicant would be 

required to distinguish between “process wastewater” generated during uranium recovery 

operations, and “mine wastewater” generated during aquifer restoration (NRC, 2003b). In 

accordance with EPA regulations, the applicant would not be allowed to discharge “process” 

wastewater to navigable waters of the United States (NRC, 2003a). The applicant would either 

need to develop storage capabilities depending on whether it intended to maintain separate 

wastewater streams, or commingle (mix) “process” and “mine” wastewater prior to treatment to 

10 CFR Part 20 standards. In addition, the applicant would need to address any radioactivity at 

the discharge point or from storage facilities (tanks, impoundments), radium-settling basins, and 

related liners and sludges as part of the decommissioning of the facility (NRC, 2003b; Cohen 

and Associates, 2008b). 

Establishing the discharge point for the treated effluent would be likely to require short-term use 

of earthmoving equipment to install pipelines, small berms, access roads, and fencing to 
Environmental Impacts and Mitigative Actions 

4-87 

exclude livestock and wildlife. The amount of land to be fenced for the discharge point alone 

would be limited (see Section 2.1.1.2), and the potential impacts to land use would be 

anticipated to be SMALL. As is the case with land application, however, the wastewater would 

likely require additional treatment to meet WYPDES zero-release permit requirements, including 

facilities such as an IX circuit, reverse osmosis, one or more radium settling basins {0.1 to 1.6 

ha [0.25 to 4 ac]}, purge storage reservoirs {4 ha [10 ac] or more}. These treatment facilities 

would also be fenced to exclude wildlife and livestock and limit access to the public. The 

amount of land needed for the wastewater treatment facilities would be similar to that for land 

application, but if the applicant chose to segregate “process” and “mine” wastewaters to meet 

the WYPDES permit requirements, the involved land area would be greater, to provide separate 

storage facilities. As with evaporation ponds and land application, the increased footprint of the 

additional wastewater treatment facilities needed to meet WYPDES requirements would be 

small relative to the entire permitted area {2,873 ha [7,100 ac]}, but large relative to the 2.4 ha 

[6 ac], for a central processing plant as described in the proposed action (Section 4.2.1) 

(Uranium One, 2009a,b). The current proposed action identifies about 61 ha [150 ac] of 

disturbed land for the proposed Moore Ranch ISR facility. Overall, the increase in the amount 

of disturbed land to accommodate the addition of a wastewater treatment facility would be about 

10 to 20 percent, and would have a SMALL impact on land use. 

Constructing the wastewater treatment facilities (e.g., radium-settling basins) would require 

earthmoving equipment such as bulldozers, backhoes, trucks, and to prepare the site and 

construct the impoundment(s). The equipment would produce diesel emissions and fugitive 

dust emissions during construction that could have a temporary and adverse effect on 

nonradiological air quality. BMP such as wetting unpaved roads would minimize fugitive dust. 

Taking into consideration the likely short-term duration of the construction period, the 

anticipated impacts to nonradiological air quality would be SMALL. The applicant may also 

need to consider emissions of radionuclides such as radon from the surface discharge points. 

Given that the WYPDES permit would require the applicant to monitor and maintain low 

radionuclide concentrations for the treated wastewater, the anticipated impacts to radiological 

air quality would be SMALL. 

The proposed Moore Ranch ISR facility and any surface water discharge points would be 

entirely within the Antelope Creek drainage basin (Section 3.5.1.4). This drainage basin is 

classified by WDEQ as a Class 3B surface water, with no known fish populations or use as a 

drinking water supply. However, surface water discharge would create more reliable water flow, 

and could lead to the development of aquatic habitat, and surface discharge could lead to an 

increase in erosion and suspended sediments in existing stream channels. Sediment loads 

would be expected to taper off quickly both in time and distance; therefore, long-term impacts 

would be SMALL. The applicant would use WFGD standard management practices to limit 

impacts to aquatic life. 

As noted previously, the applicant would not be allowed to discharge treated wastewater into 

navigable waters of the United States. The disconnected and isolated nature of existing ponds 

and wetlands systems in the vicinity of the proposed Moore Ranch ISR facility are not 

considered jurisdictional waters under Section 404 of the Clean Water Act because there is no 

connection to navigable waters. However, surface discharge of treated wastewater could create 

a more continuous system, and the applicant would need to obtain the necessary jurisdictional 

determination and permits from the USACE. 
Environmental Impacts and Mitigative Actions 

4-88 

The applicant would be required to demonstrate that any soil affected by the surface discharge 

of treated wastewater would meet 10 CFR Part 20 requirements. In addition, during operations, 

the applicant would be required to routinely monitor the soils and discharged water to ensure 

that predicted concentrations were not exceeded. For these reasons, it is not anticipated that 

decommissioning the surface discharge point would produce any additional solid byproduct 

material for disposal, and the potential impacts on waste management would be SMALL during 

the decommissioning phase of the facility. As with the land application wastewater disposal 

option, however, decommissioning wastewater treatment facilities may produce solid byproduct 

materials such as spent resins, sludges and liners from radium-settling basin(s), or 

contaminated building debris. These solids would need to be transported to a licensed facility 

for disposal as part of the decommissioning program. This would increase the total amount of 

byproduct decommissioning wastes, increasing the number of truck trips needed to transport 

the materials to a disposal facility. Given the potential limitations on available byproduct waste 

disposal capacity, it is anticipated that the potential impacts to waste management from 

decommissioning the radium settling basin(s) and other storage facilities associated with 

treating wastewater for surface water discharge would be SMALL to MODERATE. 

It is important to note that at the conclusion of operations, the licensee would be required to 

provide a plan for decommissioning any wastewater treatment facilities for NRC review 

(NRC, 2003b). The decommissioning plan would include final radiological surveys to identify 

whether there were any areas of soil contamination that would require disposal as byproduct 

material. The NRC staff would conduct detailed technical and environmental reviews of the 

proposed decommissioning program for the facility at that time. 

4.14.1.2.4 Class V Injection Well 

The potential impacts associated with wastewater disposal through a UIC Class V deep 

injection well would be similar to those associated with the proposed action (Disposal via a UIC 

Class I deep injection well). Under the terms of a UIC Class V permit issued by WDEQ, 

however, the wastewater would require additional treatment to meet class of use or federal 

drinking water standards (whichever is more stringent) prior to injection. 

The potential impacts associated with constructing, operating, and decommissioning the 

necessary wastewater treatment facilities would be similar to those described in the 

previous sections for land application (Section 4.14.1.2.2) and surface water discharge 

(Section 4.14.1.2.3) disposal options. For example, although the footprint of the Class V well 

itself would be small {0.1 ha [0.25 ac]}, the wastewater would likely require additional treatment 

to meet the necessary discharge requirements (Class of Use or Federal drinking water 

standards). This treatment would require facilities such as an IX circuit, reverse osmosis, one or 

more radium settling basins {0.1 to 1.6 ha [0.25 to 4 ac]}, and purge storage reservoirs {4 ha [10 

ac] or more}. These treatment facilities would be fenced to exclude wildlife and livestock and 

limit access of the public. The amount of land needed for the wastewater treatment facilities 

would be similar to that for land application or surface discharge. The increased footprint of the 

additional wastewater treatment facilities would be small relative to the entire permitted area 

{2,873 ha [7,100 ac]}, but large relative to the 2.4 ha [6 ac], for a central processing plant as 

described in the proposed action (Section 4.2.1) (Uranium One, 2009a,b). The current 

proposed action identifies about 61 ha [150 ac] of disturbed land for the proposed Moore Ranch 

ISR facility. Overall, the increase in the amount of disturbed land to accommodate addition of a 

wastewater treatment facility would be about 10 to 20 percent and would have a SMALL impact 

on land use. 
Environmental Impacts and Mitigative Actions 

4-89 

Constructing the wastewater treatment facilities (e.g., radium-settling basins) would require 

earth moving equipment such as bulldozers, backhoes, trucks, and to prepare the site and 

construct the impoundment(s). The equipment would produce diesel emissions and fugitive 

dust emissions during construction that could have a temporary and adverse effect on 

nonradiological air quality. BMP such as wetting unpaved roads would minimize fugitive dust. 

Taking into consideration the likely short-term duration of the construction period, the 

anticipated impacts to nonradiological air quality would be SMALL. The applicant may also 

need to consider emissions of radionuclides such as radon during the wastewater treatment 

process. These emissions would be included as part of the NRC-approved monitoring plan for 

the facility, and the anticipated impacts to radiological air quality would be SMALL. 

As with the land application and surface discharge wastewater disposal options, the solid 

wastes generated by decommissioning wastewater treatment facilities associated with a UIC 

Class V injection well, such as piping, spent resins, sludges, and liners from radium settling 

basin(s), or contaminated building debris would need to be disposed as byproduct material. 

These solids would need to be transported to a licensed facility for disposal as part of the 

decommissioning program. This would increase the total amount of byproduct 

decommissioning wastes, increasing the number of truck trips needed to transport the materials 

to a disposal facility. Given the potential limitations on available byproduct waste disposal 

capacity, it is anticipated that the potential impacts to waste management from 

decommissioning the radium-settling basin(s) and other storage facilities associated with 

treating wastewater for surface water discharge would be SMALL to MODERATE. 

It is important to note that at the conclusion of operations, the licensee would be required to 

provide a plan for decommissioning any wastewater treatment facilities for NRC review 

(NRC, 2003). The decommissioning plan would include final radiological surveys to identify 

whether there were any areas of soil contamination that would require disposal as byproduct 

material. The NRC staff would conduct detailed technical and environmental reviews of the 

proposed decommissioning program for the facility at that time. 

4.14.2 No-Action (Alternative 2) 

Under the No-Action alternative no radioactive or nonradioactive liquid or solid waste would be 

generated because the proposed Moore Ranch Project would not be licensed. No earthmoving 

activities that could result in the generation of nonhazardous solid waste would occur, no 

buildings would be constructed, no wellfields would be developed, and no wastewater would be 

injected into the subsurface. No arrangements would be made for the management of 

any wastes. 

4.15 References 

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

Protection Against Radiation.” 
Environmental Impacts and Mitigative Actions 

4-90 

10 CFR Part 40. Appendix A. Code of Federal Regulations, Title 10, Energy, Part 40, 

Appendix A, “Criteria Relating to the Operations of Uranium Mills and to the Disposition of 

Tailings or Wastes Produced by the Extraction or Concentration of Source Material from Ores 

Processed Primarily from their Source Material Content.” 

40 CFR Part 144. Code of Federal Regulations, Title 144, Protection of Environment, Part 144, 

“Underground Injection Control Program.” 

40 CFR Part 146. Code of Federal Regulations, Title 40, Protection of Environment. Part 146, 

“Underground Injection Control Program: Criteria and Standards.”

69 FR 52040, 2004. “Policy Statement on the Treatment of Environmental Justice matters in 

NRC Regulatory and Licensing Actions.” Federal Register. Vol. 69, No. 163. August 24. 

Argonne National Laboratory, 1989. “MILDOS-AREA (Computer Code)–Calculation of 

Radiation Dose from Uranium Recovery Operations for Large-Area Sources.” Argonne, Illinois: 

Argonne National Laboratory. 

BLM (U.S. Bureau of Land Management, 2010. Instruction Memorandum No. 2010-071. 

“Subject: Gunnison and Greater Sage-grouse Management Considerations for Energy 

Development (Supplement to National Sage-Grouse Habitat Conservation Strategy).” 

Washington, DC: U.S. Department of Interior Bureau of Land Management. March 5. 

BLM, 2008a. “Proposed Resource Management Plan and Final Environmental Impact 

Statement for Public Lands Administered by the Bureau of Land Management, Rawlins Field 

Office.” Rawlins, Wyoming. U.S. Department of Interior, BLM, Rawlins Field Office. January 

2008. 

BLM, 2008b. “Bureau of Land Management Buffalo Field Office Environmental Assessment for 

Yates Petroleum Corporation All Day POD Plan of Development WY-070-08-026.” Cheyenne, 

Wyoming: BLM. August 28. 

BLM. 2007. “Visual Resource Management.” Manual 8400. Washington, DC: BLM. 

<http://www.blm.gov/nstc/VRM/8410.html>. 

BLM, 2004. “National Sage-Grouse Habitat Conservation Strategy.” November. 

<http://www.blm.gov/pgdata/etc/medialib/blm/wo/Planning_and_Renewable_Resources/fish__w

ildlife_and.Par.9151.File.dat/Sage-Grouse_Strategy.pdf>. 

BLM, 2003. “Final Environmental Impact Statement and Proposed Amendment for the Powder 

River Basin Oil and Gas Project (WY–070–02–065).” January. 

Brunette, J.A., 2007. “Class III Cultural Resources Inventory for the Energy Metals Corporation, 

Moore Ranch In-Situ Uranium Project.” (nonpublic due to sensitive information on cultural 

resources). 

Center for Climate Strategies, 2007. “Wyoming Greenhouse Gas Inventory and Reference 

Case Projections 

1990–2020.” Cheyenne, Wyoming: Center for Climate Strategies. 
Environmental Impacts and Mitigative Actions 

4-91 

CEQ (Council of Environmental Quality, 1997. “Environmental Justice Guidance under the 

National Environmental Policy Act.” Executive Office of the President. December. 

Cohen and Associates, 2008. “Final Report Review of Existing and Proposed Tailings 

Impoundment Technologies.” Vienna, Virginia: S. Cohen and Associates. 

<http://www.epa.gov/radiation/docs/neshaps/subpart-w/tailings-impoundment-tech.pdf> 

<25 May 2010>. 

EMC (Energy Metals Corporation U.S.), 2007a. “Application for USNRC Source Material 

License, Moore Ranch Uranium Project, Campbell County, Wyoming, Environmental Report.” 

Casper, Wyoming: Uranium 1 Americas Corporation. ADAMS Accession Nos. ML072851222, 

ML072851229, ML072851239, ML07285249, ML07285253, and ML07285255. October 12. 

EMC, 2007b. “Application for USNRC Source Material License, Moore Ranch Uranium Project, 

Campbell County, Wyoming, Technical Report.” Casper, Wyoming: Uranium 1 Americas 

Corporation. ADAMS Accession Nos. ML072851222, ML072851258, ML072851259, 

ML072851260, ML072851268, ML072851350, ML072900446. October 12. 

EPA (U.S. Environmental Protection Agency), 2010. “SCRAM Mixing Height Data: Wyoming.” 

Washington DC: EPA. <http://www.epa.gov/scram001/mixingheightdata.htm> (07 June 2010). 

EPA, 2009. “Global Greenhouse Gas Data.” <http://www.epa.gov/climatechange/ 

emissions/globalghg.html.> (15 December 2009). ADAMS No. ML100221499. 

FWS (U.S. Fish and Wildlife Service, 2008. “Response to Request for Additional Information 

Regarding Endangered or Threatened Species and Critical Habitat for the Proposed License 

Application for Energy Metals Corporation’s Moore Ranch Uranium Recovery Project.” ADAMS 

Accession No. ML081420589. May 7. 

Griffin, M., 2009. <mike.griffin@uranium1.com>”Phases of the Moore Ranch Project” 28 

September 2009 [email communication]. ADAMS Accession No. ML092720144. 

(28 September 2009). 

Mackin, P.C., D. Daruwalla, J. Winterle, M. Smith, and D.A. Pickett, 2001. NUREG/CR–6733, 

“A Baseline Risk-Informed Performance-Based Approach for In-Situ Leach Uranium Extraction 

Licensees.” Washington, DC: NRC. September. 

National Fire Protection Association, 2001. “NFPA 50: Standard for Bulk Oxygen Systems at 

Consumer Sites.” 

NRC (U.S. Nuclear Regulatory Commission), 2009a. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

NRC, 2009b. “Staff Assessment of Groundwater Impacts from Previously Licensed In-Situ

Uranium Recovery Facilities.” Memorandum from C. Miller to Chairman Jaczko, et al. ADAMS 

Accession No. ML091770402. July 10. 

NRC, 2009c. Memo to A. Kock, Branch Chief, from I. Yu, B. Shroff, and A. Bjornsen, Project 

Managers, Office of Federal and State Materials and Environmental Management Programs. 

“Subject: Informal Meetings with Local, State, and Federal Agencies in Wyoming Regarding the 
Environmental Impacts and Mitigative Actions 

4-92 

Environmental Reviews Being Conducted on the Moore Ranch, Nichols Ranch, and Lost Creek 

In-Situ Leach Applications for Source Material Licenses (Docket Nos. 040-09073, 040-09067, 

040-09068.” ADAMS Accession No. ML090500544. March 2. 

NRC, 2008. Regulatory Guide 3.11, “Design, Construction, and Inspection of Embankment 

Retention Systems at Uranium Recovery Facilities.” Washington, DC: NRC. November. 

NRC, 2003a. NUREG–1748, “Environmental Review Guidance for Licensing Actions 

Associated With NMSS Programs.” Washington, DC: August. 

NRC, 2003b. NUREG–1569, “Standard Review Plan for In-Situ Leach Uranium Extraction 

License Applications.” Final Report. Washington, DC: June. 

NRC, 1997. NUREG–1508, “Final Environmental Impact Statement To Construct and Operate 

the Crownpoint Uranium Solution Mining Project, Crownpoint, New Mexico.” Washington, DC: 

NRC. February. 

Uranium One (Uranium One Americas), 2010. “Responses to NRC Waste Management 

Questions.” ADAMS Accession No. ML101330379. May 12. 

Uranium One, 2009a. “Response to Request for Additional Information for the Moore Ranch InSitu Uranium Recovery Project License Application (TAC JU011).” ADAMS Accession No. 

ML091900402. June 19. 

Uranium One, 2009b. “Response to Request for Additional Information for the Moore Ranch 

In-Situ Uranium Recovery Project License Application (TAC JU011).” ADAMS Accession 

No. ML092450317. August 31. 

Uranium One, 2008. “Response to Request for Additional Information for the Moore Ranch 

In-Situ Uranium Recovery Project License Application (TAC JU011), Second Set of 

Responses.” ADAMS Accession No. ML090400079. October 28. 

USACE (U.S. Army Corps of Engineers), 2010. “Subject: Response to a Preconstruction 

Notification (PCN).” Letter to J. Winter from M.A. Bilodeau, Program Manager, Department of 

the Army Corps of Engineers. May 10. 

USCB (U.S. Census Bureau), 2009. “State and County QuickFacts for Campbell, Johnson, and 

Natrona Counties Wyoming.” <http://quickfacts.census.gov> (10 September 2009). 

USCB, 2008. 

USCB (U.S. Census Bureau), 2008. 2008 Population Estimates for Wright, Edgerton, Midwest, 

Gillette, and Casper in Wyoming. <http://factfinder.census.gov> (16 October 2009). ADAMS 

No. ML092940144. 

WDEQ (Wyoming Department of Environmental Quality) 2010: “Re: Permit No. CT-7896.” 

Letter (January 4) from D.A. Finley to J. Cash, Lost Creek ISR, LLC. Cheyenne, Wyoming: 

WDEQ-Quality, Air Quality Division. 2010. 

WDEQ, 2009. “Re: Permit No. CT-8644.” Letter (October 2) from D.A. Finley to M. P. Thomas, 

Uranerz Energy Corporation. Cheyenne, Wyoming: WDEQ-Air Quality Division. 
Environmental Impacts and Mitigative Actions 

4-93 

WDEQ, 2000. “Guideline No. 4–In-Situ Mining, Attachment III Topsoil and Subsoil Management 

and the Associated Erosion Control at Uranium In-Situ Leaching Operations.” March. 

WGFD (Wyoming Game and Fish Department), 2010. “Recommendations for Development of 

Oil and Gas Resources Within Important Wildlife Habitats.” Version 6.0. Cheyenne, Wyoming. 

April. 

WGFD, 2009. “Big Game Crucial Range Maps, Cheyenne, Wyoming.” April. 

<http://gf.state.wy.us/habitat/index.asp> 

WGFD, 2004. “Fencing Guidelines for Wildlife.” Revised Version, Habitat Extension 

Bulletin No. 53—Habitat Extension Services. November. 

Whitehead, R.L., 1996. “Ground Water Atlas of the United States: Segment 8, Montana, 

North Dakota, South Dakota, Wyoming.” U.S. Geological Survey Hydrologic Investigations 

Atlas 730-I. <http://pubs.er.usgs.gov/usguspubs/ha/ha730I>. 

Wyoming Department of Employment, Research and Planning, 2009. Wyoming Unemployment 

Rate Increases to 5.0 percent in May. <http://wydoe.state.wy.us/LMI/news.htm>. 

Wyoming Office of State Lands and Investments, 2007. “Wyoming Biomass Inventory: Animal 

Waste, Crop Residue, Wood Residue, and Municipal Solid Waste.” Cheyenne, Wyoming: 

Office of State Lands and Investments, Wyoming State Forestry Division. March. 

Wyoming SHPO (Wyoming State Historic Preservation Office), 2010. “Subject: Status of Site 

48CA962.” E-mail to J. Davis from R.L. Currit, Senior Archaeologist, Wyoming State Historic 

Preservation Office. June 15. ADAMS Accession No. ML101660667. 

Wyoming SHPO, 2009. “Subject: Uranium One, Inc. More Ranch In-Situ Uranium Recovery 

Project Cultural Resources Inventory (SHPO File# 0608RLC007).” Letter to A. Kock from 

R.L. Currit, Senior Archaeologist, Wyoming State Historic Preservation Office. November 3. 

ADAMS Accession No. ML093170805.

5-1 

5 CUMULATIVE IMPACTS 

5.1 Introduction 

The Council on Environmental Quality (CEQ) National Environmental Policy Act (NEPA) 

regulations, as amended (40 CFR 1500 to 1508) define cumulative effects as “...the impact on 

the environment that results from the incremental impact of the action when added to other past, 

present, and reasonably foreseeable future actions regardless of what agency (federal or 

nonfederal) or person undertakes such other actions.” Cumulative effects or impacts1

 can result 

from individually minor but collectively significant actions taking place over a period of time. The 

proposed Moore Ranch Project could contribute to cumulative effects when its environmental 

impacts overlap with those of other past, present, or reasonably foreseeable future actions. For 

this supplemental environmental impact statement (SEIS), other past, present, and future 

actions in the area include, but are not limited to, coal mining, oil and gas production, coal bed 

methane (CBM) operations, other mining (i.e., sand, gravel, bentonite, clinker), in-situ recovery 

(ISR) operations, conventional uranium mining, and wind farms. 

The cumulative impact analysis of the proposed action was based on publicly available 

information on existing and proposed projects, information from the GEIS (NRC, 2009a), 

general knowledge of the conditions in Wyoming and in the nearby communities, and 

reasonably foreseeable actions that could occur. The primary activity in the area is a 

resurgence, within the last few years, of mineral mining and oil and gas development, although 

this interest has not necessarily translated into active projects. Within 8 km [5 mi] of the 

proposed Moore Ranch Project and within the proposed license area, coal bed methane 

operations are occurring. No long-term changes from the proposed action within the projected 

license area are anticipated because the applicant plans to return the proposed license area to 

its preextraction use following restoration and reclamation activities. There are several ISR and 

conventional uranium projects within the vicinity of the proposed Moore Ranch Project that are 

either in the prelicensing stage or decommissioning. Oil and gas operations are ongoing 

throughout the area. At distances beyond 8 km [5 mi], NRC assumed that the resurgence in 

extractive industries would continue, along with government and industry support, to develop 

infrastructure. 

The GEIS (NRC, 2009a) provides an example methodology for conducting a cumulative impacts 

assessment. Section 5.1.1 describes other past, present, and reasonably foreseeable future 

actions considered in the cumulative impact analysis. The methodology to conduct the 

cumulative impacts analysis for this SEIS is provided in Section 5.1.2. 

5.1.1 Other Past, Present, and Reasonably Foreseeable Future Actions 

The proposed Moore Ranch Project, which covers an area of approximately 28 km2 [11 mi2], is 

located in the middle of the Powder River Basin, which covers an area of approximately 

26,000 km2

 [10,000 mi2] and spans large portions of northeastern Wyoming and southeastern 

Montana. Therefore, the proposed activities at the Moore Ranch Project would affect less than 

0.1 percent of the area within the Powder River Basin. The Powder River Basin contains the 

 

1

For the purposes of this analysis, “cumulative impacts” is synonymous with “cumulative effects” 
Cumulative Impacts 

5-2 

largest deposits of coal in the United States, as well as significant reserves of other natural 

resources including uranium, oil, and gas. As such, there has been, and continues to be, 

substantial mining activities throughout the Powder River Basin. CBM extraction continues to 

be the most prolific mining activity in the region, which is a form of natural gas extraction from 

coal beds. Several environmental impact statements (EISs) issued by the U.S. Bureau of Land 

Management (BLM) and studies by environmental groups in the Powder River Basin that date 

back to the 1970s have looked at the various effects that coal-related mining activities have had 

on the affected environment. 

The various past, present, and reasonably foreseeable future actions in the vicinity of the 

proposed Moore Ranch Project are discussed as follows. 

5.1.1.1 Uranium Recovery Sites 

Along with the proposed Moore Ranch Project, there are other ISR and conventional uranium 

(underground and pit) operations in various stages of the licensing process within the Powder 

River Basin. Uranium-related exploration in the area include the Smith Ranch/Highland 

Uranium Project, an ISR project operated by Power Resources, Inc., and the 

Irigaray/Christensen Ranch Project, operated by Cogema Mining, Inc., are located 

approximately 59 km [37 mi] south-southeast and 32 km [20 mi] north-northwest of the 

proposed Moore Ranch Project (Table 5-1). The applicant has indicated that rather than 

constructing the central processing plant evaluated as part of the proposed action, it is also 

considering operating the Moore Ranch project as a satellite facility, along with the Ludeman 

and Allemand-Ross projects (Uranium One, 2010). In this reasonably foreseeable future action, 

the pregnant lixiviant from the wellfields at these ISR facilities would be pumped to remote 

satellite ion exchange facilities for initial stripping of uranium. On a daily basis during 

operations, Uranium One would load the uranium-saturated resins that result from the ion 

exchange process into 15,140 L [4,000 gal] sole-use tanker trucks. For the Moore Ranch 

facility, the trucks would carry the uranium-bearing resins west over State Highway 387, north 

over State Highway 192, and east over the Streeter Ranch Road to the Irigaray/Christensen 

Ranch Central Plant (Table 5-1) (Uranium One, 2010). There, the resins would be added to the 

elution circuit for uranium stripping and yellowcake production in a process similar to that 

described in Section 2.1.1.1.3.5 (NRC, 1998). Barren resin would be transferred into the tanker 

truck and transported by Uranium One back to the satellite facility (Uranium One, 2010). The 

tanker trucks used to transport ion exchange resins to and from the satellite facility would be 

labeled in accordance with U.S. Department of Transportation requirements at 49 CFR 171–189 

and NRC regulations at 10 CFR Part 71 (Uranium One, 2010). The amount of uranium that 

could be produced in this fashion would be subject to the NRC license condition (NRC License 

No. SUA–1341) limiting annual yellowcake production at the Irigaray/Christensen Ranch Central 

Plant to 1,134,000 kg [2.5 million lb] (NRC, 1998). Any increase in this limit would require an 

amendment to the Irigaray/Christensen Ranch NRC license, with an independent evaluation of 

the environmental impacts (NRC, 2003). 

The NRC staff is aware that several companies are actively investigating the potential for ISR 

extraction, as well as other types of mining and milling, in areas near the proposed Moore 

Ranch Project. These projects are in various stages of development, will be monitored by the 

NRC staff and other local government agencies, and will be discussed within the context of 

cumulative impacts in this SEIS based on available information. 

The current uranium-recovery sites in the Powder River Basin pertaining to potential new 

uranium-recovery sites are listed in Table 5-1. 
Cumulative Impacts

5-3 
Cumulative Impacts 

5-4 
Cumulative Impacts

5-5 

5.1.1.2 Coal Mining 

The Powder River Federal Coal Region was decertified as a federal coal production region by 

the Powder River Regional Coal Team in 1990, which allowed leasing to occur in the region on 

an application basis. Because of decertification, United States coal production increased 

11 percent, from 1,029.1 million tons in 1990 to 1,145.6 million tons in 2007 (BLM, 2009a). 

From 1990 to 2008, the BLM Wyoming State Office held 25 competitive lease sales and issued 

19 new federal coal leases containing more than 5.7 billion tons of coal using the “lease by 

application” process (BLM, 2005a,b,c). Powder River basin coal mines make up over 

96 percent of the coal produced in Wyoming each year (BLM, 2005a,b,c). In 2003, the 

cumulative disturbed land area attributable to coal mines within the Powder River Basin totaled 

nearly 28,000 ha [70,000 ac]. Reasonably foreseeable future development projects contributing 

to the estimate of the cumulative acreage disturbed range from 47,400 to 50,600 ha [117,000 to 

125,000 ac] in the year 2015. Other development related to coal includes railroads, coal-fired 

power plants, major (230 kV) transmission lines, and coal technology projects. The total land 

area of other coal-related disturbance in the Powder River Basin in 2003 was nearly 2,000 ha 

[5,000 ac]. 

Table 5-2 lists surface coal mines within the Powder River Basin in Wyoming. The Wyoming 

East Uranium Milling Region where the proposed Moore Ranch Project is located, includes 

16 surface mines. Surface mining of coal can impact land use, geology and soils, water 

resources, ecology, air quality, noise, historical and cultural resources, visual and scenic 

resources, socioeconomics, and waste management. 

5.1.1.3 Oil and Gas Production 

There are approximately 472 oil and gas production units evenly dispersed throughout the 

Powder River Basin in various stages of production. The Wyoming Oil and Gas Conservation 

Commission reported that in 2003, oil and gas wells in the Powder River Basin produced 

approximately 13 million barrels of oil and 1.1 billion m3

 [40 billion ft3] of conventional gas 

(BLM, 2005a,b,c). 

Most of Wyoming current oil production is from old oil fields with declining production and the 

level of exploration drilling to discover new fields has been low (WSGS, 2002, as cited in BLM, 

2008a). From 1992 to 2002, oil production from conventional oil and gas wells in Campbell and 

Converse Counties within the Powder River Basin decreased approximately 60.4 percent. 

Oil- and gas-related development includes major transportation pipelines and refineries. In 

2003, the cumulative disturbed land area in the Powder River Basin from oil and gas, CBM, and 

related development was nearly 76,100 ha [188,000 ac]. The corresponding projection for the 

year 2015 is 123,000 ha [305,000 ac] (BLM, 2005a,b,c). The depth to producing gas and 

oil-bearing horizons generally ranges from 1,220 to 4,120 m [4,000 to 13,500 ft], but some wells 

are as shallow as 76 m [250 ft] (BLM, 2005a,b,c). 

5.1.1.4 Coal Bed Methane Development Projects 

Natural gas production has been increasing in Wyoming. In the Powder River Basin, this is 

from the development of shallow CBM resources (BLM, 2005a,b,c). Annual CBM production in 

the Powder River Basin increased rapidly between 1999 and 2003, with nearly 15,000 
Cumulative Impacts 

5-6 
Cumulative Impacts

5-7 

producing CBM wells in the Powder River Basin in 2003 and a total production volume of 

364 billion cubic feet (BLM, 2005a,b,c). In 2007, CBM production within Campbell County was 

4.7-million m3 [167,000 million ft3] (BLM, 2009c). The BLM Buffalo Field Office, which 

administers the area where the proposed Moore Ranch Project is located, has processed 

approximately 3,000 applications for permits to drill since 2003; more than 98 percent of these 

applications are for CBM recovery (BLM, 2009c). 

The recovery of CBM involves the installation of facilities that include access roads; pipelines for 

gathering gas and produced water; electrical utilities; facilities for measuring and compressing 

recovered gas; facilities for treating, discharging, disposing of, containing, or injecting produced 

water; and pipelines to transport gas high-pressure transmission pipelines (EMC, 2007a,b). The 

wells are collocated on a well pad installed on a 32 ha [80 ac] spacing pattern (eight pads per 

square mile). The overall life of each well is approximately 10 years: 7 years of production 

followed by final reclamation, which takes about 2 to 3 years (EMC, 2007a,b). 

There are 534 CBM wells within 3.2 km [2 mi] of the boundary of the proposed license area. 

The largest CBM volumes are produced from depths greater than 60 m [200 ft] below ground 

surface (bgs). The target formation occurs at depths from 305 to 366 m [1,000 to 1,200 ft] bgs. 

5.1.1.5 Other Mining 

Sand, gravel, bentonite, and clinker (or scoria) have been and continue to be mined in the 

Powder River Basin. Bentonite is weathered volcanic ash that is used in a variety of products, 

including drilling mud and making cat litter, because of its absorbent properties. There are three 

major bentonite-producing districts in and around the Powder River Basin. Aggregate, which is 

sand, gravel, and stone, is used for construction purposes. The largest aggregate operation is 

located in the Powder River Basin in northern Converse County, and it has an associated total 

disturbance area of approximately 27 ha [67 ac], of which 1.62 ha [4 ac] have been reclaimed. 

Scoria, or clinker, is used as aggregate where alluvial terrace gravel or in-palace 

granite/igneous rock is not available. Scoria generally is mined in the Converse and Campbell 

Counties portion of the Powder River Basin (BLM, 2005a,b,c). 

5.1.1.6 EISs as Indicators of Past, Present, and Reasonably Foreseeable Actions 

Another indicator of present and reasonably foreseeable future actions is the number of draft 

and final EISs prepared by federal agencies within a recent time period. Using information in 

NUREG-1910, Generic Environmental Impact Statement for In-Situ Leach Uranium Milling 

Facilities (GEIS) (NRC, 2009a), Section 5.1.1 and publicly available information, several 

site-specific EISs evaluating actions in the Powder River Basin in addition to draft and final 

programmatic EISs for large-scale actions related to several states including Wyoming were 

considered (see NRC, 2009a, Tables 5.2-3 and 5.2-4). These projects could contribute to both 

local and regional cumulative impacts on air quality, land usage, terrestrial plants and animals, 

and groundwater and surface water resources. 

5.1.2 Methodology 

To determine the potential cumulative impact, the following methodology was developed, based 

on the CEQ guidance (CEQ, 1997): 
Cumulative Impacts 

5-8 

1. Identify for each resource area, the potential environmental impacts that would be of 

concern from a cumulative impacts perspective. These impacts are discussed and 

analyzed in Chapter 4. 

2. Identify the geographic scope for the analysis for each resource area. This scope is 

expected to vary from resource area to resource area, depending on the geographic 

extent to which the potential impacts could be at issue. 

3. Identify the time frame over which cumulative impacts would be assessed. The 

timeframe selected begins in 2007 when Uranium One submitted a license application to 

NRC for a new source material license for the Moore Ranch ISR project. The 

cumulative impact analysis timeframe will terminate in 2020 which represents the license 

termination at the end of the decommissioning period. 

4. Identify existing and anticipated future projects and activities in and surrounding the 

project site. These projects and activities are identified in Table 5-1 and 5-2 of 

this chapter. 

Assess the cumulative impacts for each resource area from the proposed action and 

reasonable alternatives, and other past, present, and reasonably foreseeable future actions 

identified in Table 5-1 and 5-2 of this SEIS. This analysis would consider the environmental 

impacts of concern identified in Step 1 and the resource area-specific geographic scope 

identified in Step 2. 

The following terminology was used to define the level of cumulative impact: 

SMALL: The environmental effects are not detectable or are so minor that they will 

neither destabilize nor noticeably alter any important attribute of the 

resource considered. 

MODERATE: The environmental effects are sufficient to alter noticeably but not 

destabilize important attributes of the resource considered. 

LARGE: The environmental effects are clearly noticeable and are sufficient 

to destabilize important attributes of the resource considered. 

In conducting this assessment, the NRC staff recognized that for many aspects of the activities 

proposed by the applicant, there would be a SMALL impact on the affected resources. 

However, an impact that may be SMALL by itself could result in a MODERATE or LARGE 

cumulative impact when considered in combination with the impacts of other actions on the 

affected resource. Likewise, if a resource is regionally declining or imperiled, even a SMALL 

individual impact could be important if it contributes to or accelerates the overall resource 

decline. The NRC staff determined the appropriate level of analysis merited for each resource 

area potentially affected by the proposed action and alternatives. The level of detailed analysis 

was determined by considering the impact level to that resource, as described in Chapter 4, as 

well as the likelihood that the quality, quantity, or stability of the given resource could 

be affected. 

Table 5-3 summarizes the cumulative impact from the proposed Moore Ranch ISR project on 

environmental resources, based on analyses conducted by the NRC staff and considering the 

other past, present, and reasonably foreseeable activities identified in Section 5.1.1. 
Cumulative Impacts

5-9 

Table 5-3. Cumulative Impacts on Environmental Resources 

Resource Category Cumulative Impacts Comment 

Land Use MODERATE 

The proposed project is 

projected to have a 

SMALL incremental effect 

on land use when added 

to MODERATE 

cumulative land use 

impacts. 

Transportation MODERATE 

The proposed project is 

likely to have a SMALL 

incremental effect on the 

MODERATE cumulative 

impacts to transportation. 

Geology and Soils MODERATE 

The proposed project 

would have a SMALL 

incremental effect on the 

MODERATE cumulative 

impacts to geology and 

soils. 

Water Resources

Surface/Wetlands MODERATE 

The proposed project may 

have a SMALL 

incremental impact on 

surface water and wetland 

resources when added 

the MODERATE 

cumulative impacts. 

Groundwater SMALL to MODERATE 

The proposed project may 

have a SMALL 

incremental impact on 

groundwater resources 

when added to the 

SMALL to MODERATE 

cumulative impacts. 

Ecology 

Terrestrial Ecology MODERATE 

The proposed project may 

have a SMALL 

incremental impact on 

terrestrial ecological 

resources, when added to 

the MODERATE 

cumulative impacts. 

 
Cumulative Impacts 

5-10 

Table 5-3. Cumulative Impacts on Environmental Resources (continued) 

Resource Category Cumulative Impacts Comment 

Aquatic Ecology SMALL 

The proposed project 

would have a SMALL 

impact on aquatic 

resources when added to 

the SMALL cumulative 

impacts. 

Threatened & Endangered Species SMALL 

The proposed project 

would have a SMALL 

impact on threatened and 

endangered species when 

added to the SMALL 

cumulative impacts. 

Meteorology 

Air Quality SMALL 

The proposed project 

would have a SMALL 

impact on air quality when 

added to the SMALL 

cumulative impact. 

Noise SMALL 

The proposed project is 

projected to have a 

SMALL incremental 

impact on noise when 

added to the SMALL 

cumulative impact. 

Historic & Cultural MODERATE 

The proposed project is 

projected to have a 

SMALL incremental 

impact on historical and 

cultural resources when 

added to the MODERATE 

cumulative impact. 

Visual MODERATE 

The proposed project is 

projected to have a 

SMALL incremental 

impact on visual and 

scenic resources when 

added to the MODERATE 

cumulative impact to the 

viewshed. 

Socioeconomic SMALL 

The proposed project is 

projected to have a 

SMALL incremental 

impact on socioeconomic 

resources when added to 

the MODERATE 

cumulative impacts 

expected from other past, 

present, and reasonably 

foreseeable future 

activities. 

 
Cumulative Impacts

5-11 

Table 5-3. Cumulative Impacts on Environmental Resources (continued) 

Resource Category Cumulative Impacts Comment 

Environmental Justice SMALL 

The proposed project is 

projected to have a 

SMALL incremental 

impact on environmental 

justice when added to the 

SMALL cumulative 

impacts expected from 

other past, present, and 

reasonably foreseeable 

future actions. 

Public and Occupational Health and 

Safety SMALL 

The proposed project is 

projected to have a 

SMALL incremental 

impact on public and 

occupational health and 

safety when added to the 

SMALL cumulative 

impacts expected from 

other past, present, and 

reasonably foreseeable 

future actions. 

Waste Management SMALL 

The proposed project is 

projected to have a 

SMALL incremental 

impact on waste 

management when added 

to the SMALL cumulative 

impacts expected from 

other past, present, and 

reasonably foreseeable 

future actions. 

5.2 Land Use 

The cumulative impact to land use was assessed within the planning area administered by the 

BLM Buffalo Field Office, which includes parts of Campbell, Johnson, and Sheridan Counties, 

because the proposed Moore Ranch Project is located in this planning area and a recent BLM 

Resources Management Plan provided information to assess cumulative land use impact. The 

timeframe for the cumulative effects analysis begins in 2007 and terminates in 2020. However, 

recent data from a BLM draft report forecasts the projected magnitude of oil and gas 

development from 2009 to 2029 in the BLM Field Office area (BLM, 2009d). Therefore, certain 

findings from this report were considered in the analysis of cumulative land use impacts. 

Land use within the Powder River Basin is diversified and cooperative, with CBM and oil and 

gas extraction activities sharing land with livestock grazing. Although federal grasslands and 

forests cover approximately 21 percent of the Basin area, most rangeland is privately owned 

(68 percent) and is primarily used for grazing cattle and sheep. Figure 5-1 shows the extent of 

BLM pasture allotments in the region. 
Cumulative Impacts 

5-12 

Figure 5-1. Conventional and ISR Uranium Facilities, BLM Pasture Allotments, and Croplands near the Proposed 

Moore Ranch ISR Facility. Source: BLM, 2010a; Neal et al., 1990; EIA, 2007; Wyoming Oil and Gas Conservation

Commission, 2010.
Cumulative Impacts

5-13 

Ranching in the area has occurred since the Civil War when Texas cattlemen moved their herds 

of Longhorn cattle north looking for open range. Mining in the form of coal, mineral, and oil and 

gas production is another important land use. The first commercial oil field discovery was made 

in 1948. Oil discoveries in 1956 touched off the first oil boom. Other major oil and gas 

discoveries were made in the 1960s and 1970s. Both conventional and CBM oil and gas 

production are expected to continue in upcoming years. As of 2009, there were a total of 

6,421 conventional oil and gas wells in the BLM Buffalo Planning Area (Planning Area), of which 

3,090 were active. An additional 1,359 wells are projected to be drilled from 2009 to 2028. 

Through 2008, 28,776 CBM wells had been drilled, while an additional 13,800 are forecast to 

be developed between the years 2009 and 2028. It is estimated that a total of 25,958 ha 

[64,144 ac] in the Planning Area would be disturbed by well pads and access roads related to all 

types of oil and gas drilling through 2028. This encompasses approximately 1.3 percent of all 

land in the Planning Area. Of this total, 5,519 ha [13,639 ac] would remain unreclaimed at the 

end of 2028, which is approximately 0.2 percent of the total Planning Area lands (BLM, 2009d). 

Coal mining activity in the Powder River Basin began during 1883, and underground coal mines 

began operation during 1894. The Powder River Basin emerged as a major coal production 

area during the 1970s and early 1980s. The largest area, the Gillette coal field is approximately 

24 km [15 mi] wide and extends from approximately 35 km [22 mi] north of Gillette, Wyoming, to 

approximately 40 km [25 mi] south of Wright, Wyoming. The second area is approximately 

32 km [20 mi] wide and extends from Sheridan, Wyoming, north to the Wyoming-Montana state 

line. In 2007, the Powder River Basin was the single most productive coal basin in the 

United States, producing nearly 40 percent of the nation’s coal. It accounts for approximately 

97 percent of Wyoming's production and boasts the 10 largest coal mines in the United States 

by 2007 production. Coal production in the Wyoming portion of the basin is expected to grow at 

an annual rate of 2 to 3 percent per year. Additional coal leases and associated lands land may 

be required to keep up with demand (BLM, 2009e). Figure 5-2 shows the extent of coalfields in 

the region. 

The total uranium mine production in the United States in the year 2007 was 2,059,762 kg 

[4,541,000 lbs], almost half of which occurred in the southernmost Powder River Basin. 

Uranium deposits in Wyoming are concentrated in southeastern Johnson and southwestern 

Campbell Counties, and exploration and production dates back to about 1918. Uranium was 

first mined in Wyoming in 1920, and the first uranium occurrence in the Planning Area was 

discovered in 1951. Continued uranium exploration resulted in discovery of additional 

sedimentary uranium deposits in the major basins of central and southern Wyoming. Most 

uranium production in the Planning Area occurred from 1955 to 1959. Uranium production 

declined in the mid-1960s but picked up again in the late 1960s and 1970s with the discovery of 

major uranium deposits in the Powder River Basin, including Christensen Ranch, Smith Ranch, 

Morton Ranch, and the Highland Mine. Conventional mine production peaked in 1980 and then 

through the early 1990s when many ISR operations were developed. During the 1980s ISR 

replaced conventional mine production as the preferred means for extracting uranium ores in 

the United States. Currently, only ISR milling operations are producing uranium in Wyoming. 

There is one active ISR uranium milling operation in the Wyoming portion of the Powder River 

Basin: the Power Resources’ Highland/Smith Ranch facility located in Converse County. In 

addition to this ISR facility, there are two permitted uranium Plans of Operations within the BLM 

Buffalo Planning Area: the Ruth and Christensen Ranch ISR Projects. The Nichols Ranch ISR 

Project is currently in the permitting process (BLM, 2009f). 
Cumulative Impacts 

5-14 

5-2. Oilfields, Coalfields, CBM Project Areas, Uranium Occurrences, and Uranium Facilities near the Proposed Moore 

Ranch ISR Facility. Source: BLM, 2010a; Neal et al., 1990; EIA, 2007; Wyoming Oil and Gas Conservation 

Commission, 2010.
Cumulative Impacts

5-15 

Land use impacts result from interruption to, reduction or impedance of, livestock grazing areas, 

open wildlife areas, land access, and limitations placed on natural resource extraction activities. 

The potential land use impact from the proposed Moore Ranch Project would be SMALL 

through ISR phases, as discussed in Section 4.2 of this SEIS. Although the proposed license 

area encompasses 2,879 ha [7,100 ac], approximately 61 ha [150 ac] of the land area would be 

used for the operation of the facility, and an even smaller area, approximately 23 ha [57 ac] 

would be disturbed by earthmoving activities and would be fenced to exclude grazing and other 

activities as identified before. Because no central plant would be constructed, the amount of 

land disturbance would be reduced if the applicant elected to operate the Moore Ranch project 

as a satellite facility as described in Section 5.1.1.1, and the potential impacts to land use would 

also be less. The impact would be limited because the applicant has indicated the land would 

be returned to its preextraction condition, except for one access road. Therefore, the proposed 

Moore Ranch Project was projected to have a SMALL incremental effect on land use when 

added to the MODERATE cumulative land use impacts from the other past, present, and 

reasonably foreseeable future action identified in Section 5.1.1 that could affect tens of 

thousands of acres in the BLM Buffalo Field Office. 

5.3 Transportation 

Potential cumulative impacts on transportation were assessed that could result from past, 

present, and reasonably foreseeable development activities. Campbell, Johnson, and Natrona 

Counties served as the geographic boundary area (referred to herein as the cumulative effects 

study area). The cumulative effects timeframe is from 2007–2020. 

Regional direct effects to roads and highways include increased vehicular traffic and the risk of 

traffic accidents in the cumulative effects study area from daily travel by workers and their 

families. Indirect effects include increased wear and tear on existing roads, air emissions, 

fugitive dust from roads, noise, increased potential access to remote areas, and an increased 

risk of vehicle collisions with livestock and wildlife. Direct effects on railroads, pipelines, and 

transmission lines would primarily include increased demand for capacity to move coal, oil and 

gas, and electricity from production locations in the cumulative effects study area to markets 

outside the area. The magnitude of any cumulative transportation impacts is largely tied to 

corresponding increases in population. 

Local impacts in the immediate vicinity of the proposed Moore Ranch Project include transport 

of chemical supplies, yellowcake product, byproduct material, nonhazardous solid waste, the 

commuting facility workforce, and the potential for accidents. During the ISR phases of the 

proposed Moore Ranch Project, truck traffic was estimated to increase by 0.2 to 9.1 percent and 

car traffic was estimated to increase from 0.3 to 7.2 percent along SR 387, the main entrance to 

the proposed facility. Therefore, the transportation impact would be SMALL, as discussed in 

Section 4.3. Wellfield roads constructed as part of the proposed action would be removed upon 

decommissioning; the gravel road leading to the central plant from the main access road would 

remain in place for future use. If the applicant elected to operate the Moore Ranch, Ludeman, 

and Allemand-Ross projects as satellite facilities, the maximum annual number of round trip 

resin shipments to the Irigaray/Christensen Ranch would be 1,460 (4/day) (Uranium One, 

2010). Assuming one daily round trip, resin transfer from a Moore Ranch satellite facility would 

represent about 3.6 times the 100 yellowcake shipments analyzed in Section 4.3, but it is still 

small compared to the average daily traffic on State Highway 387 in the vicinity of the proposed 

Moore Ranch ISR facility (see Table 4-2). Also, as described in the GEIS (NRC, 2009, the 

uranium loaded exchange resins would be less concentrated than yellowcake, and the number 
Cumulative Impacts 

5-16 

of truck trips associated with constructing a smaller satellite facility would be reduced (see 

Table 4-1). For these reasons, impacts would still be SMALL. 

As noted in Section 5.1.1, there are other ongoing or planned activities occurring within the 

Powder River Basin and within the vicinity of the proposed Moore Ranch Project to consider in 

the analysis of cumulative impacts. These activities, which include CBM development, oil and 

gas extraction activities, and large surface-mining operations that may have railways to support 

the transport of coal, all have associated transportation impacts. There is approximately 43-km 

[27-mi] of existing two-track, ungraveled road about the width of the wheels on a truck that 

traverse the proposed Moore Ranch Project, which is currently being used by active CBM 

operators in the area. Furthermore, there are six ISR sites either operating or planned within an 

80-km [50-mi] radius of the proposed Moore Ranch Project, each with transportation 

requirements comparable to that for Moore Ranch Project. In addition, oil and gas exploration 

and production and coal mines continue to be developed on both public and private lands 

throughout the Powder River Basin. 

The existing or planned ISR facilities would require the construction of new road surfaces or the 

improvement of existing roads within the vicinity of the proposed Moore Ranch Project. 

Therefore, the number of roads and road networks would be expected to grow concurrently with 

the natural resource exploration and extraction activities with a concomitant increase in traffic 

and the potential for accidents. The demand for railroads, pipelines, and transmission lines 

would increase to meet the increased demand for capacity to move coal, oil and gas, and 

electricity from production locations in the area to markets outside the area. 

Any potential impacts to the transportation system in support of the proposed Moore Ranch 

Project would be reclaimed and, therefore, overall project-related transportation impacts would 

be relatively minor and SMALL. 

The proposed Moore Ranch ISR Project is likely to have a SMALL incremental effect on 

transportation when added to the MODERATE cumulative transportation impact from the other 

past, present, and future ISR projects, CBM projects, oil and gas operations, surface coal 

mining activities, and other development with transportation requirements identified in 

Section 5.1.1. 

5.4 Geology and Soils 

Cumulative impacts to soils and geology were assessed within the BLM Buffalo Planning Area 

over the period from 2007 to 2020. The principal impacts on geology and soils from the 

proposed Moore Ranch Project would result from earthmoving activities associated with 

constructing surface facilities, access roads, wellfields, and laying pipeline. Earthmoving 

activities that would impact soils include clearing the ground surface of topsoil to build the 

central plant (or a smaller satellite facility) and develop the wellfields, which would include 

preparing a drilling pad to install wells, constructing headerhouses, building access roads, and 

laying pipeline. As discussed in Chapter 4, all phases of the proposed Moore Ranch Project 

would have a SMALL impact on geology and soils. 

The other ISR projects either ongoing or planned within the vicinity of the proposed Moore 

Ranch Project, as described in Section 5.1.1, would impact geology and soils at an intensity 

comparable to what would be seen at the proposed Moore Ranch Project. The past, ongoing, 

and reasonably foreseeable actions to explore for and extract minerals within the region 

contribute to the cumulative impact on geology and soils (BLM, 2008b). Increased vehicle 
Cumulative Impacts

5-17 

traffic, clearing vegetated areas, salvaging and redistributing soil, discharging CBM- and ISRproduced groundwater, and constructing and maintaining project-specific components (e.g., 

roads, well pads, industrial sites, and associated ancillary facilities) all contribute to the 

cumulative impact on soils (BLM, 2008b). 

The main soil resource concerns within the area administered by the BLM Buffalo Field Office, 

where the proposed Moore Ranch Project is located, is wind erosion and water erosion that 

occur where the ground cover has deteriorated (BLM, 2009c). Long-term and short-term 

impacts to soils include accelerated wind or water erosion; declining soil quality factors; a 

decline in microbial populations, fertility, and organic matter; compaction; and the permanent 

removal of soil (BLM, 2005c). Soil composition can be affect by alkalinity changes from 

discharge of CBM-produced water. 

Based on the BLM Powder River Basin Coal Review, approximately 90,140 ha [222,568 acres] 

(5 percent) of land area in the Powder River Basin has been disturbed by development activities 

as of 2007. Much of this disturbance is from coal mining and oil and gas production (BLM, 

2009g). The proposed Moore Ranch Project would disturb about 61 ha [150 ac], which 

represents less than 0.00003 percent of the Basin surface area. Since the soil disturbance for 

an ISR project is relatively minor compared to conventional surface coal mining and oil and gas 

production, the potential incremental impact from activities at the proposed Moore Ranch 

Project would have a SMALL incremental effect when added to the MODERATE cumulative 

impact to geology and soils from the other past, present, and reasonably foreseeable actions 

described in Section 5.1.1 and illustrated in Figure 5-2 that include ISR projects, CBM projects, 

oil fields, and conventional mining/milling occurring within the BLM Buffalo Planning area that 

could affect tens of thousands of acres. 

5.5 Water Resources 

The cumulative impact on surface and groundwater resources was considered with regard to 

the area within a radius of 80 km [50 mi] of the proposed Moore Ranch Project (Figure 5.3). 

5.5.1 Surface Waters and Wetlands 

The proposed Moore Ranch Project is located in the BLM Upper Belle Fourche River 

watershed. No surface water would be discharged as part of the operations of the ISR facility 

(or a satellite facility) and the potential impact to onsite washes would be from potentially 

increased surface water runoff, primarily during the construction and decommissioning phases 

of the proposed Moore Ranch Project. The U.S. Army Corps of Engineers (USACE) determined 

that authorization was not required for any construction activities within Wellfield 1; however, 

activities within Wellfield 2 would be authorized by Nationwide Permit (NP) 12. Therefore, 

according to the GEIS criteria, the proposed Moore Ranch Project could have a MODERATE 

impact on wetlands (NRC, 2009). The potential impact would be mitigated through the industrial 

and construction WYPDES permits the applicant is required to obtain from WDEQ as part of 

license application before operations commence. Furthermore, the applicant has proposed to 

avoid installing wells in the main channels of ephemeral drainages, which would avoid potential 

impacts to wetlands. In addition, the applicant has stated that properly sized culverts would be 

installed for crossing drainages to withstand a 25-year flood event, and embankments and 

culverts and drainage crossings would be protected using best management practices (BMP), 

such as rip rap and rock, in accordance with State of Wyoming regulations. Therefore, the 

potential impact on surface waters and wetlands would be SMALL. 
Cumulative Impacts 

5-18 

Figure 5-3. Energy Developments within 50 Mile Radius of Proposed Moore Ranch ISR Project./ Source: USGS, 

2003; Neal et al., 1990; EIA, 2007; Wyoming Oil and Gas Conservation Commission, 2010
Cumulative Impacts

5-19 

However, other activities occurring within the proposed license area, as well as within 80 km 

[50 mi] of the proposed Moore Ranch ISR Project also have the potential to impact surface 

water. The applicant indicated that CBM production has occurred and continues to occur within 

the proposed license area from the Roland coal within the Fort Union Formation, which occurs 

at a depth of approximately 396 m [1,300 ft] bgs. CBM-produced water from these operations is 

discharged through 22 permitted locations, seven of which are located upstream of the 

proposed Moore Ranch Project, to release water directly to the drainage or small impoundments 

specifically designed to facilitate infiltration to the groundwater. From 2000 to 2008, 

approximately 93 million gallons of CBM-produced water was discharged to the surface 

drainages and impoundments located within the proposed license area (EMC, 2007a,b). 

The BLM estimated that 9 to 52 percent of CBM-produced water would contribute to surface 

water flows, and perennial flows would be likely to develop in former ephemeral channels 

(BLM, 2003). Moreover, nine wetlands, created in response to upstream CBM discharges, have 

been identified on the proposed Moore Ranch Project. Hence, CBM-produced water would 

increase the availability of surface waters for irrigation and other purposes for downstream 

users. BLM noted that noticeable changes in water quality would occur in the main channel 

drainages during periods of low flow and that sodicity and salinity are key water-quality 

parameters because of their impact on water used for irrigation. BLM projected that the 

concentrations of suspended sediment in surface water would likely rise above baseline levels 

from increased flow and surface water runoff from disturbed areas (EMC, 2007a,b). The WDEQ 

adopted the Most Restrictive Proposed Limit (MRPL) for sodicity and salinity into its WYPDES 

permitting process to mitigate potential water quality impacts for downstream users. 

The CBM facilities operators located within the proposed license area have indicated that one of 

the CBM facilities would likely be at the end of its operational life around the time the applicant 

would begin construction, and a second operator has plans to install new facilities within the 

proposed license area. However, these locations would not coincide with the Moore Ranch 

Project wellfield locations (EMC, 2007a,b). BLM (2009b) reported 22,543 active permits for 

CBM operations within Campbell County. 

Surface water quality within 80-km [50-mi] of the proposed Moore Ranch Project could also be 

impacted by conventional oil and gas development, minerals extraction, road maintenance, 

rangeland grazing, and agriculture (BLM, 2009c). The proposed action and past, present, and 

reasonably foreseeable future actions within an 80-km [50-mi] radius of the proposed Moore 

Ranch Project could have a MODERATE cumulative impact on surface water quality. However, 

prudent resource development and use, and the proper application of mitigation measures 

identified in site-specific management or development plans would help mitigate the impact 

(BLM, 2009c). 

The Smith Ranch/Highland (operated by Power Resources, Inc. south of the proposed Moore 

Ranch Project) and the Irigaray/Christensen Ranch (operated by Cogema Mining Inc. north of 

Moore Ranch Project) ISR projects are the only licensed facilities within 30 to 60 km [18.5 to 

37 mi] of the proposed Moore Ranch Project. The licensees are required to obtain USACE 

permits if surface waters and wetlands within their ISR permit boundaries are jurisdictional. 

Moreover, the licensees are required to obtain industrial and construction permits from the 

WDEQ. These permits require best management practices for spill prevention and control; 

therefore, potential cumulative impacts of produced water at the ISR facilities on surface waters 

and wetlands within 30 km [18.5 mi] of the Moore Ranch site would be SMALL. 
Cumulative Impacts 

5-20 

Bear Creek Union Pacific (between Highland Ranch and Moore Ranch Project) and Highland 

Exxon Mobil (south of Highland Ranch) are the closest conventional mills located within 80-km 

[50-mi] of the proposed Moore Ranch Project. Both mills are currently in final reclamation and 

near completion. Because these conventional mills are in final reclamation stage and any 

potential spills to surface waters would be controlled and mitigated under the State-approved 

WYPDES permits, their expected potential cumulative impacts on surface water features at and 

near the Moore Ranch site would be SMALL. 

Oil wells occur within an 80-km [50-mi] radius of the proposed Moore Ranch Project 

(Figure 5-3). Oil wells are largely clustered around Johnson City, west of Gillette City, between 

the proposed Nichols Ranch and Moore Ranch ISR projects, and south of the proposed Moore 

Ranch Project. Under the Clean Water Act, licensees at these oil well sites are also required to 

obtain construction and industrial WYPDES permits, in addition to USACE permits if wetlands 

and surface water within their permit boundaries are determined to be jurisdictional. These 

permits involve require best management practices for spill prevention and control, therefore, 

the potential cumulative impacts of produced water on surface waters and wetlands due to oil 

production units would be SMALL. 

Based on the above analysis, the proposed Moore Ranch Project would have a SMALL 

incremental impact on surface water and a MODERATE impact on wetlands by GEIS criteria 

that if a permit was required, then the potential impact on wetlands could be MODERATE. 

However, the applicant’s proposed mitigation measures described above would reduce the 

impact to SMALL. The incremental effect on surface water and wetlands from the proposed 

Moore Ranch Project would be SMALL when added to the MODERATE cumulative impact from 

the other past, present, and reasonably foreseeable future actions described above. 

5.5.2 Groundwater 

Potential environmental impacts to groundwater resources from the proposed Moore Ranch 

Project would occur primarily during the operations and aquifer restoration phases of the ISR 

facility lifecycle. The analysis of impacts to groundwater resources from operation of the 

proposed Moore Ranch Project in Section 4.5.2 showed that the potential drawdown in wells 

outside the license area from facility operation would be nominal and would not affect well 

yields. Moreover, because the applicant is required to install monitoring wells around and within 

the proposed facility, as part of the license application, for early detection, control, and reversal 

of potential horizontal and vertical excursions, potential groundwater quality impacts on 

nonexempted aquifers would be small. Therefore, the potential impact on groundwater 

resources from operating the proposed Moore Ranch Project would be SMALL. Because 

wellfield operations would not be affected, the impacts to groundwater would be the same if 

Moore Ranch were to be operated as a satellite facility. 

However, within the proposed license area and within 80-km [50-mi] of the proposed Moore 

Ranch Project, there are other ongoing or planned activities that would contribute to a 

cumulative impact on groundwater resources. These include the operation of other ISR facilities 

(although production may be from a different ore-producing zone) and CBM production. 

The BLM estimated that CBM development in the Powder River Basin through the year 2018 

would remove about 3 million acre-feet, less than 0.3 percent of the total recoverable 

groundwater (nearly 1.4 billion acre-feet) in the Wasatch and Fort Union Formations within the 

Powder River Basin. An estimated 15 to 33 percent of the removed groundwater would infiltrate 

the surface and recharge the shallow aquifers above the coals (BLM, 2003). The redistribution 

of pressure within the coals after water production ended would allow the hydraulic pressure 
Cumulative Impacts

5-21 

head to recover to within approximately 15 m [50 ft], or less, of preproject levels within 25 years 

after project completion. The complete recovery of water levels would take tens to hundreds of 

years, depending on the specific location. Wells completed in developed coals that are located 

within the areal extent of a 30 m [100 ft] drawdown contour induced by a CBM well could 

experience water level drops and possibly encounter methane (BLM, 2003). BLM (2003) noted 

that the areal extent and magnitude of drawdown effects on coal zone aquifers and overlying or 

underlying sand units in the Wasatch Formation would be limited by the discontinuous nature of 

different coal zones within the Fort Union Formation and sandstone layers within the 

Wasatch Formation. 

Within the vicinity of the proposed Moore Ranch Project, the CBM-producing unit is the Roland 

Coal within the Fort Union Formation. The Fort Union Formation is separated from the 70 Sand 

ore production zone in the Wasatch Formation by more than 213 m [700 ft] of interbedded clays, 

siltstone, and discontinuous sands. BLM noted that coal methane fields would impact 

groundwater in the ore-bearing Wasatch Formation. As the coal zone is depressurized by 

pumping out groundwater, groundwater levels in the lower Wasatch Formation would be 

lowered because of the increased pumpage-induced vertical hydraulic gradient between the 

Wasatch and Fort Union Formations. However, BLM estimated that drawdown in the Wasatch 

Formation incurred from pumpage from the Fort Union Formation during coal methane field 

development and would be 10 percent of the drawdown in the Fort Union Formation. Because 

of the (i) expected larger vertical downward gradients from the relatively larger decline in 

groundwater levels in the underlying Fort Union Formation than in the overlying Wasatch 

Formation during coal bed methane productions, and (ii) the occurrence of a 213 m [700 ft] 

confining layer between the ore production zone in the Wasatch Formation and the coal layers 

in the Fort Union Formation, the potential for the water quality in the Wasatch Formation to be 

affected by the CBM production would be SMALL. 

CBM-produced water historically has been and continues to be discharged at the surface in the 

proposed license area, potentially affecting the water quality of the 72 Sand surficial aquifer, 

which overlies the 70 Sand ore production zone. BLM predicts that the volume of groundwater 

in shallow layers of the Wasatch Formation would increase because of infiltration of CBM 

produced water. The applicant analyzed the rate of infiltration of CBM-produced water down to 

the 72 Sand surficial aquifer and determined that it would be possible for the 72 Sand surficial 

aquifer to receive infiltration from CBM-produced water within 1 to 10 years of its surface 

discharge. However, the quantity and quality of the produced water that would be surface 

discharged would be controlled by the issuance of a State of Wyoming WYPDES permit. 

Hence, potential cumulative impacts on the quality and quantity of groundwater in the Wasatch 

Formation because of CBM related activities would range from SMALL to MODERATE. 

The Smith Ranch/Highland (operated by Power Resources, Inc. south of Moore Ranch Project) 

and the Irigaray/Christensen Ranch (operated by Cogema Mining Inc., north of Moore Ranch 

Project) projects are the only licensed ISR projects within 30 to 60 km [18.5 to 37 mi] of the 

proposed Moore Ranch Project. The Smith Ranch/ Highlands ISR operations occur in the 

deeper Fort Union Formation. Because of the distance between the Smith Ranch/Highlands 

operation and its location in a deeper formation, its potential to contribute to the cumulative 

impact on groundwater levels at and near the Moore Ranch site would be SMALL. The 

Irigary/Christensen Ranch ISR operations occur in the same Wasatch Formation as the 

proposed Moore Ranch Project. Although both ISR operations are in the same formation, the 

physical distance between them is sufficient to eliminate any significant drawdown; therefore the 

potential to contribute to the cumulative impact on groundwater levels at and near the Moore 

Ranch site would be SMALL. Moreover, because the licensees at both of these sites are 
Cumulative Impacts 

5-22 

required to implement excursion detection, control, mitigation, and remediation plans under 

NRC regulations, their potential cumulative impacts on groundwater quality and yield at and 

near the Moore Ranch Project would be SMALL. 

Oil wells located within 80-km [50-mi] of the proposed Moore Ranch Project, are completed at 

depths greater than ~3,050 m [10,000 ft] below the ground surface; the targeted aquifers for ISR 

uranium production is in the Wasatch Formation, which usually occurs at a depth that ranges 

from 42 to 135 m [137 to 440 ft] below the ground surface, thousands of feet above the oilproducing horizons. Therefore, the potential for oil production in the Powder River Basin to 

contribute to the cumulative impacts on the quality and quantity of groundwater at and near the 

Moore Ranch site would be SMALL. 

Bear Creek Union Pacific (located between Highland Ranch and Moore Ranch Project) and 

Highland Exxon Mobil (south of Highland Ranch) are the closest conventional mills within 80-km 

[50-mi] of the proposed Moore Ranch Project. The Bear Creek operation conventionally mined 

uranium in the Wasatch Formation. The Highland Exxon Mobil Site mined uranium from the 

Ft. Union Formation. Both mills are Title II sites currently in final reclamation and near 

completion. When Title II sites are reclaimed, they are placed under the care of either DOE or 

the State in perpetuity and require NRC-approved, long-term groundwater surveillance 

monitoring plans to ensure they have no impact on the groundwater. Therefore, their expected 

potential cumulative water quality and yield impacts on groundwaters at and near the Moore 

Ranch site would be SMALL. 

Deep disposal of process water is a disposal method used by CBM, ISR, and oil production 

facilities in the Powder River Basin. For deep well disposal, the applicant is required to obtain 

WDEQ UIC permits for the targeted deep aquifer. The permit would be granted if the deep 

disposal practice is protective of public health and safety and does not impose a risk to 

underground sources of water. Therefore, the proposed Moore Ranch ISR project deep 

disposal wells may have a SMALL incremental impact on groundwater resources when added 

to the SMALL to MODERATE cumulative impacts anticipated from the other past, present, and 

reasonably foreseeable future actions discussed in Section 5.1.1 and above. 

5.6 Ecological Resources 

The cumulative impact on ecological resources from the proposed Moore Ranch ISR project 

was considered. The area considered for the analysis of cumulative impacts is the Powder 

River Basin because grasslands and sagebrush shrubland habitats are important features of the 

Basin landscape and occur on the proposed project site. The timeframe for the analysis runs 

from 2007 to 2020 although older data are considered to demonstrate historical trends.

5.6.1 Terrestrial Ecology 

Activities occurring in the area around the proposed Moore Ranch Project include grazing and 

herd management, hunting, and mineral exploration. Potential cumulative impacts to ecological 

resources, both flora and fauna, include reduction in wildlife habitat and forage productivity; 

modification of existing vegetative communities; and potential spread of invasive species and 

noxious weed populations. Cumulative impacts to wildlife could involve loss, alteration, and 

incremental habitat fragmentation; displacement of and stresses on wildlife; and direct and 

indirect mortalities. Land disturbance resulting from other development activities in the vicinity 

of the proposed license area have similar ecological impacts as described in Section 4.6 and 

would be SMALL, individually, if mitigative measures were employed. However, assuming that 
Cumulative Impacts

5-23 

adjacent habitats for each disturbed land parcel would be at, or near, carrying capacity, and that 

there would be an unavoidable reduction or alteration of habitats, development activities in this 

portion of the Powder River Basin could cumulatively contribute to reduction in plant and wildlife 

populations and alteration of population structure. For some species that require specific 

habitat conditions, future use would be strongly influenced by the quality and composition of the 

remaining habitats. The BLM Powder River Basin Oil & Gas EIS concluded that continued 

natural resource development across the Basin has the potential to alter the distribution of 

various types of native vegetation, resulting in cumulative impacts to biodiversity (BLM, 2003). 

Loss and degradation of native sagebrush shrubland habitats has affected much of this 

ecosystem type as well as sagebrush-obligate species including the Greater sage-grouse. Most 

of the sagebrush lands in the region have been changed by land use such as livestock grazing, 

agriculture, or resource extraction. These uses can influence habitats either directly or 

indirectly, or alter the disturbance regime by changing the frequency of fire (Naugle, et al., 

2009). The long-term viability of the sage-grouse range wide continues to be at risk because of 

population declines related to habitat loss and degradation. Because of its spatial extent, oil 

and gas resource development is regarded as playing a major role in the decline of the species 

in the eastern portion of species range (Becker, et al., 2009). As of this writing, the United 

States Fish and Wildlife Service (USFWS) has designated the greater sage-grouse as a 

“candidate species” under the Endangered Species Act which will consider the bird on an 

annual basis for listing as a threatened or endangered species. 

However, the impact to sagebrush shrubland communities at the proposed Moore Ranch ISR 

license area would be SMALL because only 61 ha [150 ac] or about 2 percent out of 2,879 ha 

[7,110 ac] would be disturbed. A smaller land disturbance would result if the Moore Ranch 

project were to be operated as a satellite facility as described in Section 5.1.1.1. Additionally, 

Table 3-4 shows that only 10 percent of the proposed project area consists of sagebrush 

habitat, while Figure 3-11 illustrates that plant facilities are located some distance from identified 

sagebrush areas. Most of the habitat disturbance would consist of scattered, confined drill sites 

for wells that would not result in large expanses of habitat being dramatically transformed from 

its original character as in other surface mining operations; no substantial long-term impact 

would be expected. The NRC staff acknowledges that sage-grouse is rare in the vicinity of the 

proposed Moore Ranch Project because of the limited habitat available to support its existence 

and no large expanses of contiguous sagebrush occur within several kilometers of the Moore 

Ranch Project. Additionally, few sage-grouse have been documented in the area and no 

grouse leks have ever been discovered either on or near the proposed Moore Ranch Project. 

The nearest known sage-grouse lek is located approximately 4.0-km [2.5-mi] to the northwest of 

the Moore Ranch Project area. 

Regarding other species of concern, the proposed Moore Ranch ISR project has the potential to 

impact 14 avian species known to occur, or potentially be present, as seasonal or year-round 

residents. Impacts may occur to species during all phases of the proposed project. Impacts 

would be SMALL due to the limited footprint of the project across the entire proposed project 

site area. Additionally, potential SMALL impacts that occur at the proposed Moore Ranch ISR 

site (e.g., habitat loss, fragmentation, noise disturbance) would also be likely to occur at other 

mining and oil and gas facilities throughout the geographic boundary area and potentially impact 

other localized populations. The BLM Powder River Basin Oil & Gas EIS concluded that there 

could be cumulative impacts to certain species of raptors and migratory birds resulting from 

shifts in the habitat composition or distribution (BLM, 2003). 
Cumulative Impacts 

5-24 

Therefore, the proposed action could have a SMALL incremental impact on terrestrial ecological 

resources, especially those that are presently in decline, when added to the MODERATE 

cumulative impacts anticipated in the Powder River Basin from other past, present, and 

reasonably foreseeable future actions discussed in Section 5.1.1 and above that could result in 

the disturbance of tens of thousands of acres. 

5.6.2 Aquatic Resources 

Since no aquatic habitat exists on the proposed Moore Ranch ISR project to support fish or 

macroinvertebrates, the proposed project would have a SMALL impact on aquatic resources 

when added to the SMALL cumulative impacts anticipated from the other past, present, and 

reasonably foreseeable future actions. 

5.6.3 Threatened and Endangered Species 

No Federal- or State-listed sensitive plant species, endangered or threatened plant species, or 

designated critical habitats occur within the proposed license area. Any potential impacts to 

these species during the various project phases would be limited. Therefore, the proposed 

project would have a SMALL impact on threatened and endangered species when added to the 

SMALL cumulative impacts anticipated from other past, present, and reasonably foreseeable 

future actions.

5.7 Air Quality 

Potential impacts to air quality from the proposed Moore Ranch Project are anticipated to be 

SMALL and are discussed in detail in Section 4.7 of this SEIS. Nonradiological air emission 

impacts primarily involve fugitive road dust from vehicles used throughout the facility lifecycle 

and combustion engine emissions from diesel equipment that is used predominantly during the 

construction and decommissioning phases. The NRC staff concluded that the air quality for the 

region in the vicinity of the site is in compliance with the National Ambient Air Quality Standards 

(NAAQS), and based on emissions estimates described in Section 2.1.1.1.6.1, the facility would 

not be classified as a major source under the New Source Review or operating (Title V of the 

Clean Air Act) permit programs. The NRC staff analysis noted the presence of Prevention of 

Significant Deterioration (PSD) Class I and II areas within the region that could potentially be 

impacted by emissions from the proposed action; however, based on the magnitude of 

emissions, the prevailing wind direction, and distance from the proposed facility, the NRC staff 

concluded that impacts would be unlikely. 

Downwind concentrations of emitted air pollutants are affected by a number of variables, 

including the ambient meteorological conditions and the magnitude of the emission rate. Based 

on the low magnitude of estimated emissions from the proposed action (Section 2.1.1.1.6.1), 

good air quality in the region (Section 3.7.2) and meteorology that is often favorable for 

dispersion (Section 3.7.1), the NRC staff concluded detailed quantitative air analyses were not 

necessary to evaluate potential air impacts. As a result, the extent of the geographic area that 

could be impacted by proposed emissions was not quantified; however, other regional air 

modeling studies addressing larger scale emission sources applicable to oil and gas activities, 

coal bed methane production, and conventional coal mining suggest the region of influence for 

air emissions could range from about 60 km [37 mi] (Stoeckenius, et al., 2006) to beyond 242 

km [150 mi] (AECOM, 2009). Because of the low magnitude of proposed emissions, the 

distance where measurable air impacts could be detected from the proposed action would be 

closer to the proposed license area. 
Cumulative Impacts

5-25 

Past, present, and reasonably foreseeable future activities in the vicinity of the proposed Moore 

Ranch Project site that emit air pollutants include other uranium mining/milling activities, CBM, 

coal mining, and oil and gas operations. The past and present contributions of projects in the 

region that emit air pollutants are represented in the ambient air quality monitoring results 

described in Section 3.7.2. These monitoring results indicate the air quality is in attainment for 

all NAAQS. Emissions from projected development of future oil and gas exploration and 

production, including CBM and coal mining, have been evaluated for impacts to air in previous 

EISs and supporting documents for proposed developments in the Powder River Basin (BLM, 

2003; 2009; ENSR International, 2006; AECOM, 2009) where the proposed Moore Ranch 

Project is located. While the concurrent activities emit a variety of pollutants, the principal 

emissions from the oil and gas industry that would overlap significantly with emissions from the 

proposed action are nitrogen oxides, volatile organic compounds, and fugitive road dust. The 

principal emissions from coal mining include fugitive dust (particulates including coal dust) and 

exhausts from diesel-powered equipment. Therefore, the focus of the NRC staff cumulative 

impact analysis on air quality is from nitrogen oxides and fugitive dust emissions from the 

proposed Moore Ranch Project, other proposed ISR facilities, and future oil and gas, and coal 

operations in the Powder River Basin of Wyoming. 

Within an 80-km [50-mi] radius of the proposed Moore Ranch Project, there are at least six 

operating or planned ISR facilities (Table 5-1) that would generate emissions comparable to 

emissions projected for the proposed project. Because ISR facilities commonly use a phased 

approach to well drilling and wellfield construction, and all six facilities would not begin 

construction concurrently (as each must go through the average 2-year licensing process and 

obtain the necessary Federal, State, and local permits), the degree of overlap in construction 

activities would be most likely to occur for wellfield drilling activities because each facility would 

construct more than one wellfield over a period of years. To estimate the potential annual 

contribution of the six facilities to local air emissions, the NRC staff considered the emissions 

results in Appendix D and assumed two facilities were simultaneously starting construction of 

their first wellfield and drilling two deep disposal wells and the remaining four facilities each had 

an active wellfield and deep well under development. For that scenario, the total annual 

contribution of ISR facility nitrogen oxide emissions in the region that would add to the 

emissions from other past, present, and reasonably foreseeable future actions would be 

approximately 76 t/yr [84 T/yr]. The estimate of fugitive road dust emissions would scale directly 

with each new facility because emissions would occur during all phases of the facility lifecycle. 

Because the proposed Moore Ranch Project has a relatively short main access road, the NRC 

staff assumed an average value of 63.5 tons/yr [70 tons/yr] for each facility, resulting in a total of 

381 tons/yr [420 tons/yr] of fugitive road dust. Since these facilities and their emissions would 

be spatially dispersed throughout the region, they would not represent a single point source. 

Because it considers the air quality impacts associated with the more extensive construction 

and decommissioning requirements and larger workforces associated with a central plant, the 

potential impacts of operating the Moore, Ludeman, and Allemand-Ross projects as satellite 

facilities are bounded by the analysis. 

The potential air impacts from future CBM activities, coal mining, and oil and gas exploration in 

the Powder River Basin have been previously evaluated (BLM, 2003; 2009; ENSR International, 

2006; AECOM, 2009). A recent BLM cumulative air analysis of the Powder River Basin was 

conducted to support review of coal development in the Powder River Basin (AECOM, 2009). 

That analysis involved executing a state-of-the-art EPA guideline dispersion model, CALPUFF, 

version 5.8 (Scire, et al., 1999) to calculate local-scale, short-range dispersion as well as 

region-scale, long-range dispersion of emissions assuming worst case meteorological 

conditions. Emissions were developed for base year 2004 (NO2, SO2, PM2.5, and PM10) and 
Cumulative Impacts 

5-26 

were projected for year 2020. Emission sources included coal-related (mines, power plants, 

railroads, conversion facilities); permitted sources in Wyoming and Montana; CBM production 

sources; and miscellaneous roads, urban areas, conventional oil and gas, noncoal power 

plants). The estimated impacts from that study for the baseline year (2004) indicated calculated 

air concentrations were below NAAQS, except for short-term PM10 and PM2.5 in the near field. 

Year 2020 projected impacts showed compliance with standards, except for short-term and 

annual PM2.5 and PM10 in localized areas. Far-field visibility impacts were identified for 

downwind Class I areas (Northern Cheyenne Indian Reservation, Badlands National Park, Wind 

Cave National Park) as a consequence of power plant and CBM emissions, and visibility 

impacts to several Class II areas were projected from power plant and coal mine emissions. 

These modeling results suggest that local and regional air quality in the Powder River Basin and 

nearby areas is presently good but is degrading with time, primarily from particulate emissions, 

as various emissions sources are projected to increase to 2020. While NOx projections for 

near-field receptors in 2020 were below the ambient standard, the calculated concentrations 

were at 80 percent of the limit compared to the base year calculation of 30 percent of the limit. 

Therefore, the margin for compliance is being reduced with the future projected development 

and the associated increase in emissions. 

The licensing of proposed ISR facilities would contribute incremental increases to area 

emissions including, in particular, NOx and fugitive dust and, therefore, incrementally impact air 

quality. Because the volume of ISR nonradiological emissions are low compared to existing and 

future proposed developments in the region, the NRC staff concluded the relative proportion of 

future air quality impacts from ISR operations would be SMALL. While detailed emissions data 

for specific projects, practices, or industries in the local area were not identified by the NRC staff 

to compare with the proposed action estimates, the NRC staff did identify general information to 

provide context and support for the NRC staff conclusion that proposed annual ISR 

nonradiological air emissions levels are relatively low as discussed in detail in the 

following paragraph. 

At the state level, emissions inventory estimates (Russell and Pollack, 2005) for 2002 suggest 

the total amount of NOx emitted from oil and gas drilling that year was approximately 4,500 t 

[4,964 T] from the construction of 2,948 wells. From these numbers, the NRC staff approximate 

an average of 1.54 t [1.7 T] of NOx per well. For comparison, the calculated drill rig emissions 

for the proposed Moore Ranch Project wellfield development activities is 7.89 × 10−3

 t 

[8.7 × 10−3

 T] of NOx per well (derived from emission calculation results reported in Appendix D), 

orders of magnitude less than wells being drilled in support of oil and gas exploration and 

production. The state average value is more comparable to the emissions calculated for a 

single proposed deep disposal well (calculated to emit approximately 5.89 t [6.5 T] per well as 

shown in Appendix D). The higher emissions from the deep well drilling is temporary, with two 

to five deep disposal wells expected per proposal and approximately 528 hours per well 

(Appendix D) or 66 8-hour drilling days each. Other regional sources of NOx considered in the 

aforementioned air-modeling analysis included power plants and trains (for example, shipping 

coal that is mined locally). Year 2004 NOx emissions from coal-fired power plants in Southwest 

Wyoming are reported as 31,116 and 12,004 t/yr [34,321 and 13,240 T/yr]. Maximum NOx

emissions from a proposed rail line from Miles City to Decker, Wyoming, was reported as 10.1 

t per km per year [6.9 T per mile per year] (ENSR International, 2006) and therefore 184 t/yr 

[203 T/yr] along the 47.3-km [29.4-mile] route. Oil and gas drilling varies considerably in well 

depth and associated emissions. Examples of NOx emissions from oil and gas drilling in the 

Jonah-Pinedale area of southwestern Wyoming (Stoeckenius, 2010) indicate large clusters of 

drilling rigs emit between approximately 0.91 and 5.9 t [1 and 6.5 T] of NOx per day. While this 

area complies with the NOx ambient air quality standard (NOx is a precursor to ozone formation) 
Cumulative Impacts

5-27 

it has experienced episodic exceedances of the ambient ozone standard based on a 

combination of specific factors (including strong temperature inversions, low winds, snow cover, 

bright sunlight, and emissions) that is resulting in more regulatory and research attention 

(Stoeckenius, 2010). The aforementioned NOx emitted from drilling and construction equipment 

for six proposed ISR facilities that would be within an 80-km [50-mi] radius was calculated as 

76 t/yr [84 T/yr] (approximately 0.2 and 0.6 percent of the aforementioned coal plant 

emissions, 40 percent of the 47.3-km [29.4-mi] rail spur estimate, and 3.5 to 23 percent of the 

Jonah-Pinedale oil and gas drilling cluster example). The contribution to annual NOx emissions 

calculated for the proposed action 18 t/yr [20 T/yr] is approximately 24 percent of the six-facility 

estimate used in this analysis. 

Fugitive dust emissions from the proposed action and other existing or proposed ISR facilities 

would contribute to the cumulative particulate matter emissions from power plant, CBM 

activities, and coal mining, in particular. As the projected emissions from these activities for 

2020 indicate near-field exceedances of PM2.5 and PM10 (AECOM, 2009) and potential far-field 

visibility impacts would be increasing, the NRC staff expect particulate emissions would 

continue to be an air-quality concern in future years. Because ISR facilities are not major 

sources of particulate emissions, the principal emission would be fugitive road dust. Based on 

the limited daily traffic expected from the proposed action (Section 4.3) and dust control 

measures the applicant proposes to implement, and could be required by the WDEQ 

construction air permit that presently is under review for the proposed action (previously a 

permit condition for similar facilities; WDEQ, 2009; WDEQ, 2010), and the magnitude of 

estimated emissions, the NRC staff conclude that the impacts to air would be localized, 

intermittent, and temporarily MODERATE (e.g., visible plumes of dust from traffic on unpaved 

roads) but would be predominantly SMALL. 

While the proposed ISR emissions are relatively low, the actual cumulative effect of multiple 

new ISR facilities that could be licensed in the future would depend on the ambient air quality at 

the time of licensing, the continued development of other emission-generating activities in the 

area and region, and the timing and magnitude of emission-generating activities at each 

proposed ISR facility. As these ISR facilities would be licensed by NRC and permitted 

sequentially on a first-come, first-serve basis, the addition of emissions from each new facility 

would be incremental. This incremental development of uranium milling facilities in the region 

allows the NRC to evaluate each proposal and state air quality staff to evaluate potential 

impacts within the context of existing air quality 

5.7.1 Global Climate Change and Greenhouse Gas Emissions 

As discussed in the U.S. Global Change Research Program (GCRP) report (GCRP, 2009), it is 

the “... production and use of energy that is the primary cause of global warming, and in turn, 

climate change will eventually affect our production and use of energy. This assessment is 

focused on greenhouse gas emissions. 

Greenhouse gas emissions associated with the construction, operation, and decommissioning 

of an ISR facility are addressed in Chapters 3 and 4 of this SEIS (see Table 5-4). Evaluating 

the cumulative impacts of greenhouse gas emissions (GHGs) is challenging. 

Evaluation of cumulative impacts of GHGs requires the use of a global climate model. GCRP 

(2009) synthesized in a technical support document the results of numerous climate modeling 

studies as discussed in Section 3.7.1.5. Based on this study, the EPA determined that potential 

changes in climate caused by GHG emissions endanger public health and welfare. NRC 
Cumulative Impacts 

5-28 

Table 5-4. Comparison of Carbon Dioxide Emissions by Source 

Source CO2 Emission 

Global Emissions (t/yr) 28,000,000,000* 

United States (t/yr) 6,000,000,000* 

Single ISR (t/yr) Facility Lifecycle (12 years) 2,400 

Current/Proposed ISR Facilities Lifecycles (12 years) 14,400 

Average Annual U.S. Passenger Vehicle 5† 

*EPA, 2009

†Federal Highway Administration, 2006

recognizes that the global cumulative impacts of greenhouse emissions as presented in the 

report, are the appropriate basis to evaluate cumulative impacts. Based on the impacts 

identified in the GCRP report, the NRC recognizes that the national and worldwide cumulative 

impacts of greenhouse gas emissions are noticeable but not destabilizing. 

5.7.1.1 Greenhouse Gas (GHG) Emissions in the Region 

The Center for Climate Strategies (CCS) prepared a report for the Wyoming Department of 

Environmental Quality (WDEQ) that provides an inventory and forecast of the Wyoming’s GHG 

emissions (CCS, 2007). These emissions data were based on projections from electricity 

generation, fuel use, and other GHG-emitting activities. Emissions are reported as CO2

equivalents (CO2e), a conversion for the various gases emitted, (i.e., methane or nitrous 

oxides), into equivalent greenhouse effect to compare to CO2 (BLM 2008). Gross carbon 

dioxide-equivalent (CO2e) emissions in 2005 for Wyoming were 56 million metric tons (MMt). 

This volume accounted for less than one percent (0.8%) of the total United States gross GHG 

emissions. This total is reduced to 20 MMt CO2e as a result of annual sequestration (removal) 

due to forestry and other land uses (CCS, 2007). 

Wyoming has a higher per capita emission rate than the national average (>4 times). This is 

due to the state’s fossil fuel production industry and industries that consume high amounts of 

fossil fuels, as well as a large agricultural industry, large distances between cities, and a small 

population (CCS, 2007). The CCS report expects that the Wyoming GHG emissions would 

continue to grow with the increased demand for electricity, followed by emissions associated 

with transportation. These GHG projections are reflected in Table 5-5. 

As of 2009, there are 13 active coal mines in the Wyoming portion of the Powder River Basin, 

and these mines produced approximately 496 million short tons (BLM, 2010b). According to the 

Table 5-5. Wyoming Historical and Reference Case GHG Emissions 

Million Metric Tons CO2e 1990 2000 2005 2010 2020 

Energy Sector 38.0 43.6 47.5 51.6 59.6 

Electricity Production Based 39.8 43.3 44.2 47.8 54.2 

Coal 39.8 43.2 44.1 47.7 53.9 

Natural Gas 0.00 0.1 0.1 0.1 0.2 

Petroleum 0.0 0.0 0.0 0.0 0.0 

Geothermal, Biomass and Waste 

(CO2, CH4, and N2o) 

0.0 0.0 0.0 0.0 0.0 

*Million Metric Tons CO2e 

Source: CCS, 2007 
Cumulative Impacts

5-29 

Wyoming Oil and Gas Conservation Commission, there are over 33,000 active gas and oil wells 

in the State, 45 operational gas processing plants, 5 oil refineries, and over 9,000 miles of gas 

pipelines (CCS, 2007). Because there is no regulatory requirement to track carbon dioxide or 

methane emissions, there is a high degree of uncertainty associated with the Wyoming GHG 

emissions from this industry. However, the CCS (2007) estimated that approximately 13.5 MMt 

of CO2e was emitted by fossil fuel industries. Of this amount, 80 percent was due to the natural 

gas industry. This amount is expected to grow an additional 8–10 percent in the next decade 

(CCS, 2007). No data currently exists for the nonfossil fuel industries, including uranium. 

5.7.1.2 GHG Emissions from the Proposed Moore Ranch Project 

In response to current concerns related to GHG emissions, NRC has focused on evaluating CO2

emissions for the lifecycle of the proposed facility and compares this with other forms of 

extraction. The primary source of CO2 emissions from ISR facilities are combustion engine 

emissions from construction equipment (including drill rigs). Construction equipment is used 

most during initial wellfield and facility construction and later during the decommissioning phase 

to remove buildings and equipment and reclaim land surfaces. 

Annual and cumulative CO2 emissions over the life of the facility from the proposed Moore 

Ranch Project for construction and decommissioning activities were estimated by the NRC staff 

and documented in Appendix D of this SEIS. Combustion engine exhaust calculations 

performed for the proposed Moore Ranch Project were based on a combination of proposalspecific and representative information appropriate to support a conservative emissions 

screening analysis (Appendix D). Only nonroad combustion emissions were considered. Diesel 

emissions, including drilling rigs, were estimated using emission factors provided by the EPA 

using different engine classes, based upon power output and operating time (Appendix D). The 

applicant (Uranium One) proposes to drill two wellfields of approximately 470 and 500 wells, 

respectively, during the first few years of the project. This includes injection and production 

wells (for the ISR process) as well as monitoring wells. In addition, the applicant proposes to 

have two to four UIC Class I wells (for deep well injection of byproduct material [wastewater]). 

Results show that drilling rigs and other construction equipment used during the construction 

phase have the highest annual CO2 emissions for the proposed action. This amounts to 852 t 

[940 T] of CO2 per year. The cumulative calculated CO2 emissions from drilling and 

construction of all wellfields followed by decommissioning all wellfields and associated facilities 

was estimated as 2,400 t [2,600 T]. 

The majority of estimated annual CO2 emissions are from drilling and nearly 81 percent of the 

calculated drilling CO2 emissions are from deep disposal well-drilling activities. Well drilling 

activities would occur over a period of at least two years, perhaps longer, because there are two 

wellfields from which the applicant proposes to recover uranium, and the first wellfield could be 

operational for a few years. If the Moore Ranch project were to be operated as a satellite 

facility, the increased number of trips would lead to an increase in CO2 emissions from 

transportation. The construction and decommissioning footprint would be less, however, and 

wellfield operations and aquifer restoration would not be affected by a satellite facility. For these 

reasons, the estimated annual CO2 emissions would be about the same. The estimate did not 

consider sequestration (removal) due to forestry or other agricultural activities (EPA, 1996). 
Cumulative Impacts 

5-30 

5.7.1.3 Moore Ranch ISR Facility GHG Emissions Impact 

As described in Section 5.7.1.1, the total amount of GHGs produced in Wyoming in 2005 was 

56 gross MMt without considering sequestration (CCS, 2007). If 36 gross MMt for sequestration 

of GHGs is considered, as estimated in the Wyoming Greenhouse Gas Inventory and 

Reference Case Projections 1990–2020 (CCS, 2007), the net total GHGs annually produced in 

Wyoming is 20 MMt. The proposed Moore Ranch Project would conservatively produce a 

maximum annual total of 852 t (940 T) of GHGs (as carbon dioxide), which equates to 

approximately 0.004 percent of the net total GHGs produced in Wyoming in 2005. This 

compares to approximately 2.2 percent from conventional mining operations as discussed in 

Section 5.7.1.6. If either GHG emissions has increased or sequestration has decreased since 

2005, the effect from the proposed Moore Ranch Project would be even less. Therefore, the 

potential impact of GHGs from the proposed Moore Ranch Project would be SMALL. 

5.7.1.4 Effect of Climate Change on the Moore Ranch ISR Facility 

While there is general agreement in the scientific community that some change in climate is 

occurring, considerable uncertainty remains regarding the magnitude and direction of some of 

the changes, especially predicting trends in a specific geographic location. To predict the effect 

of climate change on the proposed Moore Ranch Project, temperature and precipitation data 

from two NWS stations located in and two stations located near the Powder River Basin were 

reviewed (NCDC, 2009). The data, daily records for both temperature and precipitation, 

covered a period of 50 years. Aside from the year-to-year fluctuations, there was no observable 

increase or decrease in either temperature or precipitation during the periods of record for the 

four NWS stations (NCDC, 2009). In another study, the National Climatic Data Center (NCDC) 

evaluated 105 years of climatological data from throughout the State of Wyoming, which 

revealed a slight upward trend temperature (0.16 °F per decade) (NCDC, 2010a). In the report, 

Global Climate Change Impacts in the United States (GCRP, 2009), the U.S. Global Change 

Research Team indicates that the temperatures in the past 15 years have risen even faster 

(1–2 °F for the Powder River Basin), most of which is attributed to warmer winters. This trend is 

expected to continue into the next decade, and by the end of this century, average annual 

temperatures in the Powder River Basin could rise as much as 4–8 °F (GCRP, 2009). 

In the 50-year period from 1958 to 2008, there was no obvious observable change in annual 

precipitation. However, the NCDC, in a similar evaluation of 105 years of climatological data for 

the entire State of Wyoming, revealed a slight downward trend in precipitation (0.13 inches per 

decade) (NCDC, 2010b). Nevertheless, the U.S. Global Change Research Team is predicting 

that the Northern Great Plains Region (which includes the Powder River Basin) would receive 

increased precipitation in future decades. Most of the precipitation is expected to fall in the 

colder months (winter and spring), and the summer and fall are to become drier. In addition, 

with the colder months expected to warm over the next several decades, more precipitation 

would fall in liquid form, resulting in less snow pack in the higher elevations (GCRP, 2009). 

The overall effect of projected climate change on the proposed Moore Ranch ISR facility is 

SMALL. The small predicted increases in temperatures and precipitation over the next decade 

would have no effect on any of the ISR phases. Because the major functioning of the facility is 

below ground, the effects of the surficial and atmospheric environments would not be expected 

to impact the target (ore body) aquifer. There could be an increase in recharge to the aquifer in 

future years, resulting from the projected increase in precipitation (and consequent infiltration 

into the groundwater) which could affect the proposed project by increasing the volume of 

groundwater in the ore body and improve the effectiveness of the aquifer restoration process. 
Cumulative Impacts

5-31 

Similarly, while potential changes to the site environment and resources such as ecology are 

plausible, the staff considers the small magnitude of the predicted climate changes over the 

period when the proposed action would occur would not be sufficient to alter the environmental 

conditions at the site in a manner that would significantly change the environmental impacts 

from what has been evaluated in this SEIS. 

5.7.1.5 GHG Mitigation Measures 

Best management practices (BMPs) and mitigation measures could be used to minimize the 

emission of GHGs at the proposed Moore Ranch Project. These include, but are not limited to: 

• Use of [fossil-fuel] vehicles that meet latest emission standards 

• Ensure that [diesel-powered] construction equipment and drill rigs are properly tuned 

and maintained 

• Use low-sulfur diesel fuel 

• Use newer, cleaner-running equipment 

• Avoid leaving equipment idling or running unnecessarily 

• Minimize the number of trips to well pads 

5.7.1.6 Other Mining Activities in the Powder River Basin 

Extensive research into the relative volumes of GHGs emitted by ISR facilities and other natural 

resource extraction methods has been performed. In support of the analysis for this final SEIS, 

the NRC staff surveyed the recent EISs issued for projects located in the Powder River Basin. 

Based on this survey, the NRC staff found that estimates and projections of the carbon footprint 

of the natural resource extraction activities vary widely. 

West Antelope II Coal Lease Application FEIS 

The FEIS for the West Antelope II Coal Lease Application also addressed greenhouse gas 

emissions as specifically related to the proposed action (Antelope Mine), the mine adjacent to 

the West Antelope II lease by application (LBA) tract. An inventory of expected greenhouse gas 

emissions in 2007 was conducted at Antelope Mine. Additionally, the applicant also projected 

emissions for a typical year of operations at Antelope Mine if the West Antelope II lands are 

leased and mined. Emissions are measured as CO2 equivalents (CO2e), a conversion to put 

any of the various gases emitted, (i.e., methane or nitrous oxides), into the equivalent 

greenhouse effect as compared to CO2 (BLM, 2008a). 

Emissions would be generated from the following: carbon fuels used in mining operations, 

electricity used onsite, blasting, methane released from mined coal, spontaneous combustion, 

onsite rail transport, and coal transported to purchasers (see Table 5-6). 

Projected emission rates increase if the West Antelope II tract is added to mining operations. 

The increase in CO2 emissions would result from the additional diesel fuel that would be used in 

consideration of the added haul distances and overburden hauling, as well as increased 

electricity and explosives related to increasing strip ratios (BLM, 2008a). 
Cumulative Impacts 

5-32 

Table 5-6. Annual Greenhouse Gas Emissions at the West Antelope II Mine 

Source 2007* Average year with West Antelope II LBA* 

Fuel 110,877 195,173 

Electricity 77,574 111,854 

Mining Process 36,772 40,884 

On-site Rail 1959 2251 

Total At Mine 227,182 347,911 

Other Rail† 656,444 754,338 

*CO2e in metric tons 

†Assumes 10-percent increase, based on demand in eastern United States

Source: BLM, 2008a 

The CCS estimated that activities in Wyoming accounted for 55.6 million metric tons of gross 

CO2e emissions in 2005 (Center for Climate Strategies, 2007). Using that estimate, the 2007 

Antelope Mine emissions total represents 0.41 percent of state-wide emissions. With the 

addition of the West Antelope II LBA tract, the projected total Antelope Mine emissions would 

represent 0.63 percent of state-wide emissions (BLM, 2008a). 

Wright Area Coal Lease Application DEIS 

The Wright Area Coal Lease Applications (BLM, 2009b) DEIS analyzes the environmental 

impacts of leasing six tracts of federal coal reserves adjacent to the Black Thunder, Jacobs 

Ranch, and North Antelope Rochelle mines. All are operating surface coal mines in the 

southern Powder River Basin (PRB), near the town of Wright, Wyoming. While BLM does not 

authorize mining through the issuance of a Federal coal lease, WDEQ, with oversight from the 

Office of Surface Mining (OSM), has regulatory authority in issuing permits to mine coal in 

Wyoming. However, BLM considered the impacts of mining coal because it is a logical 

consequence of issuing a maintenance lease to an existing coal mine. BLM analyzed GHG 

emissions specifically related to mining activities for the Black Thunder, Jacobs Ranch, and 

North Antelope Rochelle mines; adjacent to the North, South, and West Hilight Fields, 

West Jacobs Ranch, North Porcupine; and South Porcupine LBA tracts. The use of the coal 

after it is mined is not determined at the time of leasing. However, almost all coal that is 

currently being mined in the Wyoming PRB is being used to generate electricity by coal-fired 

power plants (BLM, 2009b). 

CO2e emissions are projected to increase at the Black Thunder, Jacobs Ranch and 

North Antelope Rochelle mines if these additional LBA tracts are added to the mining operations 

(see Table 5-7). The increase in CO2e emissions are expected to result from the additional 

fuels (especially diesel) that would be used in consideration of the increased coal and 

overburden haul distances, as well as increased use of electricity and explosives related to 

increasing overburden thicknesses. Estimates assume that the combined annual production 

rate from these three mines is 270 million tons (BLM, 2009b). 

The CCS estimated that activities in Wyoming will account for approximately 60.3 million metric 

tons of gross CO2e emissions in 2010 and 69.4 million metric tons in 2020 (CCS, 2007). Using 

the CCS projections, the 2007 emissions from the three conventional mines identified in Table 

5-7 would contribute 2.22 percent of the 2010 Wyoming state-wide emissions. The addition of 

six LBA tracts (the North Highlight Field, South Highlight Field, West Highlight Field, West 
Cumulative Impacts

5-33 

Table 5-7. Estimated Annual Equivalent CO2 Emissions* at the Black Thunder, Jacobs 

Ranch, and North Antelope Rochelle Mines 

Source 2007 With LBA Tracts 

Fuel 577,463 1,429,582 

Electricity 465,908 777,141 

Mining Process 201,871 296,166 

Total of Three 

Sources 

1,245,241 2,502,889 

*CO2e in metric tons Source: BLM, 2009b

Jacobs Ranch, North Porcupine, and South Porcupine) together with the conventional mines 

identified in Table 5-7, would increase the projected 2020 state-wide emissions to 3.61 percent 

(BLM, 2009b). 

5.8 Noise 

Cumulative impacts from noise were assessed within an 8-km [5-mi] radius of the proposed 

Moore Ranch Project. This area served as the cumulative assessment geographic boundary 

and was chosen because noise dissipates quickly from the source. The cumulative effects time 

frame runs from 2007 to 2020. 

The GEIS noted that noise would not be discernible to an offsite person at distances of greater 

than 300 m [1,000 ft] (NRC, 2009a). Section 4.8 of this SEIS evaluated potential noise impacts 

to the nearest resident who lives 4.5-km [2.8-mi] east of the center of the proposed license area. 

Because this person lives beyond 300 m [1,000 ft] of the proposed license area, there would be 

no noise impact above background levels. 

Past, present, and reasonably foreseeable future noise-generating activities in the vicinity of the 

proposed Moore Ranch Project would primarily be from traffic noise, oil and gas operations, 

CBM operations, and uranium mining/milling operations. The FEIS for the PRB Oil and Gas 

Project noted that sound levels from CBM operations would be expected to be unnoticeable at 

distances of 490 m [1,600 ft] and beyond, and the FEIS concluded there would be no 

cumulative noise impact on the surrounding area (BLM, 2003). CBM operations are active 

within the proposed license area. 

Although noise-related impacts are generally constrained to within a 610 m [2,000 ft] radius of 

activities associated with oil and gas development (e.g., drilling, operation of compressor 

stations) the level of energy-related development both on and around the proposed Moore 

Ranch Project has been increasing and is anticipated to continue to increase (BLM, 2003). 

The licensing of the proposed Moore Ranch Project would have a SMALL impact on noise 

generated in the area, as discussed in Section 4.8. Although other noise-generating activities 

(i.e., CBM operations) occur within an 8-km [5-mi] radius of the Moore Ranch ISR project, they 

do not overlap the proposed Moore Ranch Project. The noise generated from either the 

proposed Moore Ranch Project or from CBM operations would be at background levels at 

distances ranging from 300 m [1,000 ft] to 610 m [2,000 ft], as discussed above. Because the 

nearest resident is located 4.5-km [2.8 mi] east of the center of the proposed license area, there 

would be a SMALL noise-related impact. As discussed previously in Section 5.3, truck traffic 

would increase if the Moore Ranch project were operated as a satellite, but it would still 
Cumulative Impacts 

5-34 

represent only a small fraction of the average daily traffic on SR 387. Therefore, the proposed 

project (or satellite facility) would have a SMALL incremental impact on noise when added to the 

SMALL cumulative impacts expected from other past, present, and reasonably foreseeable 

future actions. Furthermore, noise levels would be mitigated by the use of administrative and 

engineering controls to maintain noise levels in work areas below OSHA regulatory limits. 

5.9 Historical and Cultural Resources 

The assessment of the cumulative impact on historical and cultural resources was defined with 

regard to activities occurring within the area of potential effects (APE), which includes the 

project site, access roads, and a 3.2-km [2 mi] buffer area outside the proposed license area. 

This area serves as the geographic study area for this resource. 

The potential impact on cultural resources from implementing the proposed Moore Ranch 

Project (or satellite facility) was estimated to be SMALL because the ISR lifecycle was not 

expected to directly impact specific archaeological sites determined to be eligible for listing on 

the National Register of Historic Places (NRHP), as discussed in Section 4.9 of this SEIS. 

BLM identified various actions that may have cumulative impacts within the greater Powder 

River Basin (2009b). These actions included coal extraction, oil and gas operations, utility 

transmission and distribution actions, other mining/milling actions including uranium, wind power 

activities, reservoir development, various nonenergy-related developments including 

transportation, and county-level economic development actions. 

As previously noted, six other ISR facilities located within 80-km [50-mi] of the proposed Moore 

Ranch Project are either operating or planned. CBM activities are occurring, and are planned to 

occur, within the proposed license area, and oil and gas development within the planning area 

of the BLM Buffalo Field Office is expected to continue. 

However, any potential impacts to historic and cultural resources would likely be minimized for 

projects occurring on Federal or State lands or which are funded in part by the government 

since these projects would be subject to the National Historic Preservation Act (NHPA), 

Section 106 consultation process, and applicable statutes. 

The proposed Moore Ranch ISR project is projected to have a SMALL incremental impact on 

historical and cultural resources when added to the MODERATE cumulative impact to these 

resources expected from the other past, present, and reasonably foreseeable future actions 

described in Section 5.1.1. The proposed Moore Ranch Project is located in an 

archaeologically rich area; therefore, the activities described above could result in a cumulative 

loss of historic and cultural resources. However, any past, present, or future actions that occur 

on Federal lands or require a Federal permit would require a Section 106 Consultation, which 

would ensure that historical and cultural resources are adequately considered.

5.10 Visual and Scenic Resources 

The cumulative impact on visual and scenic resources was considered within the area 

administered by the BLM Buffalo Field Office. 

The development of the proposed Moore Ranch Project would have a SMALL impact on visual 

and scenic resources because the facility would be located in a BLM visual resource 
Cumulative Impacts

5-35 

management (VRM) Class IV area, which allows an activity to contrast with the basic elements 

of the characteristic landscape to a much larger degree. 

However, within the area administered by the BLM Buffalo Field Office and within the Powder 

River Basin region, energy development is expected to grow over the next 15 to 20 years and 

would involve constructing railroads, coal-fired power plants, major (230 kV) transmission lines, 

coal technology projects, oil and gas transportation pipelines and refineries, and CBM 

processing plants. Within the BLM Buffalo Field Office planning area, there are other ongoing 

or planned uranium recover projects, oil and gas developments, and CBM projects, all that have 

an impact on visual and scenic resources. 

The proposed Moore Ranch ISR project is projected to have a SMALL incremental impact on 

visual and scenic resources when added to the MODERATE cumulative impact to the viewshed 

expected from other past, present, and reasonably foreseeable future actions. The lower profile 

and smaller footprint associated with operating the Moore Ranch project as a satellite facility 

would reduce visual impacts as compared to constructing and operating a Central Plant. 

5.11 Socioeconomics 

The cumulative socioeconomic impact was considered within the Powder River Basin because 

mineral extraction dominates activities within this area. The following socioeconomic indicators 

were evaluated as part of this analysis: 

• Population 

• Employment 

• Housing 

• School enrollment 

• Public services 

• Fiscal revenue 

Socioeconomic impacts from the proposed Moore Ranch Project (or satellite facility) would 

range from SMALL to MODERATE, depending on the phase of the ISR lifecycle and the 

particular socioeconomic characteristic (e.g., finance, demographics) as discussed in 

Section 4.11 of this SEIS. The GEIS socioeconomic analysis is based on 2000 U.S. Census 

Bureau data. Data presented in this SEIS for the proposed Moore Ranch Project region of 

influence (ROI) is based on a combination of 2000 U.S. Census Bureau data, U.S. Census 

Bureau 2005–2007 American Community Survey 3-Year Estimates, and U.S. Census Bureau 

2009 State and County QuickFacts. Though specific numbers may differ, the analysis of 

socioeconomics presented in Section 4.3.10 of the GEIS remains valid for the proposed Moore 

Ranch Project. Additionally, REMI Policy Insight (REMI), a professionally recognized regional 

economic model, was employed to develop the cumulative employment and population 

projections presented next, as part of the BLM PRB Coal Review Task #C Report: Cumulative 

Social and Economic Effects (BLM, 2005a,b,c). The model used two future scenarios that 

assume a lower and upper coal-production scenario in the PRB. The two scenarios represent a 

range of economic activity derived by combining the range of future coal production with other 

identified foreseeable activities, including oil and gas production and other mining operations. 

The timeframe for the analysis spans from 2007 to 2020, although older data was incorporated 

to demonstrate historical trends. 
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Cumulative Impacts 

5-38 

There could be incremental impacts to local government facilities and public services. 

Population increases in affected counties and communities generally result in across-the-board 

increases in demand on services. Additionally, various reasonably foreseeable development 

activities may result in increased demand for specific services (e.g., road maintenance, law 

enforcement, and emergency response). Incremental impacts to government facilities and 

public services from the proposed Moore Ranch Project would be SMALL, based on the 

relatively low number of employees required for all phases of the project. 

There could be additional cumulative impacts to socioeconomic resources if extractive 

industries and power production were to increase above average historic levels of growth. A 

cumulative negative impact could result if the housing supply and real estate market could not 

meet the labor demands in the extractive industries. There could be a long-term impact on local 

schools; healthcare facilities; fire and police services; and infrastructure, including waste 

management facilities, if large industrial projects created a demand for labor in the PRB. 

If the population size were to remain stable or grow at a rate that the area could manage 

(approximately 2 percent per year based on past experience), the local economy could be 

positively affected by multiple mining/milling operations occurring simultaneously, which would 

generate local and State economic revenue. However, the maximum number of jobs 

associated with the proposed Moore Ranch Project would be approximately 50 employees 

during construction while 40 to 60 workers would be needed for operation and restoration 

phases. This represents a relatively small pool of workers compared to the sizable increases 

projected for employment under both BLM Coal Review scenarios, in addition to growth 

associated with CBM development. As such, any incremental impact on local finances would 

be SMALL. 

Based on assessments of population, employment, housing, school enrollment, public services 

and local finances, the proposed project is projected to have a SMALL incremental impact on 

socioeconomic resources when added to the MODERATE cumulative impacts expected from 

other past, present, and reasonably foreseeable future activities described in Section 5.1.1 of 

this SEIS. 

5.12 Environmental Justice 

No concentrations of people living below the poverty level and no concentrated minority 

populations are located near the proposed project area; therefore, no disproportionately high 

and adverse environmental impacts would result to minority populations or those living below 

the poverty level from the proposed Moore Ranch ISR Project (or a satellite facility). 

Environmental justice impacts related to the proposed Moore Ranch ISR project are discussed 

in more detail in Section 4.12 of this SEIS. 

The percentage of people living below the poverty level within the census block groups 

surrounding the proposed Moore Ranch Project is well within the 20 percent level of significance 

compared to the state and county proportion of those living in poverty. 

The GEIS identified no minority populations in the Wyoming East Uranium Milling Region. SEIS 

Section 4.12 determined that the percentage of minority populations living in the affected block 

groups in the vicinity of the proposed Moore Ranch Project site is similar to the percentage of 

minority populations recorded at the State and county level and well below the national level. 

Therefore, no minority populations were identified as residing near the proposed Moore 

Ranch Project. 
Cumulative Impacts

5-39 

The relative homogeneity of Wyoming, despite 40 years of energy/natural resource 

development, indicates that environmental justice issues do not pose a problem. Because the 

economic base of the study area is largely ranching and resource extraction, low-income areas 

are widely dispersed within the study area. People with incomes below the poverty status may 

reside within the study area, but not disproportionately. At the present time, there is no 

significant concentration of people living below the poverty level and no significant concentration 

of minority populations located near the proposed project. Furthermore, human health and 

environmental impacts throughout the lifecycle of the proposed project are predicted to be 

SMALL for the general population. Therefore, the proposed project is projected to have a 

SMALL incremental impact on environmental justice when added to the SMALL cumulative 

impacts expected from other past, present, and reasonably foreseeable future actions. 

5.13 Public and Occupational Health and Safety 

The cumulative impact on public and occupational health and safety was considered within an 

80-km [50-mi] radius of the proposed Moore Ranch Project. The public and occupational health 

and safety impacts from the proposed Moore Ranch Project would be expected to be SMALL, 

under normal operations because the potential radiological exposure would be consistent with 

background. Under accident conditions, the potential exposure could be MODERATE, as 

discussed in Section 4.13 of this SEIS. The annual dose to the population located within 80-km 

[50-mi] of the proposed Moore Ranch ISR Project would be far below applicable NRC 

regulations. If an accident were to occur, the potential impact could be MODERATE if the 

appropriate mitigation measures and other procedures that ensure worker safety were 

not followed. 

The proposed Moore Ranch ISR Project site is located within the GEIS Wyoming East Uranium 

Milling Region, which contains 21 previous, current, or potential uranium-handling sites 

(NRC, 2009a). The GEIS (NRC, 2009a) identified eight draft or final EISs submitted from 

January 2005 to February 2008 for projects that could contribute to a cumulative impact on 

public and occupational health and safety within the Wyoming East Uranium Milling Region. In 

addition, the GEIS identified ten programmatic EISs affecting the entire State of Wyoming. No 

additional projects initiated since February 2008 were identified that would contribute to the 

cumulative impact on radiological public health and safety. As noted previously, the proposed 

Moore Ranch Project would have a SMALL impact on public health and safety consistent with 

background radioactivity under normal operations. Because the identified projects within an 

80-km [50-mi] radius of the proposed Moore Ranch Project would not significantly contribute to 

the cumulative public and occupational health and safety effects from the identified projects, the 

cumulative impact would be SMALL. 

The maximum expected exposure to any member of the public from the proposed Moore Ranch 

Project, as with other operating ISR facilities in the United States, would be expected to be less 

than 10 mrem per year at the site boundary (NRC, 2009a). This exposure, combined with 

exposures from other facilities, is expected to remain far below the regulatory public limit of 

100 mrem/year and have a negligible contribution to the 620 mrem average yearly dose 

received by a member of the public from all sources. Therefore, the proposed project is 

projected to have a SMALL incremental impact on public and occupational health and safety 

when added to the SMALL cumulative impacts expected from other past, present, and 

reasonably foreseeable future actions described in Section 5.1.1 of this SEIS. 
Cumulative Impacts 

5-40 

5.14 Waste Management 

Waste management impacts from the proposed Moore Ranch Project would be SMALL, as 

discussed in Section 4.14 of this SEIS. 

As discussed in Section 2.7 of the GEIS, all stages of the proposed Moore Ranch Project 

(construction, operation, aquifer restoration, and decommissioning) would generate effluents 

and waste streams, all of which must be handled and disposed of properly. These would 

include liquid wastes and solid wastes. Any wastewater generated during or after the uranium 

extraction phase of site operations are classified as byproduct material (NRC, 2000). Based on 

information provided by the applicant in EMC (2007) (Section 2.1.1.1.6), during the operations 

phase, the proposed Moore Ranch Project would be anticipated to annually produce 

approximately 170 to 550 Lpm [45 to 145 gpm] of liquid byproduct material, 76 m3

 [100 yd3] of 

solid byproduct material, and 1,530 m3

 [2,000 yd3] of nonhazardous solid waste. Because of 

demolition and disposal of buildings, equipment, and contaminated soil, the amount of solid 

waste [both byproduct material and nonhazardous waste] generated during decommissioning 

would be greater. The applicant indicates that solid wastes would be reused, recycled, or 

compacted, as appropriate. As discussed in Section 2.1.1.1.6, solid byproduct material that 

could be decontaminated would also be disposed of as nonhazardous solid waste, but all waste 

would ultimately need to be disposed of, with totals (Uranium One, 2008) on the order of 

• 11,010 m3

 [14,390 yd3] of solid byproduct material, the largest part of which is chipped 

trunkline, plant equipment, and contaminated soil from wellfields 

• 512 t [565 T] of solid byproduct material in the form of contaminated demolition concrete 

from demolition of plant building foundations and structures 

• 482 m3

 [630 yd3] of nonhazardous solid waste (plant equipment) 

• 6,102 t [6,730 T] of nonhazardous solid waste in the form of uncontaminated concrete 

from plant building foundations and structures 

These decommissioning waste estimates are preliminary. When the applicant initiates 

decommissioning, they will be required to provide updated waste volume estimates. The NRC 

staff would conduct an environmental review at that point to evaluate potential waste 

management cumulative impacts from the proposed decommissioning activities. Given an 

operating period of about 12 years (EMC, 2007a,b), the total amount of solid byproduct material 

to be generated through the end of decommissioning would be about 14,395 m3

 [15,878 yd3] 

and the total amount of nonhazardous solid waste for offsite disposal would be about 25,443 m3

[28,064 yd3

]. Because of the smaller footprint, the amount of both nonhazardous solid waste 

and byproduct material resulting from decommissioning a Moore Ranch satellite facility would 

be reduced as compared to decommissioning a central processing plant. All other waste 

streams would remain largely the same because wellfield operations and aquifer restoration 

would not change for a satellite facility. 

Past, present, and reasonably foreseeable future activities in the vicinity of the proposed 

Moore Ranch ISR project site that could generate nonhazardous solid, hazardous, or 

radioactive wastes include uranium mining/milling activities, CBM activities, and oil and gas 

exploration. Each of these facilities would generate solid and hazardous wastes and would be 

responsible for complying with applicable regulations and site-specific license agreements that 

manage generated wastes. Within an 80-km [50-mi] radius of the proposed Moore Ranch ISR 
Cumulative Impacts

5-41 

Project, there are at least six operating or planned ISR facilities that would generate waste 

volumes consistent with that projected for the proposed project. The cumulative effects on past, 

present, and reasonably foreseeable actions that would contribute to the total amount of 11e.(2) 

byproduct material generated by ISR facilities could therefore be as much as about 100,767 m3

[111,146 yd3

] (i.e., 14,395 m3 [15,878 yd3] x 7 facilities). Similarly, the cumulative volume of 

nonhazardous solid waste that could be generated is approximately 178,103 m3

 [196,448 yd3]. 

The applicant indicates that it will be seeking permits from the WDEQ for two or more deep 

disposal wells for liquid byproduct material (EMC, 2007a,b). Additional deep disposal well use 

in the region is anticipated as additional facilities are licensed. The state permitting process for 

these evaluates the suitability of proposals to ensure groundwater resources are protected and 

potential environmental impacts would be limited to acceptable levels. Based on the 

assumption that the state would not permit deep injection wells that would have a significant 

potential to impact groundwater resources, the staff conclude the cumulative impacts of using 

deep disposal wells for the proposed action along with the potential impacts from reasonably 

foreseeable future actions would be SMALL. 

The applicant also indicates that it is pursuing several disposal options for the disposal of solid 

byproduct material, including both in-state and out-of-state disposal, but has not yet finalized a 

contract established with an NRC-or State-licensed disposal facility (EMC, 2007a,b). Available 

local capacity for disposal of byproduct material is at the Pathfinder-Shirley Basin site in Mills, 

Wyoming. As reasonably foreseeable additional ISR sites are licensed this local capacity may 

become limited. Future ISR applicants could engage other low-level radioactive waste disposal 

facilities that are licensed to accept byproduct material. Another existing facility that is licensed 

by NRC to accept byproduct material for disposal is the Rio Algom Ambrosia Lake uranium mill 

tailings impoundments near Grants, New Mexico. Additionally, three sites are licensed by NRC 

Agreement States to accept byproduct material for disposal (i.e., the Energy Solutions site in 

Clive, Utah; the White Mesa uranium mill site in Blanding, Utah; and the Waste Controls 

Specialists site in Andrews, Texas). Based on the disposal options currently available, and the 

disposal agreement that NRC requires prior to operations, the staff concludes that the potential 

cumulative waste management impacts associated with the generation of byproduct material 

would be SMALL. 

Licensees must also comply with applicable State and Federal regulations with respect to 

disposing of solid and hazardous wastes. Based on the small projected quantities of hazardous 

wastes generated by the proposed action and other similar reasonably foreseeable ISR facilities 

that could be licensed in the region in the future, the staff conclude the potential cumulative 

impacts from the additional generation hazardous wastes would be SMALL. 

The applicant indicates that nonhazardous solid waste would be disposed of at the Casper 

landfill in Casper, Wyoming. Considering year 2005 estimates of waste disposed of at the 

Casper balefill (landfill) from the Wyoming Office of State Lands and Investments (OSLI, 2007) 

of 93,804 t [103,466 T], the aforementioned cumulative decommissioning nonhazardous solid 

waste volume resulting from the proposed action would constitute approximately 16 percent of 

the volume of waste that would be disposed at the Casper balefill over the next 12 years if the 

regional waste generation continued at the 2005 level. Based on this comparison, the staff 

concludes the region has sufficient capacity to dispose of the nonhazardous solid waste 

generated from the proposed action. Therefore, the waste management impacts for disposal of 

decommissioning nonhazardous solid waste would be SMALL. 
Cumulative Impacts 

5-42 

Assuming that the applicant obtains the necessary permits and contractual agreements for 

disposing of its byproduct material, the proposed Moore Ranch ISR project is projected to have 

a SMALL incremental impact on waste management when added to the SMALL cumulative 

impacts expected from other past, present, and reasonably foreseeable future action described 

in Section 5.1.1. 

5.15 References 

40 CFR Parts 1500 and 1508. Code of Federal Regulations, Title 40, Protection of 

Environment, Part 1500, “Purpose Policy and Mandate” and Part 1508, “Terminology and 

Index.” 

AECOM, 2009. “Update of Task 3A Report for the Powder River Basin Coal Review Cumulative 

Air Quality Effects for 2020.” Prepared for U.S. Bureau of Land Management High Plains 

District Office, Wyoming State Office, and Miles City Field Office. Fort Collins, Colorado: 

AECOM, Inc. December. 

Anderson, N.B., R.A. Beach, A.W. Gray, C.A. Roberts, D.A. Ferderer, M.J. Gobla, 1990. 

“Occurrences for Wyoming.” U.S. Department of the Interior, U.S. Bureau of Mines. Denver, 

Colorado. <URL:http://www.wygisc.uwyo.edu/clearinghouse/mineral.html> (03 May 2010) 

Becker, J.M., C.A. Duberstein, J.D. Tagestad, and J.L. Downs, 2009. “Sage-Grouse and Wind 

Energy: Biology, Habits, and Potential Effects of Development.” Prepared for the 

U.S. Department of Energy Office of Energy Efficiency and Renewable Energy Wind & 

Hydropower Technologies Program under Contract DE–AC05–76RL01830. 

<http://www.pnl.gov/main/publications/external/technical_reports/pnnl-18567.pdf> 

(28 April 2010). 

BLM (U.S. Bureau of Land Management, 2010a. Wyoming GIS Available Data 

<http://www.blm.gov/wy/st/en/resources/public_room/gis/datagis.html> (03 May 3 2010). 

BLM, 2010b. “Powder River Basin Coal.” <http://www.blm.gov/wy/st/en/programs/energy/ 

Coal_Resources/PRB_Coal.html> (June 2010). 

BLM, 2009a. “Final Environmental Impact Statement for the South Gillette Area Coal Lease 

Applications WYW172585, WYW173360, WYW172657, WYW161248.” 

<http://www.blm.gov/wy/st/en/info/NEPA/HighPlains/Wright-Coal.html> (17 September 2009). 

BLM, 2009b. “DRAFT Environmental Impact Statement for the Wright Area Coal Lease 

Applications.” Vol 1 and 2. BLM/W/PL-09/026+1320. Casper, Wyoming: U.S. Department of 

Interior, BLM, High Plains District Office. June, 2009. 

BLM, 2009c. “Summary of the Analysis of the Management Situation Buffalo Resource 

Management Plan Revision.” BLM, Buffalo Field Office. <http://www.blm.gov/wy/st/en/ 

programs/Planning/rmps/buffalo/docs.html> (September 2009). 

BLM, 2009d. “Draft Reasonable Foreseeable Development Scenario for Oil and Gas Buffalo 

Field Office Planning Area, Wyoming.” <http://www.blm.gov/pgdata/etc/medialib/blm/wy/ 

programs/planning/rmps/buffalo/docs/rfd.Par.69667.File.dat/01_text.pdf> (23 April 2010) 
Cumulative Impacts

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BLM, 2009e. “Update of the Task 2 Report for the Powder River Basin Coal Review Past and 

Present and Reasonably Foreseeable Development Activities.” <http://www.blm.gov/wy/st/en/ 

programs/energy/Coal_Resources/PRB_Coal/prbdocs/coalreview/task_2_update__12.html> 

(24 April 2010). 

BLM, 2009f. “Final Mineral Occurrence and Development Potential Report Buffalo Resource 

Management Plan Revision.” BLM Buffalo Field Office, Wyoming. .<http://www.blm.gov/ 

pgdata/etc/medialib/blm/wy/programs/planning/rmps/buffalo/docs.Par.90169.File.dat/RevisedFin

alMineralReport_Part1.pdf> (23 April 2010). 

BLM, 2009g. “Update Of The Task 3d Report For The Powder River Basin Coal Review 

Cumulative Environmental Effects.” BLM High Plains District Office and Wyoming State Office. 

<http://www.blm.gov/wy/st/en/programs/energy/Coal_Resources/PRB_Coal/prbdocs/coalreview

/task_3d_update__12.html> (24 April 2010). 

BLM, 2008a. “Final Environmental Impact Statement for the West Antelope II Coal Lease 

Application WYW163340.” <http://www.blm.gov/wy/st/en/info/NEPA/cfodocs/ 

West_Antelope_II.html> (September 2009). 

BLM, 2008b. “Fortification Creek Area Draft Resource Management Plan 

Amendment/Environmental Assessment.” . <http://www.blm.gov/wy/st/en/info/NEPA/ 

bfodocs/fortification_creek.html> (September 2009). 

BLM, 2005a. “Task 1D Report for the Powder River Basin Coal Review Current Environmental 

Conditions.” <http://www.blm.gov/wy/st/en/programs/energy/ 

Coal_Resources/PRB_Coal/prbdocs/coalreview/Task1D.html> (September 2009). 

BLM, 2005b. “Task 2 Report for the Powder River Basin Coal Review Past and Present and 

Reasonably Foreseeable Development Activities.” <http://www.blm.gov/wy/st/en/programs/ 

energy/Coal_Resources/PRB_Coal/prbdocs/coalreview/Task2.html> (September 2009). 

BLM, 2005c. “Task 3D Report for the Powder River Basin Coal Review Cumulative 

Environmental Effects.” <http://www.blm.gov/wy/st/en/programs/energy/ 

Coal_Resources/PRB_Coal/prbdocs/coalreview/task3d.html> (September 2009). 

BLM, 2003. “Final Environmental Impact Statement and Proposed Plan Amendment for the 

Powder River Basin Oil and Gas Project.” <http://www.blm.gov/wy/st/en/info/ 

NEPA/bfodocs/prb_eis.html> (September 2009). 

CCS (Center for Climate Strategies), 2007. “Wyoming Greenhouse Gas Inventory and 

Reference Case Projections 1990–2020. Cheyenne, Wyoming: Center for Climate Strategies. 

Spring 2007. 

CEQ (Council on Environmental Quality), 1997. ”Considering Cumulative Effects Under the 

National Environmental Policy Act.” 

EIA (US. Energy Information Administration), 2007. <http://www.eia.doe.gov/pub/oil_gas/ 

natural_gas/analysis_publications/maps/maps.htm#geodata> (03 May 2010) 
Cumulative Impacts 

5-44 

EMC (Energy Metals Corporation U.S.), 2007a. “Application for USNRC Source Material 

License, Moore Ranch Uranium Project, Campbell County, Wyoming, Environmental Report.” 

Casper, Wyoming: Uranium One Americas Corporation. ADAMS Accession 

Nos. ML072851222, ML072851229, ML072851239, ML07285249, ML07285253, ML07285255. 

EMC, 2007b. “Application for USNRC Source Material License, Moore Ranch Uranium Project, 

Campbell County, Wyoming, Technical Report.” Casper, Wyoming: Uranium 1 Americas 

Corporation. ADAMS Accession Nos. ML072851222, ML072851258, ML072851259, 

ML072851260, ML072851268, ML072851350, ML072900446. October 2. 

ENSR International, 2006. “Task 3A Report for the Powder River Basin Coal Review 

Cumulative Air Quality Effects.” Fort Collins, Colorado: ENSR International. February. 

EPA, 1996. “Compilation of Air Emission Factors, Volume 1: Stationary and Point Sources.” 

AP-42, Fifth Edition: Chapters 3.3 and 3.4. Washington, DC. EPA. October. 

EPA, 2009a. “Climate Change—Climate Emission, Non-CO2 Mitigation.” Washington, DC: 

EPA. September. <http://www.epa.gov/climatechange/economics/mitigation.html>. 

EPA, 2009b. “Endangerment and Cause or Contribute Findings for Greenhouse Gasses Under 

Section 202(A) of the Clean Air Act (40 CFR Chapter 1).” Final Rule 74 FR 66496. 

Washington, DC: EPA. December. 

EPA, 2010a. “Climate Change, High GWP Gases.” Washington, DC: EPA. March. 

<http://www.epa.gov/highgwp>. 

EPA, 2010b. “Climate Change—Greenhouse Gas Emissions.” Washington, DC: EPA. April. 

<http://www.epa,gov/climatechange/emissions/index.html>. 

GCRP (U.S. Global Change Research Program), 2009. “Global Climate Change Impacts in the 

United States.” Cambridge University Press. 2009 

Federal Highway Administration, 2006. Highway Statistics 2005. Table VM–1. Washington, 

DC: Federal Highway Administrati9on. 

NCDC (National Climatic Data Center), 2009. Record of Climatological Observations: Need to 

Insert NWS stations for Powder River Basin.” Ashville, North Carolina: NCDC. August. 

NCDC, 2010a. “Climate at a Glance—Annual Wyoming Temperature.” Ashville, 

North Carolina: NCDC. May. 

National Environmental Policy Act of 1969 (NEPA). 42 USC 4321 et seq. 

Naugle, D.E, K.E. Doherty, B. Walker, M.J. Holloran, and H.E. Copeland, 2009. “Chapter 21. 

Energy Development and Greater Sage-Grouse.” Ecology and Conservation of Greater 

Sage-Grouse: A Landscape Species and Its Habitats.” Studies in Avian Biology, Prepublication 

release. <http://sagemap.wr.usgs.gov/Docs/SAB/Chapter21.pdf> (28 April 2010). 

NCDC, 2010b. “Climate at a Glance—Annual Wyoming Precipitation.” Ashville, North Carolina: 

NCDC. May. 

NRC (U.S. Nuclear Regulatory Commission), 2010. NUREG–1555, “Supplemental Staff 

Guidance to NUREG-1555, "Environmental Standard Review (ESRP) for Consideration of the 

Effects of Greenhouse Gases and of Climate Change.” Washington, DC: NRC. March. 
Cumulative Impacts

5-45 

NRC (U.S. Nuclear Regulatory Commission), 2009a. NUREG–1910,“Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

NRC, 2009b. “Expected New Uranium Recovery Facility Applications/Restarts/Expansions: 

Updated 3/11/2009” <http://www.nrc.gov/info-finder/materials/uranium/2008-ur-projects-listpublic.pdf> (07 April 2009). 

NRC, 2003. NUREG–1569, “Standard Review Plan for In-Situ Leach Uranium Extraction 

License Applications.” Final Report. Washington, DC: June. 

NRC. 1998. “Environmental Assessment for Renewal of Source Material License No. SUA–

1341, Cogema Mining, Inc. Irigaray and Christensen Ranch Projects, Campbell and Johnson 

Counties, Wyoming.” Docket No. 40-8502. Washington, DC: NRC. June 1998. 

OSLI (Office of State Lands and Investments), 2007. “Wyoming Biomass Inventory: Animal 

Waste, Crop Residue, Wood Residue, and Municipal Solid Waste.” Cheyenne, Wyoming: 

OSLI, Wyoming State Forestry Division. March. 

Russell, J. and A. Pollack, 2005. “Final Report: Oil and Gas Emission Inventories for the 

Western States.” Novato, California: Environ International Corporation. December 27. 

Scire, J. S., D.S. Strimitis, and R.J. Yamartino, 1999. “A User’s Guide for the CALPUFF 

Dispersion Model (Version 5.0).” Concord, Massachusetts: Earth Tech, Inc. October. 

Stoeckenious. T., 2010. “Final Report: A Conceptual Model of Winter Ozone Episodes in 

Southwest Wyoming.” 06–20441E. Novato, California: Environ International Corporation. 

January 29. 

Stoeckenious. T., S. Lau, E. Tai, R. Morris, M. Jimenez, and J. Russell, 2006. “Final Report: 

Southwest Wyoming NO2 PSD Increment Consumption Modeling: Results for Sublette County.” 

Novato, California: Environ International Corporation. May 22. 

Uranium One, 2008. Response to Request for Additional Information for the Moore Ranch In 

Situ Uranium Recovery Project License Application (TAC JU011),” ADAMS Accession No. 

ML082060527. July 11, 2008. 

UCSB (U.S. Census Bureau), 2009. “State and County QuickFacts for Campbell, Johnson, and 

Natrona Counties, Wyoming.” <http://quickfacts.census.gov> (September 10, 2009). 

USGS (U.S. Geological Survey), 2003. “Principal Aquifers of the 48 Conterminous United 

States, Hawaii, Puerto Rico, and the U.S. Virgin Islands.” <http://nationalatlas.gov/ 

atlasftp.html> (03 May 2010). 

Uranium One, 2010. Email from J.F. Winter, Manager Environmental and Regulatory Affairs, 

Uranium One to R. Linton, Safety Review Project Manager, NRC. Subject: Response to 

Cumulative Impacts on Satellites Final 4.21.10 (1).doc. April 21, 2010. ADAMS Accession No. 

ML101160084. 

Wyoming Department of Administration and Information, Economic Analysis Division, 2008. 

<http://eadiv.state.wy.us/pop/pop.html> (26 April 2010) 
Cumulative Impacts 

5-46 

WDEQ (Wyoming Department of Environmental Quality), 2009. Re: Permit No. CT–8644.” 

Letter (October 2) from D.A. Finley to M. P. Thomas, Uranerz Energy Corporation. Cheyenne, 

Wyoming: WDEQ, Air Quality Division. 2009. 

WDEQ, 2010. “Re: Permit No. CT-7896.” Letter (January 4) from D.A. Finley to J. Cash, Lost 

Creek ISR, LLC. Cheyenne, Wyoming: WDEQ, Air Quality Division. 

 

USGS (U.S. Geological Survey), 2003. “Principal Aquifers of the 48 Conterminous United 

States, Hawaii, Puerto Rico, and the U.S. Virgin Islands.” <http://nationalatlas.gov/ 

atlasftp.html> (03 May 2010). 

Wyoming Oil and Gas Conservation Commission, 2010. <http://wogcc.state.wy.us> 

(04 May 2010). 

Wyoming Mining Association, 2008. “Wyoming Coal Data.” <http://www.wmaminelife.com/coal/coalfrm/coaldat.htm> (28 October 2009).
 6-1 

 

6 ENVIRONMENTAL MEASUREMENTS AND MONITORING PROGRAMS 

6.1 Introduction 

As discussed in the Generic Environmental Impact Statement for In-Situ Leach Uranium Milling 

Facilities (GEIS, NUREG–1910, NRC, 2009) (Section 8.0), monitoring programs, in general, are 

developed for in-situ uranium recovery (ISR) facilities to verify compliance with standards for the 

protection of worker health and safety in operational areas and for protection of the public and 

environment beyond the facility boundary (NRC, 2009). Monitoring programs provide data on 

operational and environmental conditions so that prompt corrective actions can be implemented 

if an adverse condition is detected. In this regard, these programs help to limit the potential 

environmental impacts at ISR facilities and the surrounding areas. 

Required monitoring programs can be modified to address unique site-specific characteristics 

by the addition of license conditions based on the U.S. Nuclear Regulatory Commission (NRC) 

site-specific safety and environmental reviews. 

The discussion of the proposed monitoring programs for the proposed Moore Ranch Project is 

organized in the following manner: 

• Radiological monitoring (Section 6.2) 

• Physiochemical monitoring (Section 6.3) 

• Ecological monitoring (Section 6.4) 

6.2 Radiological Monitoring 

This section describes the Uranium One Americas’ (Uranium One) proposed radiological 

monitoring program as described in its license application (EMC, 2007a,b) and subsequent 

responses to the NRC requests for additional information (Uranium One, 2009). The purpose of 

this monitoring program is to characterize and evaluate the radiological environment, to provide 

data on measurable levels of radiation and radioactivity, and to provide data on the principal 

pathways of radiological exposure to the public and workers (NRC, 2003). 

In accordance with NRC regulations in 10 CFR Part 40, Appendix A, Criterion 7, a 

preoperational monitoring program is required to establish the facility baseline conditions. 

Following this baseline program, operators of ISR facilities are required to conduct an 

operational monitoring program to measure or evaluate compliance with standards and to 

evaluate the environmental impact of an ISR facility under operational conditions. Although not 

a requirement, NRC Regulatory Guide 4.14 (NRC, 1980) provides guidance for implementing 

monitoring programs that are acceptable to the NRC staff for uranium mills, including 

ISR facilities. 

The results of the Uranium One’s baseline monitoring program are discussed in Section 3.12.1 

of this SEIS. The following sections provide a brief description of the applicant’s proposed 

operational monitoring program. 
Environmental Measures and Monitoring 

 6-2

6.2.1 Airborne Radiation Monitoring 

Uranium One proposes to implement an airborne radiation monitoring program to detect radon 

and air particulate releases from the central plant processes. Figure 6-1 shows the air sampling 

locations proposed by the applicant, which, based on the recommendations in Regulatory 

Guide 4.14, include a minimum of three air monitoring stations at or near the site boundaries, 

one station at or close to the nearest structure within 10 km [6.2 mi] of the site, and one station 

at a control or background location. These operational monitoring locations would be the same 

as those used to perform the baseline analysis described in Section 3.12.1. However, the NRC 

staff did not concur with the applicant’s proposed air particulate sampling locations because the 

proposed sampling program would not monitor downwind locations from the predominant wind 

directions. Therefore, the NRC will impose license conditions to ensure air particulate sampling 

locations and the nearest resident location are sampled in accordance with Regulatory 

Guide 4.14. 

Air particulate monitoring would be performed using low volume samplers. Filters would be 

collected weekly to help prevent dust loading and would be analyzed for average Ra-226, 

natural uranium, Th-230, and Pb-210 concentrations and detection levels. Results of the 

operational air particulate monitoring program would be reported in the semi-annual effluent 

reports to the NRC, as required by 10 CFR 40.65. Radon sampling would be conducted at the 

air particulate sampling locations using Track-Etch radon cups which would be exchanged 

semiannually and analyzed to determine radon concentrations (in pCi/L). In addition to the 

environmental monitoring, Uranium One would estimate the release of radon from process 

operations using MILDOS-AREA modeling and would report results in the semi-annual effluent 

reports required by 10 CFR 40.65. 

Figure 6-1. Proposed Moore Ranch Project Operational Environmental 

Monitoring Locations 
 Environmental Measures and Monitoring 

 6-3

6.2.2 Soils and Sediment Monitoring 

During operations, Uranium One would conduct soil sampling on an annual basis. Samples 

would be collected to a depth of 5 cm for consistency with the baseline soil sampling surveys 

described in Section 3.12.1. Following Regulatory Guide 4.14, discrete grab samples of surface 

soils would be collected at the four air particulate sampling locations shown in Figure 6-1 and 

would be analyzed for natural uranium, Ra-226, and Pb-210. Prior to decommissioning, 

following the conclusion of operations, subsurface soil samples would be taken to compare the 

results with subsurface soil samples collected as part of the pre-operational monitoring program. 

6.2.3 Vegetation, Food, and Fish Monitoring 

As described in Section 3.12.1, Uranium One conducted pre-operational vegetation sampling in 

2007 at various locations on the Moore Ranch site. The applicant evaluated the ingestion 

pathway to individuals from vegetation using the MILDOS-Area model and concluded that the 

ingestion pathway is not significant. Following Regulatory Guide 4.14, the applicant does not 

intend to conduct vegetation, food, or fish sampling because the predicted dose to an 

individual from these pathways would be less than five percent of the applicable radiation 

protection standard. 

6.2.4 Surface Water Monitoring 

The proposed license area contains only intermittent streams and natural runoff occurs during 

heavy rainfall and snowmelt events. Current CBM operations contribute surface water 

discharge, which maintains some ponding at select locations across the proposed license area 

for portions of the year. Surface water samples would be collected on a quarterly basis at the 

same locations sampled for the pre-operational baseline if surface water is present as shown in 

Figure 3.4.2-4 of the applicant’s Technical Report (EMC, 2007b). 

Surface water samples would be collected in appropriate containers and field measurements of 

pH and conductivity would be documented. A preservative (acid) would be added to the surface 

water sample immediately after collection and filtration, if required. The sampling volume, 

preservative, and holding times for the proposed analytes are summarized in Uranium One 

(2008). The samples would be analyzed for Pb-210, Ra-226, Th-230, natural uranium, and 

Po-210. Surface water monitoring results would be submitted to the NRC in the semi-annual 

environmental and effluent monitoring reports. 

6.2.5 Groundwater Monitoring 

Groundwater monitoring of wells located within 1 km [0.6 mi] of the boundary of an operating 

wellfield would be performed to detect any migration of contaminated groundwater. These wells 

would be sampled quarterly, and analyzed for natural uranium and Ra-226 with the landowner’s 

consent, to identify potential impacts from the ISR operation. The sampling would be conducted 

in accordance with standard operating procedures. Furthermore, the water levels in private 

wells would be measured by the applicant every three months during operations (EMC, 2007a) 

6.3 Physiochemical Monitoring 

The ISR process significantly alters the water quality in the production zone aquifer. Therefore, 

before uranium extraction may occur in a production aquifer, the EPA must declare the 

production aquifer to be exempt. Appendix C of this final SEIS discusses the criteria 
Environmental Measures and Monitoring 

 6-4

U.S. Environmental Protection Agency (EPA) uses for an aquifer exemption. During operations, 

physiochemical groundwater monitoring is conducted to help prevent and limit potential impacts 

to groundwater quality in any of the nonexempt aquifers surrounding the exempt production 

zone aquifer. Physiochemical monitoring provides data on operational and environmental 

conditions so that prompt corrective actions can be taken if an adverse condition is detected. 

The physiochemical monitoring program at the proposed Moore Ranch Project includes 

groundwater monitoring and wellfield and pipeline flow and pressure monitoring. 

6.3.1 Wellfield Groundwater Monitoring 

Section 8.3 of the GEIS discussed the potential for ISR production processes to affect 

groundwater in and near the operating wellfield. Hence, groundwater conditions are extensively 

monitored both before and during operations, and after restoration. The proposed preoperational and baseline groundwater monitoring that would occur at the Moore Ranch Project 

is discussed below in Section 6.3.1.1. The groundwater quality monitoring that would occur 

during operation and restoration is discussed in Section 6.3.1.2. 

6.3.1.1 Preoperational Groundwater Sampling 

Section 8.3.1.1 of the GEIS discussed how a baseline groundwater quality program would be 

established prior to uranium production (NRC, 2009). The purpose of this program is to 

characterize water quality in monitoring wells used to detect lixiviant excursions from the ore 

production zone, to remediate excursions, and to establish Restoration Target Values (RTVs) 

for aquifer restoration after the operations phase is complete. 

Groundwater monitoring wells were installed at the proposed Moore Ranch Project to evaluate 

pre-operational water quality as part of the site characterization discussed in Section 3.5.2. 

Four well groups, each with a well in the 70 Sand production zone aquifer, the overlying 72 

Sand aquifer, and the underlying 68 Sand aquifer were installed across the proposed license 

area. Three wells were also completed in the 60 Sand aquifer. Four additional wells completed 

in the 70 Sand aquifer, installed in the 1980s by Conoco, Inc., and existing stock water wells 

completed in either the production zone aquifer or the underlying and/or overlying aquifers were 

also sampled for the Wyoming Department of Environmental Quality-Land Quality Division 

(WDEQ-LQD) Guideline 8 groundwater quality parameters to establish the WDEQ class of use 

as described in Section 3.5.2 of this SEIS. 

This sampling program in combination with groundwater sampling data from the 1980 Conoco, 

Inc. project provided a preliminary baseline of groundwater quality. The purpose of the 

preoperational analysis is to evaluate the overall groundwater quality in the proposed license 

area under normal pre-operational conditions. It is not used to establish the baseline water 

quality which forms the basis for establishing restoration criteria for the individual wellfields. 

To establish baseline water quality before operations at the proposed Moore Ranch Project, 

baseline monitoring wells would be installed in the 70 Sand production zone at a density of one 

well per 1.2 ha [3 ac] of the two planned wellfields. Each monitoring well would be analyzed for 

all WDEQ LQD Guideline 8, Appendix 1, parts III and IV parameters shown in Table 5.7-1 of the 

applicant’s technical report (EMC, 2007b). The third and fourth sampling events would be 

analyzed for a reduced list of parameters defined by the previous sample results. If certain 

constituents were not detected during the first and second sampling events, then they would not 

be analyzed for again during the third and fourth sample events. Data for each water quality 

parameter would be averaged. If the collected wellfield data indicated that waters of different 
 Environmental Measures and Monitoring 

 6-5

underground water classes coexist (WDEQ-LQD Rules and Regulations, Chapter VIII), then the 

data would not be averaged but rather treated as sub-zones. Subzone specific data would also 

be averaged. A sub-zone boundary would be delineated half-way between the sampled well 

sets as appropriate. 

Once the baseline water quality for each wellfield is established, it would be used to determine 

the appropriate restoration target values to assess the effectiveness of groundwater restoration 

on a wellfield-specific basis. The restoration target values are a combination of the average and 

range of baseline values for specific constituents in wells completed in the 70 Sand ore 

production zone. WDEQ would review and approve the baseline water quality assessment and 

restoration target values for each wellfield; NRC would also review and approve the restoration 

target values for specific constituents. 

Monitoring wells would be installed in a ring around each wellfield in the 70 Sand production 

zone and in the overlying 72 Sand and underlying 68 and 60 Sand aquifers prior to the start of 

operations. Monitoring wells would be placed at a spacing of one well per 4 acres in the 

underlying 60 Sand in the areas where the 70 and 68 sand coalesce. The wells would be 

sampled to determine baseline water quality data to establish upper control limits (UCL) for 

operational excursion monitoring. The wells would be sampled four times, at least 2 weeks 

apart. The first sample would be analyzed for the full set of constituents required by the WDEQ; 

subsequent samples would only be analyzed for the UCL parameters (see Section 6.3.1.2). 

The applicant’s technical report (EMC, 2007b) provides detailed procedures for sampling and 

analysis, including methods for measuring water levels, well purging and sampling protocols, 

sample preservation and documentation, analytical methods, and quality assurance/quality 

control requirements (Uranium One, 2008). 

6.3.1.2 Groundwater Quality Monitoring 

Section 8.3.1.2 of the GEIS discussed the placement of monitoring wells around the perimeter 

of the wellfields, in the aquifers overlying and underlying the ore-bearing production aquifers to 

provide early detection of potential horizontal and vertical lixiviant excursions during production 

operations. Monitoring well placement is based on a number of factors including the nature and 

extent of the confining layer and the occurrence of drill holes, hydraulic gradient and aquifer 

transmissivity, and well abandonment procedures used in the region. The ability of a monitoring 

well to detect groundwater excursions is influenced by several factors, such as the thickness of 

the aquifer, the distance between the monitoring wells and the wellfield, the distance between 

adjacent monitoring wells, the frequency of groundwater sampling, and the magnitude of 

changes in lixiviant migration indicator parameters. Therefore, the spacing, distribution, and 

number of monitoring wells are site-specific and established by license conditions. 

The groundwater monitoring program at the proposed Moore Ranch Project would be designed 

to detect excursions of lixiviant outside the wellfield under production and into the overlying 

and/or underlying water bearing strata. The groundwater monitoring is divided into four phases: 

pre-operational, baseline, production and restoration monitoring. Section 5.7.8 of the 

applicant’s Technical Report documents the groundwater monitoring program that would be 

implemented at the proposed Moore Ranch Project (EMC, 2007b). Monitoring wells completed 

in the 70 Sand production zone would be installed around the perimeter of each wellfield. 

Approximately 24 groundwater wells would monitor the perimeter of Wellfield 1 and 

approximately 27 groundwater wells would be used to monitor the perimeter of Wellfield 2. 

Within the pattern area wells completed in the overlying 72 Sand aquifer and in the underlying 
Environmental Measures and Monitoring 

 6-6

68 Sand aquifer would be spaced at one well per every 6.4 ha [4 ac] of pattern area resulting in 

approximately 6 monitor wells completed in the overlying and underlying aquifers in Wellfield 1 

and about 9 monitor wells completed in overlying and underlying aquifers in Wellfield 2 since it 

covers a larger area. In the Wellfield 2 area where the 68 and 70 Sands coalesce, the sands 

would be treated as one aquifer and the underlying aquifer would be the 60 Sand. Additional 

monitoring wells would be placed in the 68 Sand in this area to detect potential impacts. The 

final number of such wells would be determined during final wellfield planning and submitted to 

the WDEQ-LQD and NRC for review and approval. 

The distance between perimeter monitoring wells surrounding the production wells would be no 

more than 152 m [500 ft] and the distance between the perimeter monitoring wells and the 

production pattern would also be approximately 152 m [500 ft] based on the output from the 

applicant’s groundwater flow model and the estimated hydraulic properties within the production 

area. The applicant used model simulations to demonstrate that if an excursion occurred, the 

perimeter monitoring ring would be able to detect an excursion in a timely manner. 

Appendix B–4 of the applicant’s technical report discusses the groundwater model and analyzes 

the model results (EMC, 2007b). 

At the proposed Moore Ranch Project, the constituents selected as lixiviant migration indicators 

for which UCLs would be established are chloride, conductivity, and total alkalinity. Chloride 

was selected because it has a low background concentration in native groundwater, it would be 

introduced into the lixiviant from the ion exchange process, and it is very mobile in groundwater. 

Conductivity was selected because it is an indicator of overall groundwater quality. Finally, total 

alkalinity was selected because bicarbonate is the major constituent added to the lixiviant 

during production; therefore, elevated concentrations of total alkalinity could be indicative of 

an excursion. 

Per NRC guidance in NUREG–1569 and WDEQ requirements, the applicant must provide a 

field demonstration of the hydraulic interconnection between the monitoring wells and 

production pattern using pump tests before operations can be initiated. Because of the 

unconfined nature of the groundwater aquifer in the 70 Sand at the proposed Moore Ranch 

Project, more intensive pump tests were necessary to demonstrate hydraulic interconnections 

between the production zone and the perimeter monitor wells. The applicant therefore used the 

numerical groundwater model presented in Appendix B–4 of the technical report to develop a 

pump test strategy that could demonstrate the hydraulic connections between the monitoring 

wells and production pattern in the 70 Sand unconfined aquifer (EMC, 2007b). This pump test 

strategy would be implemented after the required monitoring and production wells were 

completed but prior to operations. 

A Wellfield Hydrologic Data Package would be prepared by the applicant following the 

installation of the production pattern and monitoring well network in a wellfield. This package 

would provide the monitoring well locations, the pump test results, baseline water quality for all 

wells, and RTVs for each wellfield production zone. The applicant’s Safety and Environmental 

Review Panel, responsible for monitoring any proposed change in the facility or process, would 

review the data package to ensure that the hydrologic testing results and planned ISR activities 

would be consistent with technical requirements and did not conflict with NRC regulatory 

requirements. The Wellfield Hydrologic Data Package would be submitted to the WDEQ for 

review and approval to ensure the acceptability of the baseline data and the RTVs. WDEQ 

would also review the monitoring well locations and the wellfield-specific monitoring program to 

ensure they would provide timely detection and correction of potential horizontal or vertical 

excursions. Based on the outcome of the safety review of the technical report, NRC will request 
 Environmental Measures and Monitoring 

 6-7

by license condition to review and approve the Wellfield Hydrologic Data Package for an 

individual wellfield if NRC determines that a safety review cannot be adequately completed 

without the local wellfield-specific information provided in the package. 

After operations were completed, the wellfields would be restored. During restoration, lixiviant 

injection would be suspended; thereby reducing the potential for an excursion. The applicant 

therefore has proposed a reduced groundwater monitoring program during aquifer restoration. 

During the aquifer restoration phase, wells located in the perimeter monitoring ring and 

completed in the overlying and underlying aquifers would be sampled every 60 days for 

chloride, alkalinity and conductivity excursion parameters. An excursion would be defined in the 

same manner as during operations and subject to the same correction requirements. 

6.3.2 Wellfield and Pipeline Flow and Pressure Monitoring 

Section 8.3.2 of the GEIS discussed operator monitoring of injection and production well flow 

rates to manage the entire wellfield water balance. The pressure of each production well and 

the production trunk line in each wellfield header house would also be monitored. Unexpected 

pressure loss could indicate equipment failure, a leak, or well integrity problems. 

The proposed Moore Ranch Project would have an extensive program of wellfield and pipeline 

flow and pressure monitoring as described in Section 3.1.3 of the applicant’s technical report 

(EMC, 2007b). Injection well and production well flow rates and pressures would be monitored 

at each header house to balance injection and production in each pattern and throughout the 

wellfield. The production and injection flow rate in each well would be continuously individually 

monitored by electronic flow meters in each wellfield header house. The pressure of each 

production and injection well trunk line would also be monitored at the header house with 

electronic pressure gauges. Both flow meter and pressure gauges would tie into the header 

house control panel that would ultimately tie into the central plant control room. High and low 

pressure and/or flow alarms would alert wellfield and plant operators if specified ranges were 

exceeded. Automatic shutoff valves would stop the flow in the event of significant changes in 

volume or pressure. This monitoring would alert the operators to detect malfunctions that could 

lead to either wellfield infrastructure or pipeline failures, thus minimizing the potential to 

impact groundwater. 

6.3.3 Surface Water Monitoring 

Uranium One does not plan to conduct physiochemical monitoring of surface water since there 

would be no surface water discharges associated with the ISR process at the proposed Moore 

Ranch Project. To ensure the protection of surface water, each injection and production well 

would be monitored to detect a change in flow and/or pressure that might indicate a leak or 

rupture in the system. If a leak were to occur, the system would be shut down and remediation 

conducted as appropriate. 

6.3.4 Meteorological Monitoring 

Uranium One does not plan to conduct meteorological monitoring at the site. To describe the 

affected environment and assess air quality impacts resulting from the proposed project, the 

applicant used meteorological data from the Antelope Coal Mine meteorological station located 

approximately 40 km (25 mi) southeast of the proposed Moore Ranch Project. The Antelope 

coal mine site has similar topographic features to the proposed Moore Ranch Project and is 

characterized by mildly rolling hills covered with grass and sparse shrubs (Uranium One, 2008). 
Environmental Measures and Monitoring 

 6-8

6.4 Ecological Monitoring 

6.4.1 Vegetation Monitoring 

As discussed in Section 6.2.3, the applicant concluded from its pre-operational vegetation 

sampling program and through modeling that the ingestion pathway for radiological dose is not 

significant. Therefore, Uranium One does not intend to conduct vegetation, food, or fish 

sampling because the predicted dose to an individual from these pathways would be less than 

five percent of the applicable radiation protection standard. 

6.4.2 Wildlife Monitoring 

Large game animals such as deer or pronghorn have extensive ranges and are not confined to 

the site. Therefore, the potential for bioaccumulation of radionuclides in these animals would be 

limited since they would likely derive only a small fraction of total sustenance from the proposed 

Moore Ranch Project. No fish species occur within the proposed license area since surface 

water is intermittent in nature and does not have a sufficient volume to support aquatic species. 

The applicant has proposed wildlife studies that would include an annual raptor survey 

conducted in late April or early May to identify new nests and to assess whether known nests 

are being utilized (Uranium One, 2009). The survey would cover all areas of planned activity for 

the life of the ISR project (i.e., wellfields and the central plant) and within a one-mile area 

around the activity primarily to protect against unforeseen conditions such as the construction of 

a new nest in an area that could be affected by ISR operations (Uranium One, 2009). 

6.5 References 

10 CFR Part 40. Code of Federal Regulations, Title 10, Energy, Part 40, “Domestic Licensing of 

Source Material.” Appendix A, “Criteria Relating to the Operation of Uranium Mills and the 

Disposition of Tailings or Wastes Produced by the Extraction or Concentration of Source 

Material From Ores Processed Primarily for Their Source Material Content.” 

EMC (Energy Metal Corporation US), 2007a “Application for USNRC Source Material License, 

Moore Ranch Uranium Project, Campbell County, Wyoming, Environmental Report.” Casper, 

Wyoming: Uranium 1 Americas Corporation. ADAMS Accession Nos. ML072851222, 

ML072851229, ML072851239, ML07285249, ML07285253, ML07285255. October 2. 

EMC, 2007b. “Application for USNRC Source Material License, Moore Ranch Uranium Project, 

Campbell County, Wyoming, Technical Report.” Casper, Wyoming: Uranium 1 Americas 

Corporation. ADAMS Accession Nos. ML072851222, ML072851258, ML072851259, 

ML072851260, ML072851268, ML072851350, ML072900446. October 2, 2007. 

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities. Washington, DC: NRC. May. 

NRC, 2003. NUREG–1569, Standard Review Plan for In-Situ Leach Uranium Extraction License 

Applications. Final Report. Washington, DC: NRC. June. 

NRC, 1980. Regulatory Guide 4.14, “Radiological Effluent and Environmental Monitoring at 

Uranium Mills.” Rev. 1. Washington, DC. April 1980. 
 Environmental Measures and Monitoring 

 6-9

Uranium One (Uranium One Americas), 2009. “Responses to Request for Additional 

Information for the Moore Ranch In Situ Uranium Recovery Project License Application (TAC 

JU011).” ADAMS Accession No. ML092450317. August 31, 2009. 

Uranium One, 2008. “Additional Information Requested for the Moore Ranch In Situ Uranium 

Recovery Project License Application (TAC JU011), First Set of Responses.” ADAMS 

Accession No. ML082060527. July 11, 2008. 

7-1

7 COST-BENEFIT ANALYSIS 

This chapter summarizes benefits and costs associated with the proposed action and the 

No-Action alternative. Chapter 4 of this supplemental environmental impact statement (SEIS) 

discusses the potential socioeconomic impacts of the construction, operation, aquifer 

restoration, and decommissioning of the proposed Moore Ranch Project by Uranium 

One Americas. 

The implementation of the proposed action would primarily generate regional and local benefits 

and costs. The regional benefits of constructing and operating the proposed Moore Ranch 

Project would be increased employment, economic activity, and tax revenues in the region 

around the proposed license area. Some of these regional benefits, such as tax revenues, 

would be expected to accrue specifically to Campbell County, Wyoming, where the proposed 

facility would be located, and the town of Wright, located approximately 40 km [25 mi] from the 

proposed project. Other benefits could extend to the neighboring Wyoming counties of Johnson 

and Natrona. Costs associated with the proposed Moore Ranch Project are, for the most part, 

limited to the immediate area surrounding the site. Examples of these environmental impacts 

would include changes to current land use and increased road traffic. 

7.1 No-Action Alternative 

Under the No-Action alternative, the NRC would not grant a license for the proposed Moore 

Ranch Project. The No-Action alternative would result in the applicant not constructing, 

operating, restoring the aquifer, or decommissioning the proposed Moore Ranch Project. No 

facilities, road, or wellfields would be built; no pipeline would be laid as described in 

Section 2.1.1.1.2. No uranium would be recovered from the subsurface orebody; therefore, 

injection, production, and monitoring wells would not be installed in wellfields and the facility 

would not operate. Neither lixiviant would be introduced in the subsurface nor would buildings 

be constructed to process extracted uranium or for chemical storage. Because no uranium 

would be recovered, neither aquifer restoration nor decommissioning activities would occur. No 

liquid or solid effluents would be generated. As a result, the proposed site would not be 

disturbed by the proposed project activities, and ecological, natural, and socioeconomic 

resources would remain unaffected. All potential environmental impacts from the proposed 

action would be avoided. Similarly, all project-specific socioeconomic impacts (e.g., related to 

housing) would be avoided. 

7.2 Benefits from Proposed Action in Campbell County 

Under the proposed action, the applicant would construct, operate, restore the aquifer, and 

decommission the proposed Moore Ranch Project in Campbell County, Wyoming. The central 

plant, access roads, and initial development of the first of two wellfields for the proposed Moore 

Ranch Project would occur over a 9-month period, the second wellfield would be developed 

within the following 2-year period. Operation of the central plant for uranium recovery and 

processing would occur over 12 years, with approximately 3.25 years of uranium recovery in 

each of the two wellfields. Aquifer restoration activities and stability monitoring following 

restoration would occur over a 4.5- to 6.5-year period. The applicant expects to conduct final 

wellfield and site decommissioning within 1 year. 

The principal socioeconomic impact or benefit from the proposed Moore Ranch Project would 

be an increase in the jobs in Campbell County, Wyoming. The applicant expects to employ 

50 workers during construction and 40–60 workers during operations, aquifer restoration, and 
Cost-Benefit Analysis 

 7-2

decommissioning. As discussed in Section 4.11, the construction and decommissioning 

workers would most likely not relocate in the area because of the short period of time (9 months 

to 1 year) over which these activities would occur. 

However, during the 12-year period of operations and aquifer restoration, workers would be 

more likely to relocate to be nearer the facility. If the majority of operational requirements was 

filled by a workforce located outside the region, given a multiplier of about 0.71

, there could be 

an influx of 28 to 42 jobs (i.e., 40 jobs × 0.7 = 28 jobs and 60 jobs × 0.7 = 42 jobs). 

The closest town to the proposed Moore Ranch Project is the town of Wright with an estimated 

population of 1,462 (U.S. Census Bureau, 2008). However, employees supporting operations 

could prefer to reside in larger communities (NRC, 2009) and therefore, could choose to reside 

in the towns of Gillette and Casper. The influx of these jobs and a reduction of unemployment 

would have a MODERATE benefit to the businesses in the smaller towns such as Wright and a 

SMALL to MODERATE impact in the businesses of the larger towns within commuting distance 

from the proposed project site. 

In addition to creating jobs, the operation of the proposed Moore Ranch Project and its 

employment opportunities would contribute to local, regional, and state revenues through the 

purchase of goods and services and through the taxes levied on such goods and services. 

Furthermore, severance taxes of 4 percent of taxable market value associated with uranium 

milling/mining in Campbell County are levied by the State of Wyoming, Mineral Tax Division of 

the Department of Revenue (Wyoming Department of Revenue, 2009). The applicant’s current 

resource estimate for the proposed Moore Ranch Project is 5.8 million lbs of uranium. If the 

applicant is able to fully recover this resource and sell it at a nominal market price of $45 per 

pound of uranium, the severance tax would yield approximately $10,440,000 in net economic 

benefits over the life of the project. This figure excludes potential reserve resources and the 

potential benefit from taxes on royalties or lease payments to local landowners from the 

operation of the proposed Moore Ranch Project 

7.2.1 Benefits From Potential Production 

The employment generated by the proposed Moore Ranch Project and the taxes paid by the 

applicant depend on the production of yellowcake. The volume of yellowcake produced would 

depend on the market price for yellowcake (as uranium) and the cost of production. Since 

2007, the spot-market price for U3O8 has fluctuated significantly, from a high of over $130 in 

2007 to as low as $40 in 2009. As of July 12, 2010, the price was $41.50 per pound. 

 

1

The Economic Multiplier is used to summarize the total impact that can be expected from a change in a given 

economic activity. It is the ratio of total change to initial change. The multiplier of 0.7 was used as a typical 

employment multiplier for the milling/mining industry (Economic Policy Institute, 2003).
 Cost-Benefit Analysis 

 7-3

The project's potential benefits to the local community depend on the applicant’s operating costs 

being lower than the future price of uranium. If the price of uranium drops below the operating 

costs, then the operation of the facility would become uneconomic and the operations could be 

suspended and/or discontinued. 

7.2.2 Costs to the Local Communities 

Table 7-1 identifies both the towns and their population within 40 km (25 mi) of the proposed 

Moore Ranch Project and towns within commuting distance. 

As noted in Section 7.2, the proposed Moore Ranch Project would employ 40 to 60 workers 

during the operations period; if the majority of these workers came from outside the region, 

there could be an influx of 28 to 42 jobs (given an economic multiplier of 0.7). Assuming that 

operations workers would tend to relocate to be closer to the site, the creation of these new jobs 

could result in an influx of 69 to 104 people, based on an assumption of 2.48 persons per 

household for the State of Wyoming (U.S. Census Bureau, 2000). 

Chapter 4 of this SEIS states that because of the small relative size of the workforce at the 

proposed Moore Ranch Project, the potential impact on socioeconomics would be SMALL 

except for the impact on housing which could range from SMALL to MODERATE. As stated 

previously, operations employees could prefer to reside in larger communities (NRC, 2009) and, 

therefore, could choose to reside in larger towns. The influx of new jobs along with the 

reduction in unemployment would result in a SMALL to MODERATE increase in housing 

demand and in the construction of new homes within the region of influence. The population 

growth would have a SMALL impact on education infrastructure and health and social services. 

The local communities would require a minimal increase in emergency response and medical 

treatment capabilities because of the small risk of an industrial accident from the 

proposed action. 

Table 7-1. Towns Near the Proposed Moore Ranch Project 

Town Population * Distance From Project Site (km) 

[mi] 

Towns Within 40 km [25 mi] From the Project Site 

Edgerton 176 38 [24] 

Wright 1,462 40 [25] 

Midwest 435 40 [25] 

Towns greater than 40 km (25 mi) from the project site 

Kaycee 290 64 [40] 

Gillette 26,871 80 [50] 

Buffalo 4,832 100 [62] 

Casper 54,047 100 [62] 

*U.S. Census Bureau, 2008 
Cost-Benefit Analysis 

 7-4

7.3 Evaluation Findings of the Proposed Moore Ranch Project 

Implementation of the proposed action would have a SMALL to MODERATE overall economic 

impact on the region of influence. The implementation of the proposed action would generate 

primarily regional and local benefits and costs. The regional benefits from the operation of the 

proposed Moore Ranch Project would be increased employment, economic activity, and tax 

revenues to the region around the site. Some of these regional benefits, such as tax revenues, 

would accrue to Campbell County specifically. Other benefits could extend to neighboring 

counties in the State of Wyoming. Costs associated with the proposed Moore Ranch Project 

would be limited primarily to the area surrounding the site and the communities within 

commuting distance. Table 7-2 summarizes the costs and benefits. 

Table 7-2. Summary of Costs and Benefits of the Proposed Moore Ranch Project 

Cost-Benefit Category Proposed Action 

BENEFITS 

Capacity Produced 5.8 million pounds of U3O8

Other Monetary $10.44 million (estimated) 

Non-Monetary 

(50% of jobs would be from Campbell County) 

50 jobs-- during construction 

40-60 jobs—during operations, aquifer 

restoration, and decommissioning 

28-42 jobs—local jobs from economic 

multiplier during operations and aquifer 

restoration 

COSTS 

Education Infrastructure SMALL 

Health and Social Services SMALL 

Housing Demand SMALL to MODERATE 

Emergency Response SMALL 

7.4 References 

Economic Policy Institute, 2003. “Updated Employment Multipliers for the U.S. Economy,” 

Washington, DC. <http://www.epi.org/page/-/old/workingpapers/epi_wp_268.pdf> (13 October 

2009). 
 Cost-Benefit Analysis 

 7-5

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, ”Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities,” Washington, DC. May. 

U.S. Census Bureau, 2008. U.S. Census Bureau, 2008 Population Estimates, 

<http://factfinder.census.gov> 

U.S. Census Bureau, 2000. State and County Quick Facts, 

<http://quickfacts.census.gov/qfd/states/56000.html> 

Wyoming Department of Revenue. 2009. “State of Wyoming Department of Revenue 2009 

Annual Report.” http://revenue.state.wy.us/PortalVBVS/uploads/ 

Department%20of%20Revenue%20%2010.29> .2009.pdf> (11 November 2009). 

 8-1

8 SUMMARY OF ENVIRONMENTAL CONSEQUENCES 

This chapter summarizes the potential environmental impacts and consequences of the proposed 

action. In doing so, the potential impacts and consequences of the proposed action are discussed in 

terms of (1) the unavoidable adverse environmental impacts, (2) the relationship between local 

short-term uses of the environment and the maintenance of long-term productivity, and (3) the 

irreversible and irretrievable commitment of resources. The information is presented for the proposed 

action for the 13 resource areas and discussed by stage of the proposed Moore Ranch Project’s 

lifecycle (i.e., construction, operation, aquifer restoration, and decommissioning). These impacts are 

described in the table below. 

NRC’s NUREG-1748 (NRC, 2003) defines the following terms: 

• Unavoidable adverse environmental impacts: impacts that cannot be avoided 

and for which no practical means of mitigation are available 

• Irreversible: commitments of environmental resources that cannot be restored 

o Irretrievable: applies to material resources and will involve commitments 

of materials that, when used, cannot be recycled or restored for other 

uses by practical means 

o Short-term: represents the period from pre-construction to the end of the 

decommissioning activities, and therefore generally affect the present 

quality of life for the public. 

o Long-term: represents the period of time following the termination of the 

site license, with the potential to affect the quality of life for future 

generations. 

As discussed in Chapter 4, the significance of potential environmental impacts is categorized 

as follows: 

SMALL: The environmental effects are not detectable or are so minor that they will 

neither destabilize nor noticeably alter any important attribute of the resource. 

MODERATE: The environmental effects are sufficient to alter noticeably, but not to 

destabilize, important attributes of the resource 

LARGE: The environmental effects are clearly noticeable and are sufficient to 

destabilize important attributes of the resource 

Table 8-1 summarizes the environmental consequences for the proposed action. Under the No-Action 

alternative there would be no unavoidable adverse impacts because no licensing action would occur. 

Likewise, there would be no irreversible and irretrievable commitment of resources since no materials 

would either be committed or consumed under the No-Action alternative. Similarly, there would be no 

short- or long-term impacts under the No-Action alternative. The proposed action and the resulting 

environmental impacts are discussed the impacts associated with the No-Action alternative are 

provided for comparison in Section 5.2. 
Summary of Environmental Consequences 

 8-2

8.1 Proposed Action (Alternative 1) 

Under the Proposed Action, the NRC would issue a license for the construction, operation, aquifer 

restoration, and decommissioning of the Moore Ranch Project. Construction is expected to last about 

9 months. During this phase, buildings, access roads, wellfields, pipelines, and injection wells to be 

used for liquid effluent disposal would be constructed. These actions would disturb approximately 61 

ha [150 ac] of the 2,879 ha [7,100 ac] proposed license area. Operations are expected to last about 

12 years, however the wellfields would only be operational 3.25 years, injection wells would be used to 

inject lixiviant (recovery) solutions into the ore body to recover uranium. Production wells would be 

used to recover the dissolved uranium which then would be processed through the central plant. 

Finally monitoring wells would be installed to monitor the performance of the wellfield and to mitigate 

potential excursions from the production zone. Initially, approximately 2 to 3 million pounds of uranium 

would be produced per year. Aquifer restoration would be initiated to ensure that water quality and 

groundwater use from surrounding aquifers was not impacted by the proposed action. The process is 

expected to last about 3.5 years in Wellfield 1 and 5.25 years in Wellfield 2, and would involve 

transferring contaminated groundwater from one wellfield to the next, “sweeping” groundwater (i.e., 

replacing contaminated groundwater with cleaner baseline water through pumping action), and treating 

the groundwater to minimize the groundwater volume consumed during the restoration phase. During 

the decommissioning phase expected to last about 1 year, the disturbed lands would be returned to 

their preextraction use. The wells would be plugged and abandoned and the land surface would be 

reclaimed. 

8.2 No-Action (Alternative 2) 

Under the No-Action alternative, the NRC would not issue a license. No buildings, roads, wellfields and 

the supporting infrastructure would be built, no uranium would be recovered from the subsurface 

orebody; therefore, the aquifer would be unaffected by activities at the proposed Moore Ranch Project 

and there would be no need for restoring the aquifer or for decommissioning. The decision to not 

license the proposed Moore Ranch Project would leave a large resource unavailable for energy 

production supplies to fuel power generation facilities. 

Under the No-Action alternative, there would be no impact to land use because the facility would not be 

constructed; there would neither be earthmoving activities to disturb the land nor restrictions put on the 

land for grazing or ranching. The existing land use would continue and the property would be available 

for other uses. There would be no impact on the local transportation system. The current volume and 

existing traffic patterns would continue as described in the affected environment. Since the land 

surface would not be disturbed under the No-Action alternative, there would be no impact to soils. 

Natural phenomena such as wind and water erosion (during storms and severe weather events) would 

remain the most significant variable associated with geology and soils at the site. The subsurface 

geology at the site would be unaffected by the injection of fluids. 

Surface water and associated wetlands at the site would continue to occur intermittently in response to 

snowmelts, large precipitation events or from the discharge of surface water from upstream coal-bed 

methane operations. Under the No-Action alternative, groundwater would be unaffected by the 

proposed ISR operation. The groundwater quality in the aquifer and the water levels in wells 

surrounding the proposed license area would remain unaffected. Because there would be neither 

earthmoving nor grazing restriction activities under the No-Action alternative, the existing vegetation 

and wildlife communities would be undisturbed. There would be no impact to air quality since there 

would be no activities to generate either fugitive dust or gaseous emissions nor would there be any 

noise-generating activities. 
Summary of Environmental Consequences 

 8-3

No historic or cultural resources would be disturbed under the No-Action alternative nor would there be 

any proposed activities that could affect the viewscape. The viewscape would consist of existing 

activities in the area, such as coal-bed methane extraction and oil and gas development. There would 

be no additional radiological exposure to the general public other than that from background radiation 

levels. No additional waste streams or materials such as sanitary waste or byproduct material would be 

generated. 

Under the No-Action alternative, there would be no impact on the socioeconomics of the area. No new 

jobs would be created, no additional revenue would accrue to the tax base, there would be no impact 

on the availability of housing or public services. There would be no disproportionately high and adverse 

impact on minority and low-income populations. 

8.3 Reference 

NRC (U.S. Nuclear Regulatory Commission), 2003. NUREG–1748, “Environmental Review Guidance 

for Licensing Actions Associated with NMSS Programs.” Washington, DC: August. 
Table 8-1. Summary of Environmental Consequences 

The Proposed Action (Alternative 1) 

Impact Category (as 

applicable)

Unavoidable Adverse 

Environmental Impacts 

Irreversible and 

Irretrievable 

Commitment of 

Resources 

Short-term Impacts and 

Uses of the Environment 

Long-Te

Ma

En

Land Use 4.2.1 

There would be a SMALL impact to land during the construction and decommissioning phases of the proposed Moore Ranch Project. During construction, approximately 60 ha [150 ac) of land would be fenced and disturbed by earthmoving activities to construct the central plant, wellfields and associated infrastructure, and to build the access roads. This area is less than 2 percent of the proposed license area. During decommissioning, the land would also be impacted by earthmoving activities to reclaim and reseed the area. 

No impact. There would be no irreversible and irretrievable commitment of land resources from implementing the proposed action. The duration of the proposed action would last approximately 12 years after which time the land would be reclaimed and made available for other uses. 

There would be a short-term impact to land use from implementing the proposed action. Approximately 60 ha [150 ac] of the proposed license area would be unavailable for other uses such as rangeland or grazing; coal bed methane (CBM) or oil and gas exploration could coexist with the applicant’s proposed action. The impact would be SMALL. 

There woimpact oimplemeaction. Tavailable end of th

Transportation 4.3.1 

There would be a SMALL impact on transportation. Increased truck and 

No impact. There would be a SMALL 

impact. Small increases in the numbers of traffic 

There wotransportattributab

8-4 
Table 8-1. Summary of Environmental Consequences 

The Proposed Action (Alternative 1) 

Impact Category (as 

applicable)

Unavoidable Adverse 

Environmental Impacts 

Irreversible and 

Irretrievable 

Commitment of 

Resources 

Short-term Impacts and 

Uses of the Environment 

Long-Te

Ma

En

vehicle traffic along State Highway (SR) 387 would result in small changes in the current use of this local road. 

accidents resulting in injuries or fatalities, and small increases in vehicle emissions that should not degrade local air quality. The generic environmental impact statement (GEIS) concluded the risk from transporting yellowcake, ion exchange resin, and byproduct material, and hazardous chemicals was small (NRC, 2009). 

Moore Rlicense te

Geology and Soils 4.4.1 

There would be a SMALL impact on geology and soils. The construction and decommissioning phases would disturb surface soils during construction of the central plant, development of the wellfields, laying of pipelines, and construction of new access roads. These impacts would be temporary and at the end of the decommissioning 

Topsoil salvaged during the construction phase of the project would be replaced during the reclamation and reseeding processes. 

There would be a SMALL impact to geology and soils. No significant matrix compression or ground subsidence would be expected since the net withdrawal of fluid from the 70 Sand production zone would be about one percent or less. Earthmoving activities would disturb about 60 ha [150 ac] of soil. 

There woimpacts tfollowing 

8-5 
Table 8-1. Summary of Environmental Consequences 

The Proposed Action (Alternative 1) 

Impact Category (as 

applicable)

Unavoidable Adverse 

Environmental Impacts 

Irreversible and 

Irretrievable 

Commitment of 

Resources 

Short-term Impacts and 

Uses of the Environment 

Long-Te

Ma

En

phase topsoil would be replaced. 

Water Resources (Surface Water) 4.5 

There would be a SMALL impact to surface water and wetlands from the construction of the central plant and the two wellfields from increased sediment yield in the disturbed areas. A small (<2 ac) wetland area in Wellfield #2 could be disturbed by constructing wells near the drainage area. However, the applicant would avoid installing wells in the main channels of ephemeral drainages; therefore, there would be a SMALL impact. The applicant would also use best management practices such as the use of rip rap and rock on embankments, culverts and drainage crossings. 

There would be no irreversible and irretrievable commitment of either surface water or wetlands from implementing the proposed action. No drainage or body of water would be significantly altered during operations. The impact to wetlands would be SMALL since the stream flow is intermittent and the applicant would avoid installing wells in the main channels of ephemeral drainages and implement best management practices. 

Normal construction activities within the wellfields, at the central plant, along pipelines and access roads have the potential to result in increased sediment yield in surface water runoff, potentially affecting wetlands. However, given the absence of perennial streams, the small area to be affected, potential impacts to surface water and wetlands during construction and decommissioning would primarily be limited to uncommon precipitation or runoff events. These impacts would be further mitigated by implementing best management practices. 

There woimpact to wetlands terminati

8-6 
Table 8-1. Summary of Environmental Consequences 

The Proposed Action (Alternative 1) 

Impact Category (as 

applicable)

Unavoidable Adverse 

Environmental Impacts 

Irreversible and 

Irretrievable 

Commitment of 

Resources 

Short-term Impacts and 

Uses of the Environment 

Long-Te

Ma

En

Water Resources (Groundwater) 4.5 

There would be a SMALL impact on groundwater. Groundwater would be impacted from in-siturecovery (ISR) by consumption of groundwater and degradation of water quality in the 70 Sand production zone. 

About 99 percent of the groundwater used during the ISR process would be treated and re-injected into the subsurface; however, about one percent of the groundwater used in the process would be consumed. 

Short-term impacts to groundwater would include degradation of water quality within the 70 Sand production zone during operations and the potential drawdown in private wells completed in the same aquifer as the production zone. The potential drawdown would be nominal; so the yield in private wells would not be affected. Private wells would be monitored to mitigate potential impacts. 

Both the and the URegulatorequire regroundwoperationquality wensure thwould no

Ecology 4.6.1 

There would be a SMALL impact. Construction and decommissioning of the proposed Moore Ranch Project would result in the short-term loss of vegetation of approximately 61 ha [150 ac] and could stimulate the introduction and spread of undesirable and invasive, nonnative species. 

Vegetative communities directly impacted by earthmoving activities and wildlife injuries and mortalities would be irreversible. However, the implementation of mitigative measures such as the use of fences to limit wildlife movement and enforcing speed limits would reduce potential impacts to 

During any of the ISR phases, direct impacts to ecological resources could include injuries and mortalities caused by either collisions with project-related traffic or habitat removal actions such as the removal of topsoil. Most habitat disruption would consist of scattered, confined drill sites for wells and would not 

Some of communthe propoProject creestabliplantings could takSpecies communin numbegeneralis

8-9 8-7 

8-7 
Table 8-1. Summary of Environmental Consequences 

The Proposed Action (Alternative 1) 

Impact Category (as 

applicable)

Unavoidable Adverse 

Environmental Impacts 

Irreversible and 

Irretrievable 

Commitment of 

Resources 

Short-term Impacts and 

Uses of the Environment 

Long-Te

Ma

En

wildlife. Furthermore, areas impacted by earthmoving activities would be reclaimed and reseeded. 

result in large transformation of the existing habitat. Wildlife could be displaced by increased noise and traffic. 

Meteorology, Climatology, and Air Quality 4.7.1 

There would be a SMALL impact. During implementation of the proposed action, there would be increased amounts of dust (particulates) from the earthmoving activities to construct the central plant, drill wells and develop the wellfields, lay pipeline, and build access roads to the wellfields. SMALL impacts would also result from vehicular traffic on unpaved roads and from diesel emissions from construction equipment. 

There would be no irreversible or irretrievable commitment of air resources from implementing the proposed action. 

There would be a temporary, short-term impact on air quality primarily during the construction and decommissioning phases due to earthmoving activities and from vehicle emissions. The effect would be highly localized, temporary. Use of mitigative measure such as applying water to unpaved roads would limit fugitive dust emissions. 

No impaclong-term either froproposed license te

Noise 4.8.1 

There would be a SMALL impact. The nearest resident is located about 

No impact. No impact. No impac

noise imimpleme

8-8 
Table 8-1. Summary of Environmental Consequences 

The Proposed Action (Alternative 1) 

Impact Category (as 

applicable)

Unavoidable Adverse 

Environmental Impacts 

Irreversible and 

Irretrievable 

Commitment of 

Resources 

Short-term Impacts and 

Uses of the Environment 

Long-Te

Ma

En

4.5 km [2.8 mi] east of the center point of the proposed Moore Ranch Project and the site is in a remote location. 

action foterminati

Historic and Cultural 4.9.1 

There would be a SMALL impact. There would be no impact to historical and cultural resources recommended eligible for listing on the National 

Register of Historic Places. 

No impact. No short-term impact to 

historic or cultural resources would be expected. If any unidentified historic or cultural resources are encountered, work would stop and appropriate federal and state officials be notified. Therefore, the potential impact to historic and cultural resources during operation of the facility would be SMALL. 

No impacimpact to resourceaction foterminati

Visual and Scenic 4.10.1 

There would be a SMALL impact on the visual landscape. The area surrounding the proposed Moore Ranch Project contains wellfields, pipelines, and utility lines associated with CBM development. 

No impact. There would be a SMALL 

short-term impact to the visual landscape from implementing the proposed action. The activities would be consistent with the BLM visual resource classification of the area and the existing natural resource extraction 

No impacimpact to from the following 

8-9 
Table 8-1. Summary of Environmental Consequences 

The Proposed Action (Alternative 1) 

Impact Category (as 

applicable)

Unavoidable Adverse 

Environmental Impacts 

Irreversible and 

Irretrievable 

Commitment of 

Resources 

Short-term Impacts and 

Uses of the Environment 

Long-Te

Ma

En

activities. 

Socioeconomic 4.11.1 

For each phase of the proposed Moore Ranch Project, the socioeconomic impact would be SMALL except during the operations phase when the potential impact to housing could range from SMALL to MODERATE. 

Not applicable. Implementing the proposed 

action would predominantly have a SMALL impact on the local communities except for housing availability. Although jobs would be created and the purchase of goods and services would contribute to the Campbell County tax base, implementation of the proposed action could affect housing availability and result in a SMALL to MODERATE impact. 

Following individuaactivities Moore Rneed to fand there revenue 

Environmental Justice 4.12.1 

There would be no disproportionately high and adverse impacts to minority or low-income populations from the construction, operation, aquifer restoration, and decommissioning of the proposed Moore Ranch Project. 

Not applicable There would be no 

disproportionately high and adverse impacts to minority or low-income populations from the construction, operation, aquifer restoration, and decommissioning of the proposed Moore Ranch Project. 

None. 

Public and There would be a SMALL Not applicable. There would be a SMALL No impac

8-12 

8-10 
Table 8-1. Summary of Environmental Consequences 

The Proposed Action (Alternative 1) 

Impact Category (as 

applicable)

Unavoidable Adverse 

Environmental Impacts 

Irreversible and 

Irretrievable 

Commitment of 

Resources 

Short-term Impacts and 

Uses of the Environment 

Long-Te

Ma

En

Occupational Health and Safety 4.13.1 

impact on public and occupational health from implementing the proposed action. Construction and decommissioning would generate fugitive dust emissions that could result in a dose comparable to that from natural background exposure. 

impact from radiological exposure comparable to that from natural background. The radiological impacts from accidents would be SMALL for workers if procedures to deal with accident scenarios were followed, and SMALL for the public because of the facility’s remote location. The nonradiological public and occupational health impacts from normal operations, accidents, and chemical exposures would be SMALL if handling and storage procedures were followed. 

long-term occupatiolicense te

Waste Management 4.14.1 

Waste generation and disposal from all phases of the proposed Moore Ranch ISR activities would result in SMALL impacts on available disposal capacity, since permitted facilities are available to accept the wastes. Construction wastes would be mostly 

The energy consumed during the ISR phases, the construction materials used that could not be reused or recycled, and the space used to properly handle and dispose of all waste types (i.e., wells for liquid wastes and permitted disposal space for solid 

During all phases, hazards associated with handling and transport of wastes would represent a short-term and SMALL impact. 

During apermanein on-site representhe long-the land wells. 

8-11 
Table 8-1. Summary of Environmental Consequences 

The Proposed Action (Alternative 1) 

Impact Category (as 

applicable)

Unavoidable Adverse 

Environmental Impacts 

Irreversible and 

Irretrievable 

Commitment of 

Resources 

Short-term Impacts and 

Uses of the Environment 

Long-Te

Ma

En

solids, operations wastes would include solids (primarily municipal waste) and liquids (brine, plant washdown water, and others), and decommissioning wastes would include a range of solid wastes (nonhazardous, hazardous, and solid byproduct materials). 

wastes) would represent an irretrievable commitment of resources, resulting in a SMALL impact. 

8-12 
9-1

9 LIST OF PREPARERS 

This section documents all individuals who were involved with the preparation of this 

Supplemental Environmental Impact Statement (SEIS). Contributors include staff from the 

U.S. Nuclear Regulatory Commission (NRC) and consultants. Each individual’s role, education, 

and experience are outlined below. 

9.1 U.S. Nuclear Regulatory Commission Contributors 

Behram Shroff: Supplemental Environmental Impact Statement (SEIS) Lead Project Manager 

 M.C.P., City/Regional Planning, Georgia Institute of Technology, 1973 

 M. S., Engineering, University of California, Berkeley, 1966 

 Years of Experience: 29 

Jennifer Davis: Socioeconomics and Cultural Resources 

B.A., Historic Preservation and Classical Civilization (Archaeology), Mary Washington 

College, 1996 

Years of Experience: 11 

Nathan Goodman: Ecological Resources 

 M.S., Environmental Science, Johns Hopkins University, 2000 

B.S., Biology, Muhlenberg College, 1998 

 Years of Experience: 6 

Asimios Malliakos: Cost-Benefit Analysis 

 Ph.D., Nuclear Engineering, University of Missouri-Columbia, 1980 

 M.S., Nuclear Engineering, Polytechnic Institute of New York, 1977 

 B.S., Physics, University of Thessaloniki, Greece, 1975 

 Years of Experience: 29 

 

Douglas Mandeville: In-Situ Recovery Process 

 M.S., Civil Engineering, Clarkson University, 1999 

 B.S., Civil Engineering, Clarkson University, 1997 

 Years of Experience: 10 

Johari Moore: Public and Occupational Health 

 M.S., Nuclear Engineering and Radiological Science, University of Michigan, 2005 

 B.S., Physics, Florida A&M University, 2003 

 Years of Experience: 4 

James Park: Reviewer 

 M. Ed., Childhood Education, Marymount University, 1999 

M.S., Structural Geology & Rock Mechanics, Imperial College, University of London, 

England, 1988 

 B.S., Geology, Virginia Polytechnic Institute and State University, 1986 

 Years of Experience: 15 

Ashley Riffle: Reviewer 

 B.S., Biology, Frostburg State University, 2009 

 Years of Experience: 1 
List of Preparers 

 9-2

Elise Striz: Groundwater Reviewer 

 Ph. D., Petroleum Engineering, University of Oklahoma, 1998 

 M.S. Civil Engineering, University of Oklahoma, 1985 

 B.S., Environmental Engineering, Purdue University, 1981 

 Years of Experience: 17 

Patricia Swain: SEIS Project Manager 

 M.S., Geology, University of California, Los Angeles, 1981 

 B.S., Geology, University of Texas at Austin, 1976 

Years of Experience: 24 

Jim Webb: Public and Occupational Health Reviewer 

 M.S., Marketing and Communication, Franklin University, 2000 

 M.B.A., Business Administration, Lake Erie College, 1983 

 B.S., Radiological Health Physics, Lowell University, 1978 

 Years of Experience: 31 

9.2 Center for Nuclear Waste Regulatory Analyses (CNWRA®) 

Contractor Contributors 

Hakan Basagaoglu: Water Resources, Cumulative Impacts 

Ph.D., Civil and Environmental Engineering, University of California, Davis 2000 

M.S., Geological Engineering, Middle East Technical University, Turkey 1993 

B.S., Geological Engineering, Middle East Technical University, Turkey 1991 

Years of Experience: 17 

Philippe Dubreuilh: Land Use 

 Ph.D., Geology, University of Bordeaux, France, 1982 

M.S., Geology, University of Bordeaux, France, 1977 

B.S., Geology, University of Bordeaux, France, 1976 

Years of Experience: 34 

Amy Glovan: Ecological Resource 

B.A., Environmental Studies, University of Kansas, 1998 

Years of Experience: 11 

Lane Howard: Occupational Health and Safety (Nonradiological and Radiological) 

M.S., Nuclear Engineering, Texas A&M University, 1995 

B.S., Civil Engineering, Texas A&M University, 1988 

Years of Experience: 22 

Miriam Juckett: Principal Investigator 

M.S., Environmental Sciences, University of Texas at San Antonio, 2006 

B.S., Chemistry, University of Texas at San Antonio, 2003 

 Years Experience: 7 

Patrick LaPlante: Transportation and Air Quality 

M.S., Biostatistics and Epidemiology, Georgetown University, 1994 

B.S., Environmental Studies, Western Washington University, 1988 

Years of Experience: 22 
 9-3

List of Preparers 

James Myers: Waste Management 

Ph.D., Environmental Science & Engineering, Clemson University, 2004 

M.S., Geophysical Sciences, Georgia Institute of Technology, 1990 

B.S., Geology, Michigan State University, 1985 

Years of Experience: 25 

Jude McMurry: Geology and Soils 

Ph.D., Geosciences, Texas Tech University, 1991 

M.A., Geological Sciences, University of Texas at Austin, 1982 

B.A., English, McMurry University, 1975 

Years Experience: 35 

Robert Pauline: Cumulative Impacts 

M.S., Biology, Environmental Science and Policy, George Mason University, 1999 

B.S., Biology, Bates College, 1989 

Years Experience: 21 

Marla Roberts: NEPA Reviewer 

M.S., Geology, University of Texas at San Antonio, 2007 

B.A., Geology, Vanderbilt University, 2001 

Years Experience: 9 

John Stamatakos: Project Manager 

Ph.D., Geology, Lehigh University, 1990 

M.S., Geology, Lehigh University, 1988 

B.S., Geology, Franklin and Marshall College, 1981 

Years of Experience: 29 

David Turner: Cumulative Impacts 

Ph.D., Geology, University of Utah, 1990 

M.S., Geology, University of Utah, 1985 

B.A., Music/Geology, College of William and Mary, 1981 

Years Experience: 29 

Deborah Waiting: Geographic Information System (GIS) Analyst 

B.S., Geology, University of Texas at San Antonio, 1999 

Years Experience: 11 

Gary Walter: Waste Management Resources 

Ph.D., Hydrology, University of Arizona, 1985 

M.A., Geology, University of Missouri, Columbia, 1974 

B.A., Chinese and Sociology, University of Kansas, 1969 

Years Experience: 41 

Bradley Werling: NEPA Reviewer 

M.S., Environmental Science, University of Texas at San Antonio, 2000 

B.S., Chemistry, Southwest Texas State University, 1999 

B.A., Engineering Physics, Westmont College, Santa Barbara, 1985 

Years of Experience: 25 
List of Preparers 

 9-4

9.3 CNWRA Consultants and Subcontractors 

Susan Courage: Socioeconomics and Environmental Justice 

M.S., Environmental Science, University of San Antonio at San Antonio, 2003 

B.S., Biology, University of San Antonio at San Antonio, 1999 

Years of Experience: 11 

Eunice Fedors: Cultural and Historic Resources 

B.A., Historic Preservation, Mary Washington College, 1985 

Years of Experience: 25 

Raba-Kistner Inc.

Samuel Blanco: Cumulative Impacts 

 M.S., Environmental Science, Texas A&M University – Corpus Christi, 2002 

 B.S., Biology, Texas A&M University, Kingsville, 1998 

 Years of Experience: 10 
10-1 

10 DISTRIBUTION LIST 

The U.S. Nuclear Regulatory Commission (NRC) is providing copies of this Supplemental 

Environmental Impact Statement (SEIS) to the organizations and individuals listed below. The 

NRC will provide copies to other interested organizations and individuals upon request. 

10.1 Federal Agency Officials 

James Hanley 

 U.S. Environmental Protection Agency 

 Region 8 

 Denver, CO 

Carol Rushin 

 U.S. Environmental Protection Agency 

 Region 8 

 Denver, CO 

Larry Svoboda 

 U.S. Environmental Protection Agency 

 Region 8 

 Denver, CO 

Brian Kelly 

 U.S. Fish and Wildlife Service 

 Mountain-Prairie Region 

 Wyoming Field Office 

 Cheyenne, WY 

Ramon Nation 

 Bureau of Indian Affairs 

 Wind River Agency 

 Ft. Washakie, WY 

Gerald Queen 

 Bureau of Land Management 

 Buffalo Field Office 

 Buffalo, WY 

Pete Sokolosky 

 Bureau of Land Management 

 State Office 

 Cheyenne, WY 

Robert Stewart 

 U.S. Department of the Interior 

 Office of the Secretary 

 Office of Environmental Policy and Compliance 

 Denver, CO 
Distribution List 

10-2

10.2 Tribal Government Officials 

Perry Brady 

 Three Affiliated Tribes 

 Tribal Historic Preservation Office 

 New Town, ND 

Conrad Fisher 

 Northern Cheyenne 

 Tribal Historic Preservation Office 

 Lame Deer, MT 

John Murray 

 Blackfeet 

 Tribal Historic Preservation Office 

 Browning, MT 

Dale Old Horn 

 Crow 

 Tribal Historic Preservation Office 

 Crow Agency, MT 

Donna Rae Peterson 

 Cheyenne River Sioux 

 Tribal Historic Preservation Office 

 Eagle Butte, SD 

Arlen Shoyo 

 Eastern Shoshone 

 Tribal Historic Preservation Office 

 Ft. Washakie, WY 

Joanne White 

 Arapaho 

 Tribal Historic Preservation Office 

 Ft. Washakie, WY 

Joyce Whiting 

 Oglala Sioux 

 Tribal Historic Preservation Office 

 Pine Ridge, SD 

Darrel Youpee 

 Ft. Peck 

 Tribal Historic Preservation Office 

 Poplar, MT 
 Distribution List 

 10-3

10.3 State Agency Officials 

Richard Currit 

 Wyoming State Historic Preservation Office 

 Cheyenne, WY 

Don McKenzie 

 Wyoming Department of Environmental Quality 

 Cheyenne, WY 

Mark Rogaczewski 

 Wyoming Department of Environmental Quality 

 Sheridan District 

 Sheridan, WY 

10.4 Local Agency Officials 

Craig Collins 

 Casper Planning Department 

 Casper, WY 

Joe Coyne 

 Converse Area New Development Organization 

 Douglas, WY 

David Haney 

 Wyoming Community Development Authority 

 Casper, WY 

Lyle Murdock 

 Building Department 

 Wright, WY 

Robert Palmer 

 Campbell County Commissioners 

 Gillette, WY 

Forrest Neuerberg 

 Converse County Planning Department 

 Douglas, WY 

Michael Surface 

 Campbell County Economic Development Commission 

 Gillette, WY 
Distribution List 

10-4

10.5 Other Organizations and Individuals 

Shannon Anderson 

 Powder River Basin Resource Council 

 Sheridan, WY 

Geoffrey Fettus 

 Natural Resources Defense Council 

 Washington, DC 

Cori Lombard 

 Natural Resources Defense Council 

 Washington, DC 

Sarah Fields 

 Sierra Club – Glen Canyon Group 

 Salt Lake City, UT 

Michael Griffin 

 Uranium One Inc. 

 Casper, WY 

Eric Jantz 

 New Mexico Environmental Law Center 

 Santa Fe, NM 

Jim Jones 

 Hulett, WY 

Steve Jones 

 Wyoming Outdoor Council 

 Lander, WY 

Marion Loomis 

 Wyoming Mining Association 

 Cheyenne, WY 

Wayne Prindle 

 Biodiversity Conservation Alliance 

 Laramie, WY 

Jonathan B. Rattner 

 Western Watersheds Project 

 Pinedale, WY 

Christopher S. Pugsley, Esq. (on behalf of National Mining Association) 

 Thompson & Simmons, PLLC 

 Washington, DC 
 Distribution List 

 10-5

Pam Viviano 

 Ranchers & Neighbors Protecting Our Water 

 Sheridan, WY 

Jon Winters 

 Uranium One Americas 

 Casper, WY 

Tony Thompson 

 National Mining Association 

 Washington, DC 

 

 

APPENDIX A 

CONSULTATION CORRESPONDENCE
 

 
A–1 

A Consultation Correspondence 

The Endangered Species Act of 1973, as amended, and the National Historic Preservation Act 

of 1966 require that Federal agencies consult with applicable state and federal agencies and 

groups prior to taking action that may affect threatened and endangered species, essential fish 

habitat, or historic and archaeological resources, respectively. This appendix contains 

consultation documentation related to these federal acts. 

Table A1–1. Chronology of Consultation Correspondence 

Author Recipient Date of Letter 

U.S. Nuclear Regulatory 

Commission (G. Suber) 

Wyoming State Historic 

Preservation Office 

(M. Hopkins) 

April 9, 2008 

U.S. Nuclear Regulatory 

Commission (G. Suber) 

U.S. Fish and Wildlife Service 

(B. Kelly) April 9, 2008 

U.S. Fish and Wildlife Service 

(B. Kelly) 

U.S. Nuclear Regulatory 

Commission (G. Suber) May 7, 2008 

Wyoming State Parks and 

Cultural Resources (R. Currit) 

U.S. Nuclear Regulatory 

Commission (G. Suber) June 5, 2008 

U.S. Nuclear Regulatory 

Commission (A. Kock) 

Shoshone Business Council (I. 

Posey) February 23, 2009 

U.S. Nuclear Regulatory 

Commission (I. Yu, B. Shroff, 

and A. Bjornsen) 

U.S. Nuclear Regulatory 

Commission (A. Kock) March 2, 2009 

U.S. Nuclear Regulatory 

Commission (A. Kock) 

Wyoming Game and Fish 

Department (T. Christiansen) August 5, 2009 

Wyoming Game and Fish 

Department (T. Christiansen) 

U.S. Nuclear Regulatory 

Commission (A. Kock) September 3, 2009 

U.S. Nuclear Regulatory 

Commission (A. Kock) 

Wyoming State Historic 

Preservation Office (R. Currit) 

October 22, 2009 

Wyoming State Parks & Cultural 

Resources (R. Currit) 

U.S. Nuclear Regulatory 

Commission (A. Kock) November 3, 2009 

Wyoming State Parks and 

Cultural Resources (R. Currit) 

U.S. Nuclear Regulatory 

Commission (J. Davis) June 15, 2010 
Appendix A 

A–2 
Appendix A 

 A–3
Appendix A 

 A–4
Appendix A 

 A–5
Appendix A 

 A–6
Appendix A 

 A–7
Appendix A 

 A–8
Appendix A 

 A–9
Appendix A 

 A–10
Appendix A 

 A–11
Appendix A 

 A–12
Appendix A 

 A–13
Appendix A 

 A–14
Appendix A 

 A–15
Appendix A 

 A–16
Appendix A 

 A–17
Appendix A 

 A–18
Appendix A 

 A–19
Appendix A 

 A–20
Appendix A 

 A–21
Appendix A 

 A–22
Appendix A 

 A–23
Appendix A 

 A–24
Appendix A 

 A–25
Appendix A 

 A–26
Appendix A 

 A–27
Appendix A 

 A–28
Appendix A 

 A–29
Appendix A 

 A–30
Appendix A 

 A–31
Appendix A 

 A–32
Appendix A 

 A–33
Appendix A 

 A–34
Appendix A 

 A–35
Appendix A 

 A–36
Appendix A 

 A–37
Appendix A 

 A–38
Appendix A 

 A–39
Appendix A 

 A–40
Appendix A 

 A–41
Appendix A 

A–42 
Appendix A 

 A–43

APPENDIX B 

PUBLIC COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT 

STATEMENT FOR THE MOORE RANCH IN-SITU RECOVERY PROJECT IN 

CAMPBELL COUNTY, WYOMING, AND U.S. NUCLEAR REGULATORY 

COMMISSION RESPONSES 

Appendix B 

B–i 

CONTENTS 

TABLES ................................................................................................................................... B–iv 

ABBREVIATIONS/ACRONYMS ............................................................................................... B–v 

B1 OVERVIEW ...................................................................................................................B–1 

B2 PUBLIC PARTICIPATION ............................................................................................. B–1 

 B2.1 Notice of Intent To Develop the SEIS .......................................................... B–1 

 B2.2 Public Participation Activities ....................................................................... B–1 

 B2.3 Issuance and Availability of the SEIS .......................................................... B–2 

 B2.4 Public Comment Period ............................................................................... B–2 

B3 COMMENT REVIEW METHODS ................................................................................. B–2 

B4 MAJOR ISSUES AND TOPICS OF CONCERN ........................................................... B–5 

B5 COMMENT SUMMARIES AND RESPONSES ............................................................. B–5 

 B5.1 General Opposition ...................................................................................... B–5 

 B5.1.1 References .............................................................................. B–7 

 B5.2 General Support .......................................................................................... B–7 

 B5.3 General Environmental Concerns ............................................................... B–7 

 B5.4 NEPA Process ............................................................................................. B–8 

 B5.4.1 GEIS/SEIS .............................................................................. B–8 

 B5.4.2 Adequacy of Impact Assessment .......................................... B–10 

 B5.4.3 Range of Reasonable Alternatives ....................................... B–15 

 B5.4.4 References ............................................................................ B–16 

 B5.5 Purpose, Need, and Scope of the SEIS/GEIS ........................................... B–17 

 B5.5.1 Description of the SEIS/GEIS Purpose and Need ................ B–17 

 B5.5.2 Use of the GEIS in Site-Specific Environmental Reviews ..... B–19 

 B5.5.3 Scope of the SEIS/GEIS ....................................................... B–20 

 B5.5.4 Reference ............................................................................. B–21 

 B5.6 Scoping Process and Scoping Report ....................................................... B–21 

 B5.6.1 References ............................................................................ B–22 

 B5.7 SEIS/GEIS Methods and Approach ........................................................... B–23 

 B5.7.1 Consider Compliance History in Assessing Impacts ............. B–23 

 B5.7.2 General Comments on SEIS/GEIS Structure, Methods, 

 and Approaches .................................................................... B–24 

 B.5.7.3 References ................................................................................. B–24 

 B5.8 Public Involvement .................................................................................... B–24 

 B5.8.1 References ............................................................................ B–26 

 B5.9 Regulatory Issues and Process ................................................................. B–26 

 B5.9.1 NRC as a Regulatory Authority ............................................. B–26 

 B5.9.2 NRC Authority and Jurisdiction ............................................. B–26 

 B5.9.3 NRC Policies and Practices .................................................. B–27 

 B5.9.4 Adequacy of NRC Regulations and Practices ...................... B–28 

 B5.9.5 Applicable Rulemaking Efforts .............................................. B–30 

 B5.9.6 NRC NEPA Process Implementation .................................... B–31 

 B5.9.7 NRC Licensing Process ........................................................ B–31 

 B5.9.8 Consideration of ISL Facility Safety Record and 

 Compliance History ............................................................... B–33 

 B5.9.9 Groundwater Restoration Criteria and Methods ................... B–34 
Appendix B 

B–ii 

CONTENTS (continued) 

 B5.9.10 References ............................................................................ B–37 

 B5.10 Credibility of NRC ...................................................................................... B–39 

 B5.11 Federal and State Agencies ...................................................................... B–40 

 B5.11.1 Roles of Federal, Tribal, State, and Local Agencies ............. B–40 

 B5.11.2 Effects of Changes to Federal or State Regulations on 

 the SEIS ................................................................................ B–42 

 B5.11.3 Clarification of Other Federal/State Regulation 

 and Practice .......................................................................... B–43 

 B5.11.4 References ............................................................................ B–43 

 B5.12 Cooperating Agencies and Consultations ................................................. B–43 

 B5.12.1 References ............................................................................ B–45 

 B5.13 SEIS Schedule .......................................................................................... B–45 

 B5.13.1 References ............................................................................ B–45 

 B.5.14 ISL Process Description ............................................................................ B–46 

 B5.14.1 Overview ............................................................................... B–46 

 B5.14.2 Preconstruction and Construction ......................................... B–46 

 B5.14.3 Operations ............................................................................ B–47 

 B5.14.4 Aquifer Restoration ............................................................... B–48 

 B5.15.5 Gaseous or Airborne Particulate Emissions ......................... B–48 

 B5.14.6 Operational History ............................................................... B–49 

 B5.14.6.1 Historical Operational Experience: Spills 

 and Leaks ...................................................... B–49 

 B5.14.7 Requests for Detailed Information About All ISL Facilities .... B–50 

 B5.14.8 References ............................................................................ B–50 

 B5.15 Financial Surety ......................................................................................... B–51 

 B5.15.1 Reference ............................................................................. B–52 

 B5.16 Alternatives ................................................................................................ B–52 

 B5.16.1 References ............................................................................ B–54 

 B5.17 Land Use ................................................................................................... B–55 

 B5.17.1 Ownership Issues, Surface, and Mineral Rights ................... B–55 

 B5.17.2 Amount of Land Affected and Type, Degree, and Duration 

 of Potential Impacts .............................................................. B–55 

 B5.17.3 Mitigation and Reclamation Issues ....................................... B–58 

 B5.17.4 References ............................................................................ B–60 

 B5.18 Transportation ........................................................................................... B–61 

 B5.18.1 References ............................................................................ B–63 

 B5.19 Geology and Soils ..................................................................................... B–63 

 B5.19.1 Soil Disturbance Concerns ................................................... B–63 

 B5.19.2 Soil Impacts From Surface Spills .......................................... B–65 

 B5.19.3 Permanent Change to Rock Formations ............................... B–66 

 B5.19.4 References ............................................................................ B–66 

 B.20 Groundwater Resources ............................................................................ B–67 

 B5.20.1 General Concerns About ISL and Groundwater 

 Contamination ....................................................................... B–67 

 B5.20.2 Importance of Water and Consumptive Water Use .............. B–67 

 B5.20.2.1 Site Characterization ..................................... B–68 
Appendix B 

B–iii 

CONTENTS (continued) 

 B5.20.2.2 Aquifer Exemption and Baseline 

 Water Quality ................................................. B–70 

 B5.20.2.3 Control of Operational Impacts, 

 Excursion of ISL Solutions, and 

 History ........................................................... B–72 

 B5.20.2.4 Exploratory Drill Wells, Abandoned 

 Wells, and Old Mines .................................... B–75 

 B5.20.3 Aquifer Restoration and Decommissioning: Methods 

 and Operational Experience ................................................. B–76 

 B5.20.4 Miscellaneous Groundwater Comments ............................... B–78 

 B5.20.4 References ............................................................................ B–80 

 B5.21 Surface Water Resources ......................................................................... B–81 

 B5.21.1 Impacts to Surface Drainages and Surface Waters .............. B–81 

 B5.21.2 General Water Resource Concerns ...................................... B–82 

 B5.21.3 References ............................................................................ B–84 

 B5.22 Wetlands .................................................................................................... B–84 

 B5.22.1 References ............................................................................ B–85 

 B5.23 Ecology ...................................................................................................... B–86 

 B5.23.1 General Ecology ................................................................... B–86 

 B5.23.2 Concerns About the Sage-Grouse ........................................ B–86 

 B5.23.3 General Comments on Threatened and Endangered 

 Species ................................................................................. B–86 

 B5.23.4 Concerns About Mitigation and Timing ................................. B–88 

 B5.23.5 Habitat Loss and Fragmentation ........................................... B–89 

 B5.23.6 Comments on Migratory Birds .............................................. B–89 

 B5.23.7 General Vegetation Comments ............................................. B–90 

 B5.23.8 Impacts to Terrestrial Ecology and Wildlife Discussion ........ B–91 

 B5.23.9 Inconsistencies Between Sections ........................................ B–93 

 B5.23.10 References ............................................................................ B–93 

 B5.24 Meteorology, Climatology, and Air Quality ................................................ B–94 

 B5.24.1 Permitting and Regulations ................................................... B–94 

 B5.24.3 Baseline Air Quality ............................................................... B–95 

 B5.24.4 Impact Assessment ............................................................... B–95 

 B5.24.5 References .......................................................................... B–104 

 B5.25 Historical and Cultural Resources ........................................................... B–105 

 B5.25.5 Potential Impacts to Cultural, Historical, and Sacred 

 Places ................................................................................. B–105 

 B5.25.6 License Conditions to Address Potential Impacts to 

 Historical and Cultural Resources ....................................... B–105 

 B5.25.8 Historic and Cultural General .............................................. B–106 

 B5.25.9 References .......................................................................... B–108 

 B5.26 Socioeconomics ...................................................................................... B–108 

 B5.26.1 Reference ........................................................................... B–109 

 B5.27 Public and Occupational Health .............................................................. B–109 

 B5.27.2 Impacts to Members of the General Public ......................... B–109 

 B5.27.3 Impacts From Off-Normal Operations or Accidents ............ B–111 

 B5.27.4 General ............................................................................... B–111 
Appendix B 

B–iv 

CONTENTS (continued) 

 B5.27.5 References .......................................................................... B–113 

 B5.28 Waste Management ................................................................................ B–114 

 B5.28.1 General Waste Management Comments ............................ B–114 

 B5.28.2 Scope of the Assessment of Waste Management 

 Impacts ............................................................................... B–115 

 B5.28.3 Characteristics of Wastes Generated by ISL ...................... B–116 

 B5.28.4 Waste Treatment and Disposal Methods ............................ B–118 

 B5.28.5 Regulation of Wastes and Disposal Methods ..................... B–119 

 B5.28.6 References .......................................................................... B–120 

 B5.29 Decommissioning .................................................................................... B–120 

 B5.29.1 Reference ........................................................................... B–121 

 B5.30 Cumulative Effects ................................................................................... B–121 

 B5.30.1 General Comment: The SEIS Does Not Adequately 

 Address Cumulative Effects ................................................ B–121 

 B5.30.2 Past, Present, and Reasonably Foreseeable 

 Future Actions ..................................................................... B–122 

 B5.30.3 Specific Document Changes or Action Requests ............... B–123 

 B5.30.4 Significance ......................................................................... B–123 

 B5.30.5 Other ................................................................................... B–126 

 B5.30.6 References .......................................................................... B–127 

 B5.31 Environmental Justice ............................................................................. B–127 

 B5.32 Best Management Practices .................................................................... B–128 

 B5.32.1 Enforcement of Mitigation ................................................... B–128 

 B5.32.2 Completeness of the Mitigation Measures and Best 

 Management Practices ....................................................... B–129 

 B5.32.3 General Comments Related to Mitigation Measures 

 and Best Management Practices ........................................ B–130 

 B5.32.4 References .......................................................................... B–132 

 B5.33 Monitoring ................................................................................................ B–132 

 B5.34 Editorial .................................................................................................... B–134 

 B5.34.1 Grammatical Editorial .......................................................... B–134 

 B5.34.2 Technical Editorial ............................................................... B–135 

 B5.34.3 Regulatory Editorial ............................................................. B–140 

TABLE 

B3-1 Public Commenter Name With Affiliation and Comment Document Number ................ B–3 
Appendix B 

B–v 

ABBREVIATIONS/ACRONYMS 

AEA Atomic Energy Act 

ADAMS Agency-wide Documents Access and Management System 

ACL alternate concentration limit 

BLM U.S. Bureau of Land Management 

CBM coal bed methane 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

 

DOE U.S. Department of Energy 

DOT U.S. Department of Transportation 

EMC Energy Metal Corporation US 

EPA U.S. Environmental Protection Agency 

FR Federal Register

GEIS Generic Environmental Impact Statement 

ISL in-situ leach 

ISR in-situ recovery 

IX ion exchange 

LQD Land Quality Division 

MCL maximum contaminant limit 

MIT mechanical integrity test/testing 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act 

NOA Notice of Availability 

NPDES National Pollutant Discharge Elimination System 

NRC U.S. Nuclear Regulatory Commission 

NRHP National Register of Historic Places 

NHPA National Historic Preservation Act of 1966, as amended 

RAI request for additional information 

SDWA Safe Drinking Water Act 

SEIS Supplemental Environmental Impact Statement 

SER safety evaluation report 

SGIT Sage-Grouse Implementation Team 

SHPO State Historic Preservation Office 

TDS total dissolved solids 
Appendix B 

B–vi 

ABBREVIATIONS/ACRONYMS (continued)

UCL upper control limit 

UIC Underground Injection Control 

USDW Underground Source Drinking Water 

WDEQ Wyoming Department of Environmental Quality 

WGFD Wyoming Game and Fish Department 

WSEO Wyoming State Engineer’s Office 
Appendix B 

B–1 

PUBLIC COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT 

STATEMENT FOR THE MOORE RANCH IN-SITU RECOVERY PROJECT IN 

CAMPBELL COUNTY, WYOMING, AND U.S. NUCLEAR REGULATORY 

COMMISSION RESPONSES 

B1 OVERVIEW 

On December 11, 2009, the U.S. Nuclear Regulatory Commission (NRC) staff published a 

notice in the Federal Register requesting public review and comment on the Draft 

Environmental Impact Statement for the Moore Ranch In-Situ Recovery (ISR) Project in 

Campbell County, Wyoming, Supplement to the Generic Environmental Impact Statement 

for In-Situ Leach Uranium Milling Facilities (SEIS) [74 Federal Register (FR) 65806] in 

accordance with 10 Code of Federal Regulations (CFR) Part 51, Environmental Protection 

Regulations for Domestic Licensing and Related Regulatory Functions. The NRC staff initially 

established February 1, 2010, as the deadline for submitting public comments on the draft SEIS. 

The NRC staff subsequently extended this deadline to March 3, 2010 (75 FR 6065). Twenty 

documents (i.e., email, mail, and facsimiles) were submitted to NRC containing comments on 

the proposed Moore Ranch project. In addition to the public comment period, the public also 

had the opportunity to request a hearing {January 25, 2008, [73 FR 4642]}. The deadline to 

request a hearing expired on March 25, 2008. No requests for a hearing were submitted.

B2 PUBLIC PARTICIPATION 

Public participation is an essential part of the NRC environmental review process. This section 

describes the process for public participation during the NRC staff development of the SEIS. 

NRC conducted an open, public SEIS development process consistent with the requirements of 

the National Environmental Policy Act of 1969 (NEPA) and NRC regulations. The NRC staff 

met with Federal, State, and local agencies and authorities, as well as public organizations, as 

part of a site visit to gather site-specific information. Including an extension, NRC provided an 

81-day public comment period for agencies, organizations, and the general public to review the 

draft SEIS and provide comments. 

B2.1 Notice of Intent To Develop the SEIS 

The NRC staff published a Notice of Intent to prepare the SEIS in the Federal Register (74 FR 

42332) on August 21, 2009, in accordance with NRC regulations. 

B2.2 Public Participation Activities 

As described in SEIS Section 1.4.2, the NRC staff met with Federal, State, and local agencies 

and authorities during the course of an expanded visit to the proposed Moore Ranch ISR 

Project site and vicinity. The purpose of this visit and these meetings was to gather additional 

site-specific information to assist in the preparation of the Moore Ranch ISR Project 

environmental review. As part of this effort to gather additional site-specific information, the 

NRC staff also contacted potentially interested Native American tribes and local authorities, 

entities, and public interest groups in person and via e-mail and telephone. Additional 
Appendix B 

B–2 

opportunities for public participation in the licensing process for the proposed Moore Ranch 

Project are described in Section B5.8 of this comment response report. 

B2.3 Issuance and Availability of the SEIS 

On December 11, 2009, in accordance with NRC regulations, the NRC staff published a Notice 

of Availability (NOA) of the draft SEIS in the Federal Register (74 FR 65806). In this notice, the 

NRC staff provided information on how to access or obtain a copy of the draft SEIS. Electronic 

versions of the draft SEIS and supporting information were made accessible through the NRC 

Agencywide Documents Access and Management System (ADAMS) database on the NRC 

website (http://www.nrc.gov/reading-rm/adams.html). The public may examine and have 

copied, for a fee, the draft SEIS and other related publicly available documents from the NRC 

Public Documents Room. Copies of the draft SEIS were also publicly available at the Campbell 

County public libraries. 

B2.4 Public Comment Period 

In the publication of the NOA of the draft SEIS on December 11, 2009 (74 FR 65806), the NRC 

staff stated that public comments on the draft SEIS should be submitted by February 1, 2010. 

Members of the public were invited and encouraged to submit related comments through any 

one of the following means. Electronically, comments could be submitted to the Federal 

rulemaking or the NRC websites. Written comments could be submitted by mail or facsimile. 

On February 5, 2010, the NRC staff extended the public comment period to March 3, 2010 

(75 FR 6065), in response to public requests for extension submitted in comment letters 

and emails. The 81-day period for public comments (i.e., from December 11, 2009 to 

March 3, 2010) exceeds the minimum 45-day comment period required under NRC regulations. 

The NRC staff identified 691 comments from the 20 documents commenting on the Moore 

Ranch draft SEIS. 

B3 COMMENT REVIEW METHODS 

As previously discussed, the NRC staff received 691 comments from 20 documents (i.e., email, 

mail, and facsimiles) during the comment period. Each of these comments has been included in 

the following comment summaries and addressed in the responses provided. Each comment 

was individually identified and responded to using a systematic approach. This approach 

involved indentifying individual comments from the source documents, consolidating comment 

information into a database, sorting all comments by topic, and distributing and reviewing all 

comments by the appropriate staff. 

NRC conducted the Moore Ranch draft SEIS comment period simultaneously with the comment 

period for two other draft SEISs for proposed ISR facilities: Lost Creek and Nichols Ranch. 

Some commenters provided a single document that included comments for two or three of the 

proposed projects. NRC screened each document to determine if it applied only to one project 

or to multiple projects. For documents that commented on multiple projects, copies of the 

document were provided to each individual project and were treated independently from that 

point forward. Each document was given a unique number based on the order in which the 

documents were received. The prefix “MR” was attached to the identification number to indicate 

that this document, or document copy if originally addressing multiple projects, was for Moore 

Ranch. For documents addressing multiple projects, commenters had specified which 
Appendix B 

B–3 

comments applied to the Moore Ranch Project. Sometimes comments were specifically 

directed only to the Moore Ranch Project. In other cases, the commenter stated that the same 

comment applied to multiple projects. Only comments concerning Moore Ranch, either uniquely 

or jointly, were identified and processed within the Moore Ranch version of the document. Lost 

Creek and Nichols Ranch specific comments were not identified and processed within the 

Moore Ranch version of the document. 

The NRC staff reviewed all comment documents and identified, marked, and consecutively 

numbered individual, unique comments in each document. Comment numbers are followed by 

a two-part numbering system separated by a hyphen. The part of the comment number to the 

left of the hyphen is the document number. The number to the right of the hyphen is a 

consecutive, unique- count number for each comment identified in a specific comment 

document. Table B3–1 lists all commenter names, their affiliations, the comment document 

number assigned to their commenter letter, and the ADAMS Accession Number for the 

commenter letter. This table can be used by readers to electronically search the report to locate 

comments submitted by specific individuals or to find individuals associated with comments 

described in Section B.5. 

In addition to the numbering, each unique comment was also assigned a topic category to 

facilitate sorting and reviewing comments on similar topics. Topic categories aligned with the 

topics addressed in Section B.5 of this appendix. Following the initial comment identification 

review, the identified comments were entered into a database that allowed individual comments 

to be sorted by topic and distributed to staff for further consideration. Staff then continued 

sorting and reviewing all comments within specific topic categories, developed comment 

Table B3–1. Public Commenter Name With Affiliation and Comment Document Number 

Name Affiliation 

Comment Document 

Number 

ADAMS Accession 

Number 

Anderson, S. Powder River Basin 

Resource Council 

MR003, MR014 ML100271048 

ML100690176 

Currit, R. Wyoming State Historic 

Preservation Office 

MR007 ML100341192 

Fettus, G. Natural Resources 

Defense Council 

MR001 ML100270995 

Fettus, G. 

Lombard, C. 

Natural Resources MR017 ML100850378 

Jantz, E. New Mexico 

Environmental Law 

Center 

MR005, MR012 ML100270996, 

ML100890375 

Jones, J. Public MR010 ML100890223 

Jones, S. Wyoming Outdoor Council MR006, MR016 ML100271689, 

ML100740240 

Loomis, M. Wyoming Mining 

Association 

MR019 ML100640056 
Appendix B 

B–4 

Table B3–1. Public Commenter Name With Affiliation and Comment Document Number 

Name Affiliation 

Comment Document 

Number 

ADAMS Accession 

Number 

McKenzie, D. Wyoming Department of 

Environmental Quality 

(WDEQ), Land Quality 

Division 

MR018 ML100621314 

Bott, K. WDEQ, Air Quality 

Division 

 

Schroeder, T. WDEQ, Industrial Siting 

Division 

 

Conrad, M. WDEQ, Water Quality 

Division 

 

Anderson, C. WDEQ, Solid and 

Hazardous Waste 

Division 

 

Emmerich, J. Wyoming Game and Fish 

Department 

 

Pugsley, C. National Mining 

Association 

MR013 ML100690165 

Ratner, J. Western Watersheds 

Project 

MR004 ML100270999 

Rushin, C. U.S. Environmental 

Protection Agency, 

Region 8 

MR015 ML100680712 

Stewart, R. U.S. Department of the 

Interior 

MR002 ML100341191 

Svoboda, L. U.S. Environmental 

Protection Agency, 

Region 8 

MR020 ML100890218 

Thompson, T. National Mining 

Association 

MR008 ML102080471 

Viviano, P. Public MR008 ML100890221 

Winter, J. Uranium One Americas MR009 ML100570072 

summaries and responses for this appendix, and changed the draft SEIS, as necessary, to 

address the public comments. 

Based on the similarity of comments related to a specific topic, as appropriate, staff 

consolidated same or similar comments within each topic to facilitate developing responses. 

This approach allowed addressing of multiple, similar comments with a single response, 

avoiding duplication of effort and enhancing readability of this report. For each comment, or 
Appendix B 

B–5 

group of comments, a response has been provided. Each response indicates whether or not 

the SEIS was modified as a result of the comment. 

B4 MAJOR ISSUES AND TOPICS OF CONCERN 

The majority of comments received specifically addressed items within scope of the draft SEIS. 

Topics raised included, and were limited to, a variety of concerns about the purpose, need, and 

scope of the draft SEIS; regulatory issues; NEPA-related concerns; the description of the ISR 

process; land use; groundwater; surface water; ecology; air; historic, cultural, and Native 

American concerns; socioeconomic concerns; public health concerns; waste management; and 

cumulative effects. Other comments addressed topics and issues that are not applicable to the 

SEIS, including general support or opposition for uranium milling, legacy of past uranium mining 

and milling, evaluation of the NRC regulatory program or licensing process, comparison of the 

Moore Ranch financial assurance to previous restoration funding, compensation requests for 

loss of private water supplies, environmental impacts at disposal facilities for radioactive 

byproduct material other than Moore Ranch, and comments not specifically directed towards the 

draft SEIS [e.g., comments exclusively directed towards the generic environmental impact 

statement (GEIS)]. 

B5 COMMENT SUMMARIES AND RESPONSES 

Detailed responses to comments are provided in this section. The structure of this section is 

based on the comment topics provided. Within each topic-specific subsection, the detailed 

presentation of comment and response information includes the applicable comment 

identification numbers, comment summaries, and the NRC staff response. 

B5.1 General Opposition 

Comments: MR001-002; MR002-005; MR010-006; MR012-079 

Some commenters found the GEIS “wanting” and noted that the GEIS environmental analysis 

was deficient in several respects; however, they did not provide examples or citations. Another 

commenter was opposed to the proposed project because the long-term effects from ISR sites 

are unknown. Other commenters stated that NRC should “scrap” the current draft SEIS, 

conduct public scoping meetings, and issue another draft SEIS for public comment without 

reliance on the GEIS for site-specific analysis. 

Response: The GEIS provides criteria for each environmental resource area to help determine 

the significance level for potential impacts (e.g., SMALL, MODERATE, or LARGE). The NRC 

staff applied these criteria to the site-specific conditions at the proposed Moore Ranch Project. 

The NRC recognizes that some commenters are not supportive of the development of either the 

GEIS or the Moore Ranch SEIS. NRC held a 103-day public comment period for the draft GEIS 

from July 28, 2008, through November 7, 2008, at which time members of the public were 

invited to provide comments, including eight public scoping meetings. The NRC considered and 

responded to comments received on the draft GEIS in Appendix G of the final GEIS [NOA 

published in the Federal Register on June 5, 2009 (74 FR 27052)]. Therefore, comments on the 

GEIS are beyond the scope of the Moore Ranch SEIS. 

The Moore Ranch draft SEIS public participation process is described in Section 1.4.2 of the 

final SEIS. The Moore Ranch draft SEIS was prepared to fulfill the requirement under 
Appendix B 

B–6 

10 CFR 51.20(b)(8) to prepare an EIS, or supplement to an EIS for the issuance of a source 

material license. The GEIS provided a starting point for the NRC NEPA analysis at the Moore 

Ranch site. The Moore Ranch site environmental review was initiated by the applicant submittal 

and NRC acceptance of the license application for detailed technical review, as discussed in the 

final SEIS Section 1.6.1. No further changes were made to the Moore Ranch SEIS beyond the 

information provided in this response. 

Comments: MR010-001; MR011-001 

Some commenters were adamantly opposed to granting a project permit. Another commenter 

stated that the ISR process was an injustice to the people of Wyoming. 

Response: The NRC recognizes that some commenters are not supportive of uranium milling. 

These comments are beyond the scope of the GEIS. 

Comment: MR017-003 

A commenter was opposed to in-situ milling, and described it as “not a benign substitute for past 

uranium recovery” and suggested that the NRC “...examine and present to the public a precise 

history of conditions at in-situ leach (ISL) uranium mining operations...” both pre and 

postoperation. 

Response: The NRC recognizes that some commenters are not supportive of uranium milling. 

Chapter 2 of the GEIS provides information on the uranium recovery using the ISR process. 

Information regarding operational experience at ISR facilities is discussed in Section 2.11 of the 

GEIS. These comments are beyond the scope of the SEIS. 

Comment: MR017-033 

A commenter urged the withdrawal of both the draft SEIS and the final GEIS, for failing to meet 

the requirements of NEPA. The commenter stated the document was legally deficient because 

it failed to address a number of substantive matters, take a hard look at the proposed action, 

consider a reasonable range of alternatives, and analyze cumulative impacts in the region of the 

proposed action. 

Response: The NRC recognizes that some commenters are not supportive of the development 

of either the SEIS or GEIS. As previously noted, NRC held a 103-day public comment period 

for the draft GEIS from July 28, 2008, through November 7, 2008, at which time members of the 

public were invited to provide comments, including eight public scoping meetings. The NRC 

considered and responded to comments received on the draft GEIS in Appendix G of the final 

GEIS (see NOA published in the Federal Register on June 5, 2009 (74 FR 27052). Therefore, 

comments on the GEIS are beyond the scope of the Moore Ranch SEIS. 

The Moore Ranch SEIS was prepared in accordance with NRC guidance in NUREG–1748 

(NRC, 2003) and is consistent with NRC implementing regulations in 10 CFR Part 51. 

Chapter 2 of the Moore Ranch SEIS describes the proposed action and alternatives and 

Chapter 5 analyzes the cumulative impact from licensing the proposed Moore Ranch Project. 

No further changes were made to the Moore Ranch SEIS beyond the information provided in 

this response. 

For detailed comments and responses on topics related to those expressed in some of the 

general opposition comments, see the following sections of this comment response appendix: 
Appendix B 

B–7 

NEPA Process (B5.4); Purpose, Need, and Scope of the SEIS/GEIS(B5.5); Public Involvement 

(B5.8); and History and Legacy of Uranium Mining (B5.17). 

B5.1.1 References 

10 CFR Part 40. Code of Federal Regulations, Title 10, Energy, Part 40, “Domestic Licensing of 

Source Material.” Appendix A, “Criteria Relating to the Operation of Uranium Mills and the 

Disposition of Tailings or Wastes Produced by the Extraction or Concentration of Source 

Material From Ores Processed Primarily for Their Source Material Content.” 

74 FR 27052, NRC, June 5, 2009. “Notice of Availability of Final Generic Environmental Impact 

Statement for In-Situ Leach Uranium Milling Facilities.” Federal Register. Vol. 74, No. 107. pp. 

27052–27054. 

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

NRC, 2003. NUREG–1748, “Environmental Review Guidance for Licensing Actions Associated 

with NMSS Programs.” Washington, DC: NRC. August. 

B5.2 General Support 

Comment: MR018-096 

A commenter was generally supportive of the development of the SEIS, stating it was a “great 

improvement from prior versions.” 

Response: The NRC recognizes that some commenters are supportive of the development of 

the environmental review for the proposed Moore Ranch Project. However, these comments 

are beyond the scope of the SEIS. 

Comment: MR019-001 

A commenter was supportive of the benefits that the proposed Moore Ranch Project would 

bring to the surrounding area and to the State of Wyoming to include jobs, tax revenues, and 

domestically produced uranium to fuel current U.S. nuclear reactors. 

Response: The NRC recognizes that some commenters are supportive of the development of 

the Moore Ranch in-situ uranium milling facility. However, these comments are beyond the 

scope of the SEIS. 

B5.3 General Environmental Concerns 

Comments: MR003-002, MR006-002

Two commenting organizations stated that uranium exploration and production impacts many of 

their members since these individuals live, work, or recreate in areas where such activities 

are conducted. 

Response: The NRC acknowledges that uranium milling activities may impact individuals who 

live, work, or recreate in and around the proposed Moore Ranch Project. The environmental 

review documented in this final SEIS addresses potential environmental impacts covering a 
Appendix B 

B–8 

variety of resource areas that can affect impacted individuals. Because the comment was 

general in nature, no changes were made to the final SEIS. 

B5.4 NEPA Process 

B5.4.1 GEIS/SEIS 

Comment: MR017-006 

One commenter stated that NRC, in its final GEIS, had provided little more than a cursory 

response to comments submitted by the commenter and others on the draft GEIS. For 

example, the commenter stated that the U.S. Bureau of Land Management (BLM) and the 

U.S. Environmental Protection Agency (EPA) submitted approximately 77 comments, only 16 of 

which resulted in changes to the GEIS. The commenter considered that this minimal response 

meant that NRC did not fulfill its responsibility under NEPA, which requires that agencies 

respond to comments submitted by the public or cooperating agencies. The commenter stated 

that NRC responses to comments on the draft GEIS were conclusory and non-responsive, 

thereby failing a basic requirement of NEPA and the agency duty to supplement, modify, or 

improve its analyses in response to comment. 

Response: NRC disagrees with the commenter that the final GEIS response to comments was 

inadequate. NEPA requires an agency to have a reasonable response to comments but does 

not require an agency to accept recommendations or suggestions of other agencies or 

commenters. An agency is not obligated to conduct new studies in response to issues raised in 

comments, nor is it obligated to resolve conflicts raised by opposing viewpoints. The standard 

requires that agencies identify opposing views found in the comments such that differences in 

opinion are readily apparent and there is a good faith, reasoned analysis in the response. 

The NRC published the final GEIS on June 5, 2009 (74 FR 27052). The final GEIS included 

Appendix G, which was dedicated to identifying and summarizing comments submitted on the 

draft GEIS and NRC responses to those comments. Pursuant to NRC regulations under 

10 CFR Part 51 that implement NEPA, and specifically 10 CFR 51.91(a), NRC responses took 

one of the following forms: 

(i) Modification of alternatives, including the proposed action 

(ii) Development and evaluation of alternatives not previously given 

serious consideration 

(iii) Supplementation or modification of analyses 

(iv) Factual corrections 

(v) Explanation of why comments do not warrant further response, source citing, 

authorities, or reasons that support this conclusion 

The NRC staff consider its response to comments on the draft GEIS, as documented in the 

main text and appendices of the final GEIS, to be consistent with NRC responsibilities under its 

NEPA implementing regulations, 10 CFR Part 51. No further modification to the Moore Ranch 

SEIS was made beyond the information provided in this response. 

Comments: MR012-011; MR017-016 

Two commenters stated that there were many figures in the Moore Ranch draft SEIS that were 

either illegible or barely legible. Both commenters stated that the failure to present legible 

information within the draft SEIS violated NEPA and its implementing regulations. One 
Appendix B 

B–9 

commenter additionally stated that it was difficult to review the data provided from such poor 

quality reproductions. 

Response: NRC regrets that many of the figures in the Moore Ranch draft SEIS did not 

reproduce well in the printed versions of the document that were mailed to the commenters, 

among others. Additionally, the electronic version of the Moore Ranch draft SEIS, which NRC 

made available through its public website, contained the same poor quality figures because the 

electronic version was simply a scanned copy of the printed version. However, as one of the 

commenters noted, the NRC published revised figures and posted them on its public website as 

quickly as possible. 

The NRC staff revised 17 figures in this final SEIS. 

Comments: MR012-033; MR012-035 

One commenter stated that neither the GEIS nor the Moore Ranch draft SEIS were based on 

accurate data related to the impacts of spills and leaks on water resources and that, therefore, 

neither document was sufficient under NEPA. As background to this comment, the commenter 

characterized the NRC staff evaluation in the GEIS and the Moore Ranch draft SEIS of the 

impacts of spills and leaks on water resources as relying on incomplete and inaccurate data, 

thus, resulting in a misleading impact evaluation in both documents. Additionally, the 

commenter considered that the NRC had not conducted the requisite site-specific analysis of 

impacts from spills and leaks at the Moore Ranch project, but instead the NRC had simply 

stated that the site-specific conditions at Moore Ranch were consistent with the GEIS affected 

environment description to find the significance of such impacts to be SMALL. 

Response: The NRC site-specific analysis of the potential environmental impacts to water 

resources from spills and leaks is found in Section 4.5 of the Moore Ranch draft SEIS. This 

section includes the evaluation of potential surface water and wetlands resources impacts and 

to near-surface groundwater resources from spills and leaks during operations proposed for the 

Moore Ranch Project. This site-specific analysis determined that, for the Moore Ranch Project, 

the significance of potential impacts is expected to be SMALL. This site-specific determination 

draws on the evaluation found in Sections 4.2.4 and 4.3.4 of the GEIS, wherein evaluation 

criteria for considering the significance of impacts is provided. For impacts to surface water and 

wetlands resources the criteria include: size of a spill, success of remediation, use of the 

surface water for domestic or agricultural purposes, proximity of the spill to surface water, and 

compliance with storm water and National Pollutant Discharge Elimination System (NPDES) 

permits issued by the State of Wyoming. In the GEIS, the NRC staff determined that such 

impacts could be SMALL to MODERATE, depending on site-specific conditions. For potential 

impacts to near-surface groundwater resources, the criteria included: proximity of the shallow 

aquifer to the surface, use of the shallow aquifer for domestic or agricultural purposes, and 

connection of the shallow aquifer to other locally or regionally important aquifers. In the GEIS, 

the NRC staff determined that impacts to near-surface aquifers could be SMALL to LARGE, 

depending on site-specific conditions. 

As discussed in this response, the NRC staff conducted a site-specific evaluation of impacts to 

water resources from spills and leaks at the proposed Moore Ranch Project. That evaluation 

determined that such impacts are expected to be SMALL, given the proposed operations and 

site-specific conditions. No modification has been made to the SEIS beyond the information 

provided in this response. 
Appendix B 

B–10 

B5.4.2 Adequacy of Impact Assessment 

Comments: MR015-038; MR012-061 

A commenter rated the Moore Ranch draft SEIS as inadequate pursuant to commenter 

responsibilities under NEPA and authority under Section 309 of the Clean Air Act. The 

commenter further indicated belief that the SEIS did not meet the purposes of NEPA and, 

therefore, should be formally revised and made available for public comment in a supplemental 

or revised SEIS. The commenter indicated that if its concerns were not addressed, then it 

would consider elevating the issue for referral to the Council on Environmental Quality (CEQ) 

for resolution. 

Response: The NRC disagrees with the commenter and believes that the Moore Ranch final 

SEIS adequately addresses all public comments and does not need to be reissued for public 

comment. For further information on how the SEIS tiers from the GEIS and the process of 

determining impacts, refer to Section B5.5.2 of this appendix. The NRC recognizes EPA 

authorities and responsibilities under NEPA and the Clean Air Act to rate draft environmental 

impact statements. The NRC staff consider that it has prepared the Moore Ranch draft SEIS 

consistent with its regulations under 10 CFR Part 51 that implement NEPA and its guidance for 

conducting environmental reviews as found in NUREG-1748 (NRC, 2003). Pursuant to 

10 CFR 51.73, the NRC staff issued the Moore Ranch draft SEIS for public comment on 

December 11, 2009 (74 FR 65806), and the comment period on the document closed on 

March 3, 2010 (75 FR 6065). As discussed previously in this appendix, 691 comments were 

received on the Moore Ranch draft SEIS, among which were additional comments raised by this 

commenter. Consistent with 10 CFR 51.91(a), the NRC staff have considered and responded 

to all comments received. 

Comment: MR016-005 

A commenter stated that the Moore Ranch draft SEIS was deficient because the NRC had 

not balanced the need for the project against the potential impacts to humans and the 

natural environment. 

Response: NRC does not analyze the market conditions or business decision of a private 

entity to submit a license request as part of its licensing decision. NRC licensing decision is 

based on the safety evaluation review and environmental review of an applicant submitted 

license application. The NRC staff prepared the Moore Ranch draft SEIS consistent with 

regulations under 10 CFR Part 51 that implement NEPA and guidance for conducting 

environmental reviews found in NUREG-1748 (NRC, 2003). NRC regulations at 

10 CFR 51.10(b) state that NRC “recognizes a continuing obligation to conduct its domestic 

licensing and related regulatory functions in a manner which is both receptive to environmental 

concerns and consistent with the [NRC’s] responsibility as an independent regulatory agency for 

protecting the radiological health and safety of the public.” 

As stated in Section 1.3 of this SEIS, the purpose and need of the proposed action is to either 

grant or deny Uranium One’s license application to use ISR technology to recover uranium and 

produce yellowcake at the proposed Moore Ranch project. As a regulatory agency, NRC has 

no role in a company’s business decision to submit a license application to operate an ISR 

facility at a particular location. No further changes have been made to the SEIS beyond the 

information provided in this response. 
Appendix B 

B–11 

Comments: MR016-021; MR016-022 

A commenter stated that the Moore Ranch draft SEIS and the GEIS were inadequate for the 

purposes of NEPA, and that the Moore Ranch draft SEIS should be withdrawn, a scoping 

process begun, and the document subsequently reissued for public comment. 

Response: The NRC staff prepared the Moore Ranch draft SEIS consistent with its regulations 

under 10 CFR Part 51 that implement NEPA and its guidance for conducting environmental 

reviews as found in NUREG-1748 (NRC, 2003). Additionally, the GEIS, which this final SEIS 

supplements (see Section 1.4.1), provides a starting point for NRC NEPA analyses for 

site-specific license applications for new ISR facilities, such as the Uranium One application for 

the Moore Ranch Project. Section 2.11 of the GEIS discusses historic ISR facility operations 

licensed by NRC. The NRC staff used this historical information in its generic evaluation of 

potential environmental impacts from the construction, operation, aquifer restoration, and 

decommissioning of ISR facility in specific geographic regions of the western United States. 

This final SEIS tiers and incorporates by reference from the GEIS relevant information, findings, 

and conclusions, depending upon the similarity between the Uranium One (the applicant) 

proposed facility, activities, and conditions at the Moore Ranch site with those for the reference 

facility evaluated in the GEIS. 

The scope of the Moore Ranch SEIS is discussed in Section 1.4 of the final SEIS, and 

opportunities for public participation are discussed in Section 1.4.2. In accordance with NRC 

regulations in 10 CFR 51.26(d), the NRC staff need not conduct a public scoping process for a 

SEIS. Further information regarding scoping is addressed in Section B5.6 of this appendix. 

Comment: MR017-005

A commenter expressed concern that the GEIS and the Moore Ranch draft SEIS gave short 

attention to the recurring issues with uranium solution mines in the United States and other 

countries and ignored long historical evidence that environmental harms, such as the escape of 

extraction fluids from the ore recovery zone, do occur. The commenter provided examples of 

harms that the commenter considered NRC failed to analyze in the draft SEIS. The commenter 

felt it was incumbent upon the NRC to comprehensively address the environmental risks 

inherent in an expansion of the domestic uranium mining and milling industry and to have 

sufficient protections in the licensing process to prevent a recurrence of previous environmental 

harms to the environment and public health. 

Response: The NRC evaluated historical information on ISR operations licensed by the NRC 

(see GEIS, Section 2.11) and considered this historical information to assess the potential 

environmental impacts from the construction, operation, aquifer restoration, and 

decommissioning of an ISR facility in specific geographic regions of the western United States. 

The Wyoming East Uranium Milling Region, where the Moore Ranch Project would be located, 

is in one of these geographic regions (see GEIS, Section 4.3). The final SEIS tiers and 

incorporates by reference from the GEIS relevant information, findings, and conclusions to the 

extent that the applicant proposed facility, activities, and conditions are consistent with the 

reference facility activities, information, and impact conclusions described in the GEIS. 

As discussed in Section 1.7.1 of the GEIS, if a new license (e.g., for ISR operations at the 

Moore Ranch Project) was issued following NRC environmental and safety reviews, NRC would 

ensure that the applicant complied with the conditions in its NRC license and the applicable 

regulations through an inspection program managed out of the NRC Region IV office in 

Arlington, Texas. 
Appendix B 

B–12 

No further changes have been made to the SEIS beyond the information provided in 

this response. 

Comments: MR017-007; MR012-026; MR005-005 

A commenter asserted that NRC had not taken a “hard look” at the environmental impacts, and 

that the draft SEIS added little, if anything, to the sufficiency of NRC analysis of environmental 

impacts from the ISR process. The commenter stated that the draft SEIS analysis mirrored the 

analysis in the final GEIS and that the lack of a discernable difference between the GEIS 

environmental impact findings and those contained in the draft SEIS was a clear indication that 

no searching analyses were performed, as required under NEPA. Another commenter stated 

that the analysis was deficient, but the commenter did not provide specific examples. 

Response: As discussed in Section 1.4.1, the Moore Ranch SEIS supplements the GEIS, 

which provided a starting point for NRC site-specific analysis of potential environmental impacts 

from the construction, operation, aquifer restoration, and decommissioning of the proposed 

Moore Ranch ISR Project facility. The proposed Moore Ranch Project would be located in the 

Wyoming East Uranium Milling Region, one of the four specific geographic regions evaluated in 

the GEIS. Table 1-1 of the Moore Ranch SEIS shows the range of environmental impacts 

expected in the Wyoming East Uranium Milling Region, based on the GEIS analyses. Table 1-1 

shows those resource areas (e.g., transportation, groundwater, noise), for which the GEIS 

concluded there was a range of potential impacts possible, depending on site-specific 

conditions; therefore, these resource areas were evaluated in detail in the SEIS. 

The SEIS evaluated potential impacts in Chapter 4 and relied on a description of the proposed 

Moore Ranch Project facility and associated activities (SEIS Chapter 2), a description of the 

affected environment at and in the vicinity of the proposed Moore Ranch Project (SEIS 

Chapter 3), and the resource criteria identified in the GEIS to assess the significance of the 

environmental impacts. Each resource area was assessed by comparing the site-specific 

conditions at the proposed Moore Ranch Project with the conditions documented in the GEIS, in 

addition to identifying any new or significant information that could result in an environmental 

impact inconsistent with those identified in the GEIS. Table 2-3 summarizes the potential 

environmental impacts from implementing the proposed action at the proposed Moore 

Ranch Project. 

No further changes have been made to the SEIS beyond the information provided in 

this response. 

Comments: MR017-008; MR017-012; MR012-035

A commenter stated that NRC should evaluate the potential impact of spills and that the failure 

to consider spills in the draft SEIS, and more notably in the GEIS, was disappointing. The 

commenter also stated that the potential impacts to groundwater, surface water, and land from 

spills should be considered, with respect to a reasonable range of the possible severity of spills. 

Response: Sections 4.4.1.2, 4.5.1.1.2, and 4.5.2.1.2 of the Moore Ranch SEIS present the 

analysis of the potential environmental impacts on land use, surface water, and groundwater 

from spills associated with the ISR operations at the proposed Moore Ranch Project. 

Sections 4.3.3.2, 4.3.4.1.2, and 4.3.4.2.2.1 of the GEIS discuss these impacts. Table 1-1 in the 

Moore Ranch SEIS summarizes the results of the GEIS analyses of impacts to these resources. 

The SEIS tiered and incorporated by reference from the GEIS, and the analysis demonstrated 
Appendix B 

B–13 

that the proposed facility, activities, and the site-specific conditions at the proposed Moore 

Ranch Project were comparable to that considered in the GEIS, which included: 

• Engineering controls to detect pressure changes in the wellfield piping system; 

• Mechanical integrity testing (MIT) of completed wells prior to their placement in 

service and subsequent retesting every 5 years; 

• Alarm systems for individual wells and in header houses; 

• Daily visual inspection of wellfield monitoring; 

• A spill response plan to address accidental spills; 

• Requirements to remediate affected areas and dispose of contaminated soils; 

• The near-surface aquifer at the proposed site is not an important source for local 

domestic or agricultural water supplies; and 

• The near-surface aquifer is not hydraulically connected to other locally or 

regionally important aquifers. 

Furthermore, should a new license be issued for ISR operations at the Moore Ranch Project, 

the NRC staff would take necessary actions to respond to reported incidents at the facility, 

including spills. NRC would also conduct periodic inspections to determine compliance with 

applicable regulatory requirements, license conditions, and approved procedures. Potential 

violations and allegations would be evaluated and addressed through either the appropriate 

NRC enforcement or allegation programs. 

No further changes have been made to the SEIS beyond the information provided in 

this response. 

Comment: MR017-028

A commenter stated that NRC has the duty to fully explain the science, technology, and 

techniques used in the ISR process and to fully analyze and assess the environmental impacts 

of each aspect of the process. The commenter believes that an environmental review is 

impossible without historical data on the success rates of the technologies used in the ISR 

process. Only by doing so, the commenter states, can NEPA’s “hard look” requirement 

be fulfilled. 

Response: Chapter 2 of the GEIS describes the ISR process used to evaluate the potential 

impacts from an ISR facility. All phases of the ISR facility lifecycle are described and 

information on the historical operating experience at ISR facilities is provided, with respect to 

safety significance and issues of public concern such as spills, leaks, excursions, and aquifer 

restoration. Chapter 2 of the GEIS discussed key aspects of the ISR process common to 

NRC-licensed ISR facilities to build the foundation for GEIS impact analyses. The focus of 

Chapter 2 was to discuss significant issues for ISR proposals and their potential environmental 

impacts, rather than to provide a detailed description of all aspects of every facility that NRC 

has licensed. 

Detailed information regarding the specific technologies, equipment, and operational practices 

and parameters applicable to the proposed Moore Ranch Project are provided in the applicant 

license application and are summarized in Chapters 2 and 6 of the SEIS. The NRC staff 

evaluated the adequacy of the license application with respect to operational safety and 

potential environmental impacts and determined that key aspects of the ISR process proposed 
Appendix B 

B–14 

for implementation at the Moore Ranch Project were consistent with those identified in the GEIS 

before incorporating by reference the relevant sections of the GEIS into the Moore Ranch SEIS. 

While NRC guidance discusses methods that are considered acceptable to staff, NRC does not 

prescribe technology or methods that must be used by an applicant nor is it necessary for NRC 

to proactively evaluate all available options in the GEIS or elsewhere before applications are 

received. Past experience suggests that ISR facilities use similar technology; by focusing on 

what is common, the GEIS provides a reasonable basis for supporting future ISR license 

application reviews. If an applicant application that includes unproven technology or methods 

not analyzed in the GEIS, the NRC review may require additional details and performance data 

and additional environmental impact analysis to verify that safety would be maintained. 

However, as discussed previously, the NRC staff have determined that the key aspects of the 

ISR process of Moore Ranch ISR Project were consistent with those identified in the GEIS. 

No additional changes were made to the Moore Ranch SEIS beyond the information provided in 

this response. 

Comment: MR012-028

A commenter stated that NRC lacked a coherent framework for regulating ISR operations. 

Absent such a framework, the commenter stated that the NRC analysis in the Moore Ranch 

draft SEIS was arbitrary and ad hoc, and the public was unable to rely on any objective, 

consistent standards by which to judge the NRC site-specific environmental analysis. The 

commenter asserted that this approach confounded public participation in the NEPA process 

and is neither supported by NEPA nor its implementing regulations. 

Response: NRC disagrees with the commenter. NRC regulations addressing ISR facility 

licensing include 10 CFR Part 20, 10 CFR Part 40, Appendix A, and 10 CFR Part 51, which 

provides a coherent framework for regulating ISR facilities. NRC also has approximately 

30 years of experience regulating ISR facilities, which has been considered in developing its 

environmental reviews and safety evaluation reports (SERs) and in promulgating the applicable 

regulations, guidance, and license conditions that have been used to regulate ISR facilities 

throughout that timeframe to protect public health and safety and the environment. 

The public participation activities associated with the preparation of the Moore Ranch draft SEIS 

are described in Section B2 of this comment-response appendix and in Section 1.4.2 of the final 

SEIS. The public participation process included commenting on the draft SEIS, which 

was issued for public comment on December 11, 2009. Approximately 700 comments 

were received. 

No further changes have been made to the SEIS beyond the information provided in 

this response. 

Comment: MR012-049 

A commenter stated that the NRC analysis of groundwater impacts from aquifer restoration was 

insufficient and relied entirely on the GEIS framework for analyzing those impacts. As a 

result, the commenter noted that the NRC analysis was limited to impacts from consumptive use 

(i.e., water quantity). 

Response: Groundwater impacts from aquifer restoration are discussed in Section 4.5.2.1.3 of 

the SEIS. As stated there, the potential environmental impacts to groundwater resources during 

aquifer restoration are related to groundwater consumptive use, waste management practices, 

and groundwater quality. NRC analysis of impacts from consumptive use determined that such 

impacts would be SMALL, given that only nominal drawdown would be experienced in private 
Appendix B 

B–15 

wells within 3.2 km [2 mi] of the proposed license area. Similarly, impacts from waste 

management practices were expected to be SMALL due to the characteristics of the proposed 

host formations for deep well injection and the rigor of the Wyoming Department of 

Environmental Quality (WDEQ) permitting process for authorizing deep well injection. Finally, 

the NRC staff determined that the impact of aquifer restoration on groundwater quality would be 

SMALL, because groundwater quality in the impacted aquifers would be restored to water 

quality standards that protect human health and the environment, and that surrounding aquifers 

would not be impacted. 

No further changes have been made to the SEIS beyond the information provided in 

this response. 

Comment: MR015-002

One commenter stressed the need for site-specific information in the analysis of all potential 

impacts associated with ISR projects, and that the Moore Ranch draft SEIS did not provide 

adequate information to effectively address key issues. 

Response: As discussed in Section 1.4.1, this SEIS was prepared to fulfill the requirement at 

10 CFR 51.20(b)(8) to prepare either an EIS or a supplement to an EIS for the issuance of a 

source material license for an ISR uranium recovery facility. This final SEIS supplements the 

GEIS, which provided a starting point for the NRC NEPA analysis (documented here) of the 

Uranium One license application for the proposed Moore Ranch Project. The NRC site-specific 

NEPA analysis used detailed information and descriptions of the proposed ISR facility and 

activities. For example, the characterization of the subsurface stratigraphy and groundwater 

hydrology at the proposed Moore Ranch Project was based on data collected by the applicant 

from 422 boreholes and 34 monitor wells. In addition, approximately 2,700 rotary drill holes and 

approximately 130 core holes were completed by Conoco Minerals Corporation from the 1970s 

through the mid-1980s when the site was being evaluated for conventional milling. These data 

were used by the applicant and reviewed by NRC to characterize the site-specific stratigraphy 

and groundwater hydrology. The hydrologic data collected from these wells were used to 

evaluate how the ore zone would behave, assuming the applicant injected fluids at a certain 

rate. For each of the resource areas evaluated in the SEIS, the NRC staff reviewed the 

information provided by the applicant, validated the information as appropriate, and evaluated 

the potential impact to the environment in the SEIS. 

No further changes have been made to the SEIS beyond the information provided in 

this response. 

B5.4.3 Range of Reasonable Alternatives 

Comments: MR012-007; MR016-002; MR016-004

A commenter noted that while NEPA does not require the NRC to consider every possible 

alternative to the proposed action, it does require that NRC consider all reasonable alternatives. 

The commenter stated that NRC failed to consider reasonable alternatives by limiting the 

analysis to the proposed action and “no action” alternatives. Another commenter disagreed that 

the SEIS eliminated conventional milling as a reasonable alternative to consider for the Moore 

Ranch site, and noted that with good topsoil preservation and appropriate reclamation, it may be 

better from an environmental perspective. Both commenters stated the failure to consider 

reasonable alternatives was a violation of NEPA. One commenter called for the NRC to 

reevaluate the alternatives within the GEIS and the Moore Ranch SEIS. 
Appendix B 

B–16 

Response: The range of reasonable alternatives is defined by the proposed federal action and 

the purpose and need for the proposed federal action. As a regulatory agency, the proposed 

federal action for the Moore Ranch site is a NRC decision of whether to grant or deny the 

license application of a private party. The purpose and need for the proposed federal action 

does consider the applicant goals and objectives to extract uranium from a particular location, 

which helps define what are reasonable alternatives to the proposed federal action. 

Reasonable alternatives considered in a site-specific environmental review depend on the 

proposed action and site conditions. As discussed in Section 2.1 of the SEIS, NRC considered 

all reasonable alternatives, including the No-Action Alternative not approving the license 

application. Section 2.2 of the SEIS provides a discussion of alternatives that were considered 

but eliminated from detailed study and the reasons for the elimination. 

As noted in Section 1.4.5 of this final SEIS, NRC evaluated the potential environmental impact 

from issuing a license to Conoco, Inc., to construct and operate a uranium mill associated with 

an open-pit mine in the same geographic location now being considered for ISR of uranium 

(NRC, 1982). Further, as noted in NUREG–1508, underground mining would have more 

significant environmental impacts than ISR extraction, and the ore from underground mining 

would require processing at a conventional uranium mill to produce the final product. Significant 

quantities of tailings (the residual rock materials after uranium removal) would be produced by 

conventional milling, which are normally disposed of on-site at the conclusion of mill operating 

life (NRC, 1997). NUREG–0706, Final Generic Environmental Impact Statement on Uranium 

Milling (NRC, 1980), provides a detailed evaluation of the impacts associated with tailings 

disposal from conventional uranium milling. The environmental impacts of underground mining 

and conventional milling would be more significant than those from ISR milling. Therefore, 

underground mining and conventional milling are not evaluated in the Moore Ranch SEIS. 

While the NRC staff consider reasonable alternatives to the proposed action in the 

environmental review, the only alternative within NRC decision-making authority is to approve or 

not approve the license application. The NRC has no authority or regulatory control over an 

applicant’s selection of uranium recovery technology to be used at the site. NRC regulatory 

authority is limited to evaluating an applicant license request to use ISR technology at the site. 

If the NRC decides to grant the license request, the applicant must comply with the license, 

NRC regulatory requirements, and any other relevant local, State or Federal requirements to 

operate their facility. 

B5.4.4 References 

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

Protection Against Radiation.” 

10 CFR Part 40. Appendix A. Code of Federal Regulations, Title 10, Energy, Part 40, 

Appendix A, “Criteria Relating to the Operations of Uranium Mills and to the Disposition of 

Tailings or Wastes Produced by the Extraction or Concentration of Source Material from Ores 

Processed Primarily from their Source Material Content.” 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 
Appendix B 

B–17 

74 FR 27052, U.S. Nuclear Regulatory Commission (NRC). “Notice of Availability of Final 

Generic Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities.” Federal 

Register. Vol. 74, No. 107, pp. 27052-27054. June 5, 2009. 

74 FR 65806, NRC. “Notice of Availability of Draft Environmental Impact Statement for the 

Moore Ranch In-Situ Recovery (ISR) Project in Campbell County, WY; Supplement to the 

Generic Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities.” Federal 

Register, Vol. 74, No. 237, pp. 65806-65810. December 11, 2009. 

75 FR 6065, NRC. “Extension of Public Comment Period on the Draft Environmental Impact 

Statement for the Moore Ranch In-Situ Recovery Project in Campbell County, WY; Supplement 

to the Generic Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities.” 

Federal Register, Vol. 75, No. 24, pp. 6065-6066. February 5, 2010. 

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

NRC, 2003a. NUREG–1748, “Environmental Review Guidance for Licensing Actions 

Associated with NMSS Programs.” Washington, DC: NRC. August. 

NRC, 2003b. NUREG–1569, “Standard Review Plan for In-Situ Leach Uranium Extraction 

License Applications. Final Report.” Washington, DC: NRC. June. 

NRC, 1997. NUREG–1508, Final Environmental Impact Statement to Construct and Operate 

the Crownpoint Uranium Solution Mining Project, Crownpoint, New Mexico.” Washington, DC: 

NRC. 

NRC, 1980. NUREG–0706, “Final Generic Environmental Impact Statement on Uranium 

Milling,” Project M-25. Washington, DC: NRC. 

B5.5 Purpose, Need, and Scope of the SEIS/GEIS 

B5.5.1 Description of the SEIS/GEIS Purpose and Need 

Comments: MR012-001; MR012-003; MR012-004; MR012-005; MR017-025; MR016-001; 

MR016-003; MR016-006 

Three commenters noted that the statement of purpose and need in the GEIS was too limited, 

which resulted in a limited analysis of reasonable alternatives in the Moore Ranch SEIS. One 

commenter stated that because of the construct of the purpose and need in the GEIS, the 

subsequent Moore Ranch SEIS was too narrow and limited the range of reasonable alternatives 

either to granting or denying the applicant licensing request, and thus failed to satisfy the 

fundamental requirements of the NEPA. This commenter stated further that by limiting the 

purpose and need scope, only two alternatives in the Moore Ranch draft SEIS were evaluated 

in detail, which the commenter concluded meant that only one alternative, licensing the project, 

was given serious consideration. The commenter also stated that the alternatives analysis 

violated both the letter and spirit of NEPA and that if the NRC had articulated a reasonable 

and legitimate purpose and need, the range of alternatives considered would likewise have 

been reasonable. 
Appendix B 

B–18 

A second commenter stated that NRC should craft a statement of purpose and need in 

consultation with other involved Federal and State agencies that related the uranium recovery 

program to broad national objectives within NRC purview, such as “improving remediation of 

land and water impacts from the recovery of source or byproduct materials” or “ensuring the 

long-term isolation from the human and natural environment of harmful radionuclides and 

chemical toxins produced in the nuclear fuel cycle.” 

A third commenter stated that because of the construct of the purpose and need statement, the 

applicant had not been required to identify a customer for its product, but rather assumed that 

such a customer would exist to buy the uranium and that this did not satisfy the NEPA “hard 

look requirements.” This commenter also disagreed with the NRC statement in the Moore 

Ranch SEIS that NRC does not have a role in a company business decision to submit a license 

application. The commenter argued that the purpose and need of the project could not be 

determined without NRC evaluating whether or not the project is economically viable at the 

Moore Ranch site for the particular product. 

Response: The statement of the purpose and need is found in Section 1.3 of this final SEIS 

and is derived from the proposed federal action. Under the AEA, NRC’s has statutory authority 

to issue licenses for the possession and use of AEA regulated radioactive materials and 

particular activities involving this material. Based on NRC statutory authority, the proposed 

federal action is NRC’s decision whether to grant or deny a private party’s licensing application 

to conduct ISR operations to extract uranium and produce yellowcake at a particular site. The 

purpose and need for the proposed federal action does consider the applicant goals and 

objectives to extract uranium from a particular location, which helps define reasonable 

alternatives to the proposed federal action. As a result, NRC limits its analysis of alternatives to 

accomplishing the objective of extracting uranium from the applicant site. 

The alternatives to the proposed action are discussed in Sections 2.1 and 2.2 of this final SEIS. 

As discussed there, the No-Action Alternative (i.e., denial of the license application) was 

considered in detail in the draft SEIS analysis, while alternative mining and milling methods 

(conventional and heap leach), alternate sites, alternate lixiviants, and alternate wastewater 

treatment methods were considered in Section 2.2 of the Moore Ranch SEIS, but were not 

analyzed in detail. Alternate sites analysis is limited to the occurrence of the subsurface ore 

body and could consider the placement of the wellfields. Section 2.1.1.2 was added to this final 

SEIS to discuss alternative wastewater disposal options. Section 4.14.1.2 discusses the 

impacts from alternative wastewater disposal options. NRC does not analyze the market 

conditions or business decision of a private entity to submit a license request as part of its 

licensing decision. An NRC licensing decision is based on the safety evaluation review and 

environmental review of the license application. 

NRC does recognize that NRC performs an analysis of alternative energy production methods 

and alternative sites in its environmental reviews of nuclear power plant licensing actions. In 

that case, the proposed action involves the decision of whether to grant or deny the license of 

an energy production facility, and the facility could perform this function at other locations. Even 

in these environmental reviews, NRC notes that the decision regarding energy policy and 

energy planning, including whether to implement energy options like solar power, conservation, 

or even nuclear power, are also made by the utility and State and Federal (non-NRC) 

decisionmakers, and NRC does not have authority to make these decisions. If NRC decides to 

renew or grant an operating license to a nuclear power plant the decision of whether to operate 
Appendix B 

B–19 

the nuclear power plant, or an alternative is left up to the appropriate State, utility, and 

Federal entities. 

In comparison, an ISR facility does not generate energy and is a fixed site based on the location 

of the ore body. As a result, alternative energy production methods and alternative site 

locations are not related to the proposed federal action to decide whether to grant or deny an 

applicant license request to extract uranium from a particular site. NRC has not included an 

analysis of alternate geographic locations, alternative energy production methods, or market 

conditions in this final SEIS. 

Sections 2.1.1.2 and 4.14.1.2 were added to the final SEIS to discuss alternative waste disposal 

options in response to these comments. 

B5.5.2 Use of the GEIS in Site-Specific Environmental Reviews 

Comments: MR005-004, MR012-036

Commenters expressed concerns about how information from the GEIS was incorporated into 

the Moore Ranch draft SEIS. One commenter stated that a regional description of the affected 

environment could not substitute for a meaningful description and analysis of the impacts on the 

environment from the proposed Moore Ranch ISR Project. Another commenter stated that 

because the Moore Ranch SEIS was one of three tiered from the GEIS, that analysis of the 

relationship between the three SEISs and the GEIS was warranted and expressed concern 

about how information was incorporated from the GEIS. 

Response: The relationship of the Moore Ranch SEIS to the GEIS is discussed in Sections 1.1 

and 1.4, and as noted, the SEIS is a supplement to the GEIS, wherein the GEIS provided a 

starting point for NRC NEPA analyses for site-specific license applications for new ISR facilities 

and for applications to amend or renew existing ISR licenses. The Moore Ranch SEIS tiers and 

incorporates by reference from the GEIS relevant information, findings, and conclusions 

concerning potential environmental impacts. The structure of Chapter 3 of the SEIS was first to 

describe each resource area (e.g., land use, geology and soils, water resources) at a regional 

level and then to provide local and site-specific characteristics. The extent to which NRC 

incorporated GEIS impact conclusions depended on the consistency among the applicant’s 

proposed facility and activities and conditions at the proposed Moore Ranch site and the 

reference facility description, activities, regional conditions, and information or conclusions in the 

GEIS. NRC determinations regarding potential environmental impacts and the extent to which 

GEIS impact conclusions were incorporated by reference are discussed in Chapter 4 of 

this SEIS. 

Sections 1.7.1 and 1.8 of the GEIS provided a general discussion of the NRC process for 

reviewing license applications for proposed new ISR uranium recovery projects. An NRC 

site specific environmental review is conducted for each license application. As discussed in 

GEIS Section 1.8, each site-specific environmental review will evaluate information provided on 

all resource areas to ensure sufficient information to assess environmental impacts has been 

provided in a license applicant environmental report. The applicant environmental report 

includes a detailed description and assessment of the proposed action, alternatives, site 

characterization information, and potential environmental impacts. If sufficient information were 

not provided, NRC would request additional information (RAI) to ensure the information is 

complete. The GEIS does not relieve the applicant of the need to adequately document 

site-specific information in its application. 
Appendix B 

B–20 

The NRC staff initially rely on applicant information provided by the applicant as well as 

information and conclusions from a separate detailed safety review conducted by NRC staff in 

documenting the staff environmental review. NRC staff confirm important attributes of the 

license application and environmental report through visits to the proposed site location and 

vicinity, independent research activities, and consultations with appropriate Federal, tribal, 

State, and/or local agencies. If, after reviewing the detailed information on the site-specific 

proposal provided by the applicant, the NRC staff find commonality between site conditions and 

those evaluated in the GEIS, the staff may incorporate by reference into the documentation of 

the site-specific environmental review the applicable portions or conclusions from the GEIS. 

Whether or not the staff use information from the GEIS in completing their site-specific 

environmental review, the conclusions in the site-specific environmental review documentation 

would be required to have sufficient technical basis. 

Section 1.8.3 of the GEIS describes the process by which the NRC staff use the GEIS to help 

determine the significance of site-specific environmental impacts in the Moore Ranch SEIS (see 

Chapter 4). As discussed in the GEIS, the GEIS provides criteria for each environmental 

resource area to help determine the significance level of potential impacts (e.g., SMALL, 

MODERATE, or LARGE). The NRC staff applied these criteria to site-specific conditions at the 

Moore Ranch Project to determine the significance of potential impacts. Finally, the NRC staff 

compared the conditions of the proposed Moore Ranch site and activities under review to the 

conditions and aspects identified and discussed in the GEIS to see whether the environmental 

impact conclusions for a particular resource area could be adopted in the Moore Ranch SEIS. 

The NRC staff compared whether the GEIS impact significance conclusions for a specific 

resource area could be adopted in full, only in part, or not at all. Chapter 4 of the SEIS 

discusses the extent to which the GEIS conclusions could be adopted, including the supporting 

information and data that form the basis for that determination. Additionally, where the GEIS 

conclusions could be adopted only in part or not at all, the NRC staff also determined the 

significance of environmental impacts for those resource areas and provided the basis for that 

determination. For each resource area in Chapter 4 of the Moore Ranch SEIS, the NRC staff 

provided a conclusory statement (i.e., the one identified by the commenter), which followed the 

site-specific information and analysis to indicate the extent to which new and significant 

information affected the ability to adopt impact conclusions from the GEIS. No changes were 

made to the SEIS beyond the content of this response. 

B5.5.3 Scope of the SEIS/GEIS 

Comments: MR001-005; MR012-002; MR012-055

Several commenters expressed concern over the scope of the SEIS and relatedly, the GEIS. 

One commenter stated that certain aspects of the GEIS, including its scope, appeared to be 

binding upon the SEIS. The commenter further noted that, by improperly limiting the scope of 

the SEIS, the NRC failed to analyze a number of impact areas. Another commenter stated that 

additional comments on the GEIS were appropriate,given that the GEIS did not apply to any 

federal plan or project and did not represent any final NRC regulatory or policy decision, which, 

therefore, made it impossible for any member of the public to meaningfully comment on the 

GEIS in a concrete context. The same commenter noted that despite many public comments 

on the GEIS urging NRC to consider the impacts of previous uranium mining and milling, the 

NRC deemed that contamination from past uranium mining and milling to be outside the GEIS 

scope. One commenter requested that the public have an opportunity to review NRC proposed 

rulemaking on groundwater protection at ISL facilities and urged NRC to extend the draft SEIS 
Appendix B 

B–21 

comment period to allow NRC to promptly release its associated draft groundwater protection 

rule so it could be reviewed concurrently with the draft SEISs. 

Response: The scope of this SEIS is discussed in Section 1.4. As discussed there, the NRC 

staff consider the scope of the GEIS to be sufficient for the purposes of defining the scope of 

this SEIS. In so stating, the NRC considers that topics determined to be within scope for the 

GEIS were also within scope for the SEISs. NRC made this determination based on its review 

of the information provided by the applicant and as a result of meetings with Federal, State, and 

local agencies and contact with potentially interested Native American tribes and local 

authorities, entities, and public interest groups in person and via e-mail and telephone (see 

Section 1.4.2 of this SEIS). 

Concerning public involvement in the GEIS, NRC accepted public comments on the scope of 

the GEIS from July 24 to November 30, 2007, and held three public scoping meetings to aid in 

this effort. Additionally, NRC held eight public meetings to receive comments on the draft GEIS, 

published in July 2008. Comments on the draft GEIS were accepted between July 28 and 

November 8, 2008. Comments received during scoping and on the draft GEIS are available 

through NRC ADAMS database on the NRC website (http://www.nrc.gov/readingrm/adams.html). Transcripts of the scoping meeting and draft GEIS comment meetings are 

available at http://www.nrc.gov/materials/ uranium-recovery/geis/pub-involve-process.html. A 

scoping summary report is provided as Appendix A to the GEIS (NRC, 2009a). As is evident in 

the public meeting transcripts and the written comments received during the scoping and public 

comment period for the GEIS, the NRC staff consider that meaningful and extensive public 

comments were received on the GEIS. 

With respect to the specific comment that contamination from past conventional mining and 

milling was outside the scope of the GEIS, the NRC noted in Appendix A to the GEIS that such 

contamination could be assessed as part of a site-specific cumulative impacts evaluation. 

Chapter 5 of this final SEIS provides the NRC site-specific cumulative effects analysis. In 

Table 5-1, past uranium recovery operations, including conventional mills within the Wyoming 

East Uranium Milling Region (where the proposed site is located) are identified. The cumulative 

impacts evaluation in Chapter 5 of this final SEIS has been revised to clarify and improve the 

transparency of the analysis. 

Regarding the comment concerning the proposed rulemaking on groundwater protection, this 

SEIS is based on the regulations in effect at the time of writing. This has been clarified in 

Section 1.5 of this final SEIS. 

B5.5.4 Reference 

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

B5.6 Scoping Process and Scoping Report 

Comments: MR009-044; MR012-057; MR012-059; MR012-60

A commenter stated that NRC did not conduct any public meetings regarding the scope of the 

Moore Ranch SEIS in contrast to what was done for the GEIS. The commenter stated that 

instead of public scoping meetings, the NRC met with government agencies and groups it 
Appendix B 

B–22 

considered “interested” in the SEIS to determine scope. The commenter stated that the NRC 

failure to conduct public scoping prevented the public from raising issues, including the 

cumulative impact of past uranium mining and milling that the commenter stated should have 

been considered in the Moore Ranch SEIS. Another commenter stated that the NRC failure to 

conduct public scoping meetings on the Moore Ranch SEIS was a violation of NEPA. Another 

commenter stated that NRC should describe in more details its “targeted scoping” and 

emphasize that, while not mandatory under Part 51, it was conducted to provide interested 

stakeholders with an opportunity to provide public comments. 

Response: NRC conducted a public scoping process for the ISR GEIS, from which the Moore 

Ranch ISR SEIS is tiered. The scoping process included three public scoping meetings, one of 

which was in Casper, Wyoming. NRC considered public comments, along with information on 

ISR technology and regional information to identify the scope of the GEIS for ISR facilities. The 

process included identifying significant issues to be studied in depth in the GEIS to help 

evaluate potential environmental impacts to various resource areas and identify other regulatory 

and consultation requirements for ISR facilities. 

NRC considers the ISR GEIS to be a final environmental impact statement (EIS) and that the 

environmental reviews for a specific license application to be a supplement to the ISR GEIS. 

According to NRC regulation 10 CFR 51.92(d), the NRC staff is required to prepare a 

supplement to a final EIS in the “same manner as the final EIS except that a scoping process 

need not be used.” Furthermore, even if a scoping process is conducted, NRC regulations do 

not require the scoping process to include public scoping meetings (see 10 CFR 51.26(b). 

The NRC staff interacted with multiple Federal, tribal, State, and local agencies and/or entities 

during the preparation of the Moore Ranch SEIS for consultation purposes and to gather 

information on potential issues, concerns, and environmental impacts related to the proposed 

ISR facility at the Moore Ranch site, as described in Section 1.7.3. The NRC staff used 

information from these interactions and other site-specific information to evaluate whether 

issues identified during the scoping process for the GEIS were adequate for the Moore Ranch 

environmental review and whether specific GEIS conclusions or findings were applicable to the 

Moore Ranch Project. NRC used this information to prepare a draft supplemental EIS which 

was issued for public comment. 

Comments received on the draft SEIS were considered in the development of this final SEIS. In 

particular, the cumulative impact analysis in Chapter 5 of the Moore Ranch SEIS has been 

revised in response to public comments received on the draft SEIS and considers past uranium 

mining and milling. 

B5.6.1 References 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 
Appendix B 

B–23 

B5.7 SEIS/GEIS Methods and Approach 

B5.7.1 Consider Compliance History in Assessing Impacts 

Comment: MR012-039 

One commenter stated that the NRC conclusion regarding groundwater impacts disregarded the 

operational history of other ISR operations that have used the same or similar leak detection 

and well integrity programs as proposed for the Moore Ranch Project. The commenter provided 

the example of the Smith Ranch Project as support for their concern. 

Response: The NRC conclusions regarding the potential environmental impacts to 

groundwater for the Moore Ranch Project are provided in Section 4.5.2.1. These impact 

conclusions are based on facility-specific process descriptions for the Moore Ranch Project and 

site-specific characteristics at the proposed site. In determining impact conclusions, the NRC 

staff reviewed information provided by the applicant in its license application as amended 

(including the technical and environmental reports), information and data independently 

collected by the staff, and information and data provided in the GEIS. Section 2.11 of the GEIS 

presents a historical discussion of ISL operations (including the Smith Ranch Project) and 

Section 2.14 provides reference to specific facilities in Wyoming, Nebraska, and New Mexico. 

The intent of the information in these sections of the GEIS was to inform the reader regarding 

which issues have historically resulted in potential impacts at ISL facilities and to provide a 

range of conditions that may be expected for each of the four ISL phases of ISL. No changes 

were made to the Moore Ranch SEIS beyond the information provided in this response. 

Comment: MR012-050 

One commenter stated that the NRC conclusion that impacts to groundwater from groundwater 

restoration would be small was arbitrary and unreasonable. Additionally, the commenter 

requested that NRC fully disclose ISR industry groundwater restoration history and then 

reconsider impacts to groundwater, regionally and locally, based on that history. 

Response: NRC conclusions regarding the potential environmental impacts to groundwater 

from groundwater restoration for the Moore Ranch Project are provided in Section 4.5.2.1.3. As 

discussed there, NRC analyzed impacts that could result from drawdown, leaks and spills from 

buried piping, and disposal of waste fluids via deep well injection, and determined that such 

potential impacts would be SMALL. These impact conclusions are based on facility-specific 

process descriptions for the Moore Ranch Project and site-specific characteristics at the 

proposed site. In determining these impact conclusions, the NRC staff reviewed applicant 

license application information as amended (including the technical and environmental reports), 

information and data independently collected by the staff, and considered information and data 

from the GEIS. 

NRC published a summary of groundwater impacts from ISR operations at operating facilities 

that is available through the NRC ADAMS using the Accession Number ML091770402. 

ADAMS is available on the internet at http://www.nrc.gov/reading-rm/adams.html. Since this 

information is already publicly available and the NRC analysis of potential impacts to 

groundwater is based on site-specific information, the SEIS was not revised in response to 

this comment. 
Appendix B 

B–24 

B5.7.2 General Comments on SEIS/GEIS Structure, Methods, 

and Approaches 

Comment: MR012-048 

A commenter stated that the GEIS’s brief discussion of ISL restoration history implies that while 

restoration may be difficult, there have been some successful restoration projects. The 

commenter stated the GEIS’s discussion is conclusory and misleading. 

Response: The draft GEIS was published with a NOA on July 28, 2008 (73 FR 43795). NRC 

held a 103-day public comment period for the draft GEIS from July 28, 2008, through 

November 7, 2008. During this comment period, members of the public were invited and 

encouraged to submit related comments online, via e-mail, via regular mail, or orally at one of 

eight public meetings held on the draft GEIS. The NRC considered and responded to comments 

received on the GEIS and included these responses in Appendix G of the final GEIS, the NOA, 

of which was published on June 5, 2009 (74 FR 27052). 

The comments referenced previously were submitted during the public comment period for the 

draft SEIS for the Moore Ranch ISR Project. Because the comment referenced previous 

comments solely on the GEIS and does not directly comment on the draft SEIS or provide any 

site-specific information related to the Moore Ranch ISR Project, it will not be considered 

further. No changes were made to the SEIS as a result of this comment. 

B5.7.3 References 

73 FR 43795, NRC (U.S. Nuclear Regulatory Commission). “Notice of Availability of Draft 

Generic Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities.” Vol. 73, 

No. 145, pp. 43795-43798. July 28, 2008. 

74 FR 27052, NRC. “Notice of Availability of Final Generic Environmental Impact Statement for 

In-Situ Leach Uranium Milling Facilities.” Federal Register. Vol. 74, No. 107, pp. 27052-27054. 

June 5, 2009. 

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

B5.8 Public Involvement 

Comments: MR009-045; MR013-015 

Commenters requested that NRC clarify the additional opportunities for public participation 

during preparation of the Moore Ranch draft SEIS including public meetings and 

teleconferences. Another commenter stated that if the SEIS provided a more detailed 

description of the licensing process, to include scoping and public comment meetings on the 

GEIS, completion of the SER, and license applicant meetings with NRC staff that this would 

provide members of the public and interested stakeholders with a better understanding of how 

focused the NRC licensing process is on transparency and public participation and how 

extensive the process is on the issues of protecting public health and safety and the 

environment on a site-specific basis. 
Appendix B 

B–25 

Response: NRC provides multiple avenues for public involvement in its licensing process. In 

the NRC license review process, once an application is received, reviewed for completeness, 

and accepted for detailed review, NRC formally dockets the application and publishes a notice 

in the Federal Register. The Federal Register notice announces the availability of the 

application and provides an opportunity for affected individuals or entities to request a hearing 

under the NRC formal hearing process. The NOA published in the Federal Register includes 

the relevant identifying information for the license application so that an interested member of 

the public can view the application either electronically through the NRC ADAMS [at 

www.nrc.gov/reading-rm/adams.html] or in person by visiting NRC’s public document room. 

In the case of the proposed Moore Ranch Project, there have been eight opportunities for public 

involvement, in addition to opportunities that have been afforded through the NEPA process for 

the site-specific Moore Ranch supplemental EIS. These include a pre-application meeting, and 

five publicly-noticed meetings or teleconferences with the applicant to discuss various technical 

issues or issues associated with the application such as coal bed methane (CBM) operations. 

The publication of the Notice of Intent to prepare the GEIS also provided an opportunity for 

public involvement and subsequent notices that extended the public comment period, and the 

Notice of Opportunity to request a hearing, published in the Federal Register on January 25, 

2008 (73 FR 4642). No requests for a hearing were received. 

As discussed in Section 1.4.1 of the Moore Ranch SEIS, NRC accepted public comments on 

the scope of the GEIS, from which the Moore Ranch SEIS is tiered, from July 24 to 

November 30, 2007, and held three public scoping meetings, one of which was in the State of 

Wyoming. During the public comment period on the draft GEIS, NRC held eight public meetings 

to receive comments on the draft GEIS: three of these meetings occurred in the State of 

Wyoming. The public participation activities associated with the development of the Moore 

Ranch SEIS are discussed in Section 1.4.2 of the SEIS, and discussion of the NRC licensing 

process are described in Section 1.6.1 of the SEIS. No changes were made to the final SEIS 

beyond the information provided in this response.

Comments: MR015-026; MR015-035; MR020-042 

A commenter requested that interested stakeholders be involved in the review of any modeling 

protocol for assessing air quality impacts prior to supplemental work being performed. The 

same commenter asked if there is a public participation process associated with the 

establishment and NRC decision to approve, alternate concentration limits (ACLs). 

Response: NRC provides multiple avenues for public involvement in its licensing process in 

the review of an individual ISR facility. For new ISR license applications, NRC will publish a 

Notice of Intent to prepare a site-specific SEIS and provide details on the scoping process for 

the SEIS, if applicable. NRC will also publish for public comment a draft SEIS and address 

stakeholder comments received in its final SEIS. NRC may also make a draft environmental 

assessment and accompanying draft finding of no significant impact available for 

public comment. 

A licensee must apply for a license amendment for an ACL; a notice is published in the Federal 

Register for all licensing actions made under the Atomic Energy Act, including amendments. 

Under NRC regulations, an opportunity is provided for any person whose interest may be 

affected by an NRC licensing action (see 10 CFR 2.309). Further, NRC performs a safety and 

environmental review (typically an environmental assessment) as part of evaluating the 

adequacy of an ACL. 
Appendix B 

B–26 

B5.8.1 References 

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

B5.9 Regulatory Issues and Process 

B5.9.1 NRC as a Regulatory Authority 

Comments: MR013-010; MR009-003 

Two commenters asked for clarification about the NRC and its statutory mission under the 

AEA and its approach to licensing as an independent regulatory agency. The commenter 

suggested that all references to the NRC statutory mission in the SEISs be revised with the 

following language: 

“NRC must license facilities, including ISR operations, in accordance with the AEA and the 

Commission’s implementing regulations to protect public health and safety from potential 

radiological and non-radiological hazards associated with AEA materials and operations.” 

Response: The NRC was created after Congress passed the Energy Reorganization Act in 

1974. This Act, along with the AEA of 1954, provides the foundation of the NRC regulatory 

authority. As an independent regulatory agency, NRC reports directly to Congress. 

Independent agencies can be distinguished from regular executive agencies by their structural 

and functional characteristics. The NRC has the responsibility in licensing and regulating 

uranium ISR facilities through the statutory requirements of the Uranium Mill Tailings Radiation 

Control Act of 1978 and the AEA, as amended. These statutes require that NRC ensure source 

material, as defined in Section 11(z) of the AEA and byproduct material, as defined in Section 

11e.(2) of the AEA, is managed to conform with applicable regulatory requirements. The text 

within the SEIS is correct. No changes were made to the SEIS beyond the information provided 

in this response. 

B5.9.2 NRC Authority and Jurisdiction 

Comment: MR007-001 

One commenter noted an error in the text, which stated that the Wyoming State Historic 

Preservation Office (SHPO) had declared all sites ineligible for listing on the National Register of 

Historic Places (NRHP). The commenter further stated that Wyoming SHPO does not 

necessarily determine the eligibility of sites. The determination of site eligibility is made by the 

lead agency, which in the case of the Moore Ranch Project is the NRC. 

Response: NRC acknowledges this comment and agrees that the Wyoming SHPO does not 

determine the NRHP eligibility of historic properties. The responsibility of the SHPO is to concur 

or not concur with the status of resource eligibility determined by the federal agency assessing 

the resources (36 CFR 800.4(c)(2)). As such, the text in Section 3.9 Historical and Cultural 

Resources, Section 4.9, and Section 1.7.2 National Historic Preservation Act of 1966 (NHPA) 

Consultation was revised in response to this comment. 
Appendix B 

B–27 

B5.9.3 NRC Policies and Practices 

Comment: MR008-003 

A commenter noted that the NRC staff were not listed as reviewers and asked if the NRC staff 

were involved with the development of the SEISs. 

Response: Chapter 9 of the final SEIS lists all of the contributors to the SEIS. No change was 

made to the SEIS. 

Comments: MR009-194; MR009-199 

A commenter stated that the NRC should not rely on the Wyoming Game and Fish Department 

(WGFD) document, “Recommendations for Development of Oil and Gas Resource within 

Crucial and Important Wildlife Habitats” because this draft document provided recommendations 

specific to impacts to wildlife from the oil and gas industry and the impacts from the oil and gas 

industry bear no relation to those posed by ISR uranium mining. The commenter further 

questioned why NRC referenced BLM’s proposed Resource Management Plan since the report 

had not been finalized and was prepared for the Rawlins Field Office. 

Response: The NRC acknowledges that the WGFD’s “Recommendations for Development of 

Oil and Gas Resources within Important Habitats” (WGFD, 2010) are recommendations, not 

regulations, and NRC does not have the statutory authority to require the Moore Ranch ISR 

Project to abide by these recommendations. This final SEIS references these 

recommendations because they provide a useful basis for assessing impacts and determining 

reasonable mitigation strategies for wildlife species. Concerning the applicability of the WGFD 

recommendations to the ISR uranium milling process, the WGFD recommendations for 

seasonal wildlife stipulations guidelines are reasonable to use for analysis of impacts because 

the stipulations mainly serve the function of identifying times of the year that particular species 

are more sensitive to human disturbance. Though specific types of disturbance and magnitude 

of disturbance varies between oil and gas development and ISR uranium milling, the WGFD 

guidelines that provide seasonal distance buffers for noise, vehicular traffic, and human 

proximity provide a valuable gauge for determining impacts on wildlife from the proposed Moore 

Ranch ISR Project. Additionally, the most recent version of the WGFD recommendations 

published in April 2010, specifically directs in-situ uranium development to follow stipulations 

specified for oil and gas development for the greater sage-grouse (Centrocercus urophasianus) 

that were reviewed, even though the proposed Moore Ranch Project is not located in a greater 

sage-grouse core area. 

Comments: MR009-282; MR013-018 

A commenter stated that NRC needed to clarify its approach to wellfield package review and 

approval; the commenter stated that the new policies are inconsistent with performance-based 

licensing and the manner in which ISR operations were licensed in the past. The commenter 

noted that NRC has stated that new licenses would be required to submit some initial wellfield 

Hydrologic Data Packages until the staff developed a level of comfort with the applicant. 

Another commenter stated their opinion that it appeared from the language in the SEIS that 

NRC would be reviewing and approving all wellfield packages rather than just initial wellfield 

packages. The commenter went on to note that, in their opinion if NRC reviewed and approved 

all wellfield packages, that would be contrary to and detrimental to the Commission’s policy 

supporting performance based licensing, and that NRC staff should continue to allow Safety and 

Environmental Review Panels to review and approve wellfield packages under traditional 

performance-based licensing as has been done in the past. 
Appendix B 

B–28 

Response: The NRC agrees with the need to clarify its position on review and approval of 

wellfield hydrologic data packages. Historically, the NRC reviewed and approved all wellfield 

packages. During the mid-1990s, the Commission adopted a performance-based approach to 

licensing. A performance-based regulatory approach is one that establishes performance and 

results as the primary basis for regulatory decisionmaking, and this approach incorporates the 

following attributes: (1) measurable (or calculable) parameters (i.e., direct measurement of the 

physical parameter of interest or of related parameters that can be used to calculate the 

parameter of interest) exist to monitor system, including both facility and applicant performance, 

(2) objective criteria to assess performance are established based on risk insights, deterministic 

analyses, performance history, or both, (3) applicants flexibility in determining how to meet the 

established performance criteria in ways that would encourage and reward improved outcomes; 

and (4) a framework in which the failure to meet a performance criterion, while undesirable, will 

not in and of itself constitute or result in an immediate safety concern. 

Current Commission policy allows applicant Safety and Environmental Review Panels (SERP) 

to review and approve wellfield packages under performance-based license conditions. 

However, in some wellfields there are particular geologic features (e.g. faults, thin/missing 

aquitards) or groundwater flow behavior (e.g., unconfined aquifer, leakage across aquitards) 

that require local field data and testing to be characterized to determine if ISR operations can 

meet regulatory requirements, the staff may review and approve wellfield packages. Therefore, 

based on the outcome of the safety review of the technical report, NRC may request by license 

condition to review and approve the Wellfield Hydrologic Data Package for an individual wellfield 

if NRC determines that a safety review cannot be adequately completed without the information 

provided in the package. The discussion in Section 6.3.1.2 of the final Moore Ranch SEIS was 

revised to clarify this issue. 

B5.9.4 Adequacy of NRC Regulations and Practices 

Comments: MR009-005; MR009-048; MR009-049; MR013-012; MR013-013 

Commenters noted that there are many applicable regulatory provisions other than 

10 CFR Part 51 (10 CFR Parts 20 and 40) and that the NRC should mention other applicable 

guidance and regulatory guides used for completing environmental reviews. Another 

commenter noted that the NRC discussion of regulatory programs applicable to ISR operations 

outside the context of the AEA should be expanded to demonstrate how highly regulated the 

ISR industry is in the United States. The same commenter further noted that the NRC should 

specify all of the regulatory programs that apply to ISR operations and not limit the discussion in 

the final SEIS to only 10 CFR Part 51 regulations. Another commenter noted that the SEIS 

states that ISR operatons are subject to the AEA and NEPA with no mention of other statutory 

programs such as the Safe Drinking Water Act (SDWA), NHPA, and the Endangered Species 

Act as implemented in accordance with various state programs. Commenters stated that the 

final SEIS should make clear how extensive the regulatory oversight is for ISR operations. 

Commenters noted that multiple agencies oversee ISR operations, often resulting in two or even 

three layers of financial assurance for each ISR project; a commenter stated this more than 

assures that adequate site-specific decommissioning and decontamination would be performed. 

Response: NRC has to comply with all applicable Federal environmental laws, regulations, and 

Executive Orders, including its own regulations (in Title 10 of the CFR) and those promulgated 

by other Federal agencies, so long as compliance would not be inconsistent with other statutory 

requirements. Section 1.6 of the GEIS identifies agencies involved in a uranium ISR facility, 

and Section 1.7 discusses the licensing permitting process for an ISR facility. Section 1.6 of the 
Appendix B 

B–29 

Moore Ranch SEIS discusses the status of licensing and permitting and associated 

consultations that pertain to the ISR licensing review at the proposed Moore Ranch Project. 

The SEIS was prepared in accordance with NEPA requirements and NRC implementing 

regulations at 10 CFR Part 51. 

Furthermore, Appendix B of the GEIS summarizes other Federal statutes, implementing 

regulations, and Executive Orders potentially applicable to the Moore Ranch licensing review. 

The description of regulatory programs applicable to ISR operations is provided by the agencies 

responsible for implementing those programs, and readers should consult the responsible 

agencies for clarification of their regulations and programs. ISR applicants are ultimately 

responsible for understanding and complying with all Federal, State, and local permits and 

regulations, whether described in the GEIS or not. No changes were made to the SEIS beyond 

the information provided in this response. 

Comments: MR012-027; MR012-053 

A commenter stated that the NRC analysis of groundwater restoration and excursions shows 

that the NRC has no coherent framework for regulating ISL operations. They also noted that 

the NRC staff recognizes that “class of use” is an inappropriate restoration goal and referred to 

the NRC Regulatory Issue Summary issued in 2009, which concluded that Criterion 5B did not 

provide for restoration to “class of use” standards (RIS 2009-05). The commenter noted that 

since “class of use” is a restoration standard that is not legally cognizable, it should not be the 

basis for analysis of groundwater impacts. 

Response: The NRC has announced its intent to issue a proposed rulemaking specific to 

groundwater protection at ISR facilities; but to date, this rulemaking has not yet been published 

in the Federal Register. NRC regulations require that the groundwater quality be returned to the 

standards identified in Criterion 5B(5) of Appendix A to 10 CFR Part 40. Those standards are 

background, the values in the table in Criterion 5C of Appendix A to 10 CFR Part 40, or an ACL 

established by the NRC in accordance with Criterion 5B(6) of Appendix A to 10 CFR Part 40. 

Criterion 5(B)(5) allows the NRC to approve an ACL for groundwater restoration. A rigorous 

regulatory process is used for a applicant to receive approval for ACLs as discussed in 

Appendix C of this SEIS. The applicant must demonstrate that it has attempted to restore 

hazardous constituents in groundwater to either background concentrations or to the maximum 

contaminant level (MCL)—whichever level is higher. A license amendment application must be 

submitted by the applicant to request to establish ACLs. The regulations and criteria used for 

review of ACL applications is found in 10 CFR Part 40, Appendix A, Criterion 5B(6). 

Within the State of Wyoming, the Wyoming "class of use" standard comes within the 

10 CFR Part 40, Appendix A, Criterion 5B(6)(a)(v-vi) and (b)(vi-vii) factors, and thus may be 

considered as one factor in evaluating ACL requests for ISR facilities located within the state. 

In considering ACL requests, particular importance is placed on protecting underground sources 

of drinking water (USDW). The use of modeling and additional groundwater monitoring may be 

necessary to show that ACLs in ISR wellfields would not adversely impact USDW. 

Before an ISR applicant is allowed to extract uranium, the EPA under 40 CFR Part 146.4 and in 

accordance with the SDWA must issue an aquifer exemption covering the portion of the aquifer 

in which the ore zone is located. The EPA cannot exempt the portion of the aquifer unless it is 

found that “it does not currently serve as a source of drinking water” and “cannot now and would 

not in the future serve as a source of drinking water.” Because of these criteria, only impacts 
Appendix B 

B–30 

outside of the exempted aquifer are evaluated. In most cases, the water in aquifers adjacent to 

the uranium ore zones does not meet drinking water standards. The NRC would not approve an 

ACL if it would impact adjacent USDW. 

Further guidance for the review of ACLs for ISR facilities is being developed in a revision of 

NUREG–1569, Standard Review Plan for the In-Situ Leach [Recovery] Uranium Extraction 

License Applications. Existing guidance for the review of ACLs is contained in NUREG–1620, 

Standard Review Plan for the Review of a Reclamation Plan for Mill Tailings Sites Under Title II 

of the Uranium Mill Tailings Radiation Control Act of 1978, Section 4.3. 

No changes were made to the SEIS in response to these comments beyond the information 

provided in this response. 

Comment: MR017-026 

A commenter stated that for the NRC to craft an appropriate “Purpose and Need for Agency 

Action,” the agency must work with its Federal colleagues at EPA, the U.S. Department of 

Energy (DOE), and the U.S. Department of the Interior to develop a regulatory framework for 

uranium recovery cleanup and licensing that protects public health and the environment. The 

commenter asserted that the NRC refuses to issue a draft groundwater protection rule for nearly 

five years, and that it is past time for NRC to develop a coherent set of protective environmental 

requirements for ISR uranium mining; the commenter also stated that developing a draft 

groundwater rule would be a start. 

Response: The NRC has announced its intent to issue a proposed rulemaking specific to 

groundwater protection at ISR facilities; but to date, this rulemaking has not yet been published 

in the Federal Register. COMJSM–06–001 (2006) directed the staff to focus on eliminating dual 

regulation of groundwater by NRC and EPA. The Commission stated that the NRC should 

retain its jurisdiction over the wellfield and groundwater under its AEA authority, but should defer 

active regulation of groundwater protection programs to either EPA or to the EPA-authorized 

state through the EPA Underground Injection Control (UIC) program. The analysis in the Moore 

Ranch SEIS is based on existing regulations at the time the final SEIS is published. The status 

of ongoing rulemaking activities is provided on the NRC public website at www.nrc.gov. 

Because no proposed rule is available to discuss, no changes were made to the Moore Ranch 

SEIS beyond the information provided in this response. 

B5.9.5 Applicable Rulemaking Efforts 

Comments: MR012-054; MR001-007, MR012-030 

A commenter stated that NRC has an ad hoc approach to ISL regulation. A commenter 

asserted that the “class of use” restoration standard used in both the GEIS and the Moore 

Ranch SEIS indicated a fundamental problem with the NRC regulatory framework and was 

concerned that the GEIS would become the proxy for ISL regulations. The commenter stated 

that NRC does not have regulations specifically relevant to ISL operations but rather has 

adapted some of the conventional milling regulations to apply to ISL operations and “filled in the 

remaining gaps with license conditions,” the standard review plan for ISL facilities, and the 

GEIS. Another commenter stated that because the public did not have a sense of the timing, 

scope, and coverage of the proposed groundwater rule and any associated NEPA process, the 

initial close of the public comment period on the Moore Ranch draft SEIS in February 2010 was 
Appendix B 

B–31 

unreasonable. One commenter also stated that the SEIS and GEIS should be withdrawn and 

reissued after regulations are complete. 

Response: NRC is currently working on a proposed rulemaking specific to groundwater 

protection at ISR facilities. The analysis in the Moore Ranch SEIS is based upon the current 

regulations in 10 CFR Part 40. Until and if the above proposed rulemaking is made final, license 

applications will continue to be reviewed and licensed in accordance with current regulations. 

As background, COMJSM–06–001 (2006 directed the staff to focus on eliminating dual 

regulation of groundwater by NRC and EPA. The Commission stated that the NRC should 

retain its jurisdiction over the wellfield and groundwater under its AEA authority, but should defer 

active regulation of groundwater protection programs to either EPA or to the EPA-authorized 

state through the EPA UIC program. The status of ongoing rulemaking activities is provided on 

the NRC public website at www.nrc.gov.

B5.9.6 NRC NEPA Process Implementation 

Comment: MR017-002

A commenter noted that without vigorous compliance with NEPA requirements and adherence 

to strict environmental protections that the environmental history of uranium mining could 

be repeated. 

Response: NRC understands and recognizes there are serious legacy issues resulting from 

the decades of uranium mining activities from the 1940s through the 1970s when waste from 

uranium mines was not cleaned up after mines were shut down. NRC regulation of ISR facilities 

includes ensuring the necessary measures are taken by ISR operators to confine mobilized 

uranium and other constituents within the wellfield where the facility is operating, ensuring 

monitoring programs are in place to provide early detection of any migration of process fluids 

away from the wellfield, and enforcing necessary corrective actions to prevent uranium from 

contaminating adjacent water sources to ensure the public is protected. 

The Moore Ranch SEIS was prepared consistent with NRC regulations at 10 CFR Part 51 that 

implement NEPA and in accordance with NRC guidance in NUREG–1748 (NRC, 2003). 

Because the comment was general in nature, no changes were made to the Moore Ranch SEIS 

beyond the information provided in this response. 

B5.9.7 NRC Licensing Process 

Comments: MR009-006; MR013-009 

Two commenters requested that a more complete description of the NRC licensing process be 

provided for those not familiar with that process. They stated that the process included NRC 

safety and environmental reviews of the entire license application (including the technical and 

environmental reports), NRC RAIs, and a public participation process. One of the 

commenters stated that the SEIS should clarify the link between the NRC’s environmental and 

safety reviews. 

Response: SEIS Sections 1.6 and 1.6.1 discuss in general the NRC licensing process for the 

Moore Ranch Project. These sections refer to Section 1.7.1 of the GEIS for a more complete 

discussion of the NRC licensing process. Further, as stated in SEIS Section 1.6.1, NRC 
Appendix B 

B–32 

detailed technical review of the Moore Ranch license application is comprised of two parallel 

reviews: a safety review and an environmental review. The safety review focuses on assessing 

compliance with the applicable requirements of 10 CFR Parts 20 and 40 and Appendix A to 

Part 40, while the environmental review is conducted in accordance with the regulations in 

10 CFR Part 51. The results of these two detailed reviews support NRC licensing decision. 

Figure 1.7-1 of the GEIS provides a general flow diagram for the NRC licensing process, 

including safety and environmental reviews. 

It is common during the detailed technical review of a license application for NRC to request 

additional applicant information to ensure the application is complete. In some cases, multiple 

rounds of RAIs are possible. For applications that are not complete, this iterative process is 

designed to provide the applicant the necessary feedback to supplement the application so it is 

complete. The public participation process for this SEIS is discussed in Section 1.4.2 of the 

Moore Ranch SEIS. 

As indicated by the commenters, there is some overlap between safety and environmental 

reviews. This is most clearly seen in topics such as groundwater resources and protection and 

radiological dose to workers and members of the public. The NRC staff conducting the 

environmental and safety reviews collaborate, as necessary, during the conduct of these 

parallel reviews. 

Throughout the SEIS, NRC has used the term “license application” to be inclusive of all aspects 

of the application, including the applicant’s technical report, environmental report, and 

responses to NRC RAIs. The reference sections following SEIS Chapters 2, 3, 4, 5, and 6 are 

reflective of the reliance on all aspects of the application as described previously. 

No further changes were made to the SEIS beyond the information provided in this response. 

Comment: MR009-050 

One commenter requested that language should be added to SEIS Section 1.6.1 to mention 

that NRC issued RAIs and that the applicant responded. 

Response: The focus of SEIS Section 1.6.1 is to provide only the initial acceptance of the 

Moore Ranch license application and to discuss the NRC licensing process in general. NRC did 

make use of the applicant responses to RAIs in its description of the proposed action 

(Chapter 2), in the description of the affected environment (Chapter 3), and in the analysis of 

potential environmental impacts (Chapter 4). No further changes were made to the SEIS 

beyond the information provided in this response. 

Comment: MR009-061 

One commenter requested that in Section 2.1 (Alternatives Considered for Detailed Analysis), 

NRC should include mention of the applicant’s technical report and of consultations with the 

NRC staff conducting the safety review. 

Response: The resources mentioned by the commenter were not primary sources used by 

NRC in determining the range of reasonable alternatives to be considered for detailed analysis 

in the SEIS. Therefore, they were not identified in Section 2.1. No further changes to the SEIS 

were made beyond the information in this response. 
Appendix B 

B–33 

B5.9.8 Consideration of ISL Facility Safety Record and Compliance History 

Comments: MR010-002; MR011-002; MR017-001; MR012-040 

Two commenters stated that there are several ISL uranium sites in Wyoming, and that all of 

these facilities have a history of leaks, spills and excursions. Another commenter wanted to 

remind the NRC of the dreadful uranium mining environmental history which is likely to repeat 

itself without meaningful oversight, vigorous compliance with the requirements of NEPA, and 

adherence to strict environmental protections. The commenter further added that NRC is 

seemingly on a path that will doom us to repeat this chapter of American history. Another 

commenter stated that there was a fundamental contradiction between actual operational data 

and NRC conclusions regarding the magnitude of impacts in both the GEIS and the Moore 

Ranch SEIS were contrary to NEPA. 

Response: Section 2.11.2 of the GEIS discusses leaks, spills, and excursions that have 

occurred at existing ISR facilities. Excursions and mechanical integrity failures have been 

reported for past and current ISR facilities, but in most cases they have been controlled and did 

not pose a threat to human health or the environment. Three ISRs are currently operating: two 

in Wyoming [Uranium One Irigaray and Christensen Ranch facility (formally owned by Cogema 

Mining, Inc.)], and the PRI Smith Ranch—Highland Uranium Project), and one in Nebraska (the 

Cameco Crowe Butte Project). Excursion history and corrective action for all of these sites can 

be found in annual reports and correspondence between the NRC and the applicants in NRC 

public document room. 

All ISR facilities have the potential to have leaks, spills, and excursions, and the purpose of the 

oversight program is to help ensure that leaks, spills, and excursions are minimized. Oversight 

activities, including inspection activities, verify that ISR facility operations, aquifer restoration, 

and decommissioning activities are being conducted according to NRC regulations. NRC 

enforcement programs and policies are effective at verifying if applicants are in compliance 

with NRC regulations, and takes appropriate enforcement action if a licensed facility is not 

in compliance. 

Surface containment of leaks and spills is required for all storage tanks (EPA 2006). In addition, 

spill prevention plans are required of each ISR facility (EPA 1994). For chemicals stored at ISR 

facilities, concrete berms with containment equivalent to at least the volume of the tank are 

required. Spill reporting varies from state to state. NRC requires that a applicant report a spill 

within 24 hours if it meets the criteria in 10 CFR Parts 20 and 40.60. Otherwise, NRC typically 

requires, by license condition, that if a leak or spill meets state reporting requirements, it must 

also be reported to the NRC. Leaks and spills must be characterized and cleaned up to 

regulatory requirements [see 10 CFR Part 40 Appendix A, Criterion 6(6)]. 

The following is a summary of the regulatory requirements that apply to ISR facilities that are 

designed to address leaks, spills, or excursions from these facilities. 

Surface impoundments (including ponds) are designed with a capacity to hold the anticipated 

volume of liquids and are operated and maintained to prevent overtopping from normal 

operations, rainfall, run-on from upstream areas, wind and wave action, and equipment 

malfunctions. Monitoring wells (both up- and down-gradient) are installed, in addition to 

requiring a liner under each surface pond (NRC, 2008). Liner materials require a construct tha 

has sufficient physical properties and strength to withstand the anticipated physical stresses and 

environmental conditions. Liners are typically constructed with leak detection systems that 
Appendix B 

B–34 

allow for leak identification and repair. The leak detection systems are checked for the 

presence of liquids on a regular basis. 

To detect and prevent excursions to the overlying and underlying aquifers, NRC issues a 

license condition that requires operators to perform mechanical integrity testing for all injection 

and production wells (NRC, 2003). This test is conducted every five years to ensure that the 

wells do not develop leaks. To ensure that excursions are identified early, excursion monitoring 

wells are installed. Horizontal excursion monitoring wells are placed in a perimeter ring 

surrounding the wellfield in the production aquifer. In addition, vertical excursion monitoring 

wells are installed in the overlying and underlying aquifers (NRC, 2003). The monitoring wells 

are usually sampled twice a month for excursion indicators. When excursion indicators exceed 

predetermined upper control limits (UCLs), it may signal that production fluids are moving out of 

the wellfield boundary. If an excursion is confirmed, the applicant must begin corrective actions 

to control the excursion and must continue corrective action until the excursion is controlled. 

The location of the excursion monitoring wells, the choice of excursion indicators, and the 

process for determining the UCLs are all reviewed before a license is approved. 

Prior to the recovery of uranium from an aquifer, the EPA must declare the portion of the aquifer 

where production would occur, exempt as a USDW (see 40 CFR 146.4). In addition, if liquid 

byproduct material is to be disposed of via deep well injection, the EPA must also declare the 

deep-well receiving aquifer exempt, as well. The production aquifer exemption area would be 

restored to the standards in 10 CFR Part 40, Appendix A, whereas the injected 

byproduct material fluid would remain in the exempted aquifer. 

The NRC performs an environmental review of an applicant license application to determine the 

environmental effects of operating the proposed ISR facility. The Commission determined it 

would prepare a SEIS for each license application to fulfill its responsibilities under the NEPA 

(see 10 CFR 51.20). NEPA requires that all Federal agencies consider environmental values in 

the conduct of their work. No changes were made to the SEIS beyond the information provided 

in this response. 

B5.9.9 Groundwater Restoration Criteria and Methods 

Comments: MR012-016; MR012-044 

A commenter asserted that the NRC practice of averaging poor groundwater quality with good 

groundwater quality to characterize preextraction groundwater quality misrepresents the 

impacts from groundwater restoration. The commenter stated that NRC tied groundwater 

restoration in the Moore Ranch SEIS to the average of poor groundwater quality in the 

immediate ore zone with good groundwater quality outside the ore zone but within a mine area. 

The commenter stated that Table 3-2 of the draft SEIS gave the impression that the 

groundwater in the aquifer within the proposed mine boundary exceeded EPA and Wyoming 

water quality standards for several constituents but elsewhere in the SEIS, the NRC disclosed 

that there were wells with good quality water. For example, the SEIS disclosed that there were 

either active domestic or stock wells within a 3.2 km [2-mi] radius. The commenter asserted 

that the practice of averaging good groundwater quality with poor groundwater quality is 

incomplete and misleading and skewed the impact analysis to minimize potential groundwater 

impacts from ISL mining in general and at the Moore Ranch site in particular, and that the use of 

this “mathematical artifice” inflated the preextraction contaminant levels within project 

boundaries to create an impression that pre-extraction groundwater quality is poor and 
Appendix B 

B–35 

restoration is possible. Finally, the commenter stated that if groundwater quality within and 

outside of an ore zone were analyzed separately and not averaged, then the adverse impact on 

groundwater outside of the ore zone would be substantially larger. 

Response: The commenter is referring to the need to establish a baseline for groundwater 

quality in the proposed license area before ISR operations begin. As part of the site 

characterization to obtain a license, the applicant is required to determine the average 

preoperational water quality for all aquifers in, above, below, and outside the proposed 

wellfield(s) to generally characterize the water quality of each aquifer across the entire license 

area. However, this general preoperational average is not the same as the average baseline 

water quality of the uranium-bearing aquifer for a specific wellfield. The average baseline water 

quality for a specific wellfield is determined only from water quality measured in wells installed 

within the production ore zone aquifer in each licensed wellfield, and it is this specific average 

that is used to determine groundwater restoration target values in individual wellfields. Contrary 

to the comment, this average baseline water quality does not include wells “outside the 

ore zone.” 

Comments: MR012-051; MR012-052 

A commenter stated that it appears that NRC evaluates groundwater restoration impacts 

assuming that if baseline groundwater quality is not achieved, “class of use” quality would be 

achievable and that this analysis ignores NRC regulations governing ISL groundwater 

restoration that make no mention of “class of use” as a restoration standard, and mandates that 

groundwater must be restored to background or the MCLs listed in Criterion 5D. 

Response: The commenter is correct that NRC has used “class of use,” a state designation 

under the SDWA, as a restoration goal. The “class of use” standard for restored groundwater 

quality was based on restoration standards provided in NUREG–1569. NRC has determined 

that the primary and secondary restoration standards in NUREG–1569 are inconsistent with the 

restoration standards in 10 CFR Part 40, Appendix A, Criterion 5B(5). NRC has notified 

licensees and applicants in Regulatory Information Summary, RIS 09-05, dated April 29, 2009, 

that the restoration standards listed in NUREG-1569, Section 6.1.3(4) are not consistent with 

those listed in 10 CFR Part 40, Appendix A. NRC requires that licensees commit to achieve the 

restoration standards in Criterion 5B(5). A licensee can apply for a license amendment for an 

ACL only after showing that restoration to the background level or MCL is not practically 

achievable for a particular constituent. NRC reviews the ACL request using the criteria 

articulated in 10 CFR 40, Appendix A Criterion 5B(6). The State designation of “class of use” 

for an aquifer can be one of the factors that are considered during NRC review of the ACL 

request. A discussion of the additional Criterion 5B(6) requirements for ACLs is presented in 

Appendix C. 

Comments: MR012-016; MR015-005; MR015-028; MR015-029 

Several commenters were concerned with the potential establishment of ACLs as groundwater 

restoration targets prior to the completion of adequate restoration, and that the draft SEIS did 

not fully assess the operational requirements and constraints associated with restoration 

activities. A commenter noted that although the SEIS acknowledged that the water quality goal 

in the portion of the aquifer where extraction occurs is pre-ISR baseline conditions, the 

discussion concluded by stating that the demonstration of restoration must comply with the 

requirements in 10 CFR Part 40, Appendix A, which allows for restoration target values that do 

not meet the pre-ISR baseline. The commenter noted that although EPA standards in 

40 CFR Part 192 allow NRC to use this practice, ACLs are above baseline or MCL values. 
Appendix B 

B–36 

Response: For any given groundwater constituent, licensees and applicants are subject to the 

three groundwater quality standards listed in 10 CFR Part 40, Appendix A, Criterion 5B(5) – 

background, MCL, or ACL. Specifically, under Criterion 5B(5), the concentration of a hazardous 

constituent must not exceed (a) the NRC-approved background concentration of that constituent 

in groundwater; (b) the respective MCL value in the table in paragraph 5C if the constituent is 

listed in the table and if the background level of the constituent is below the value listed or; 

(c) an ACL established by the NRC. Under Criterion 5B(6),requests for ACLs would only be 

considered after a applicant has demonstrated that restoring the constituent at issue to 

background or MCL values is not practically achievable at a specific site. Only ACLs that 

present no significant hazard may be proposed by applicants for NRC consideration. The NRC 

may establish a site specific ACL for a hazardous constituent if it finds that the proposed limit is 

as low as reasonably achievable, after considering practicable corrective actions, and that the 

constituent would not pose a substantial present or potential hazard to human health or the 

environment as long as the ACL is not exceeded. A discussion of the additional Criterion 5B(6) 

requirements for ACLs is presented in Appendix C of the final SEIS. 

Comments: MR010-005; MR011-005; MR017-021; MR017-023; MR012-042; MR012-043

A commenter noted that NRC has not been able to accomplish restoration of groundwater to 

baseline values for all groundwater constituents in any ISL wellfield to date. Another 

commenter stated that NRC had mischaracterized the ISR mining’s groundwater restoration 

efficacy history and unreasonably minimized the impacts from groundwater restoration. A 

commenter stated that restoration has only been accomplished by lowering the standards. 

Another commenter similarly stated that restoration to either background levels or MCL 

standards has been aspirational rather than a reality, and that regulators—whether NRC or 

Agreement States—have allowed ACLs to be established for some constituents. The 

commenter asserted that restoration standards have been a moving target for all ISR mining 

sites and that NRC has made it nearly impossible for a reader to analyze environmental impacts 

because of the lack of a detailed and comprehensive history of ISR restoration operations. 

Response: The commenters are correct that, to date, restoration to backgroundwater quality 

for all constituents has proven to be not practically achievable at licensed NRC ISR sites (NRC, 

2005; NRC, 2004; NRC, 2003). In the past, NRC has applied “class of use,” a state designation 

under the SDWA, as a secondary restoration goal to approve these restorations. The “class of 

use” standard for restored groundwater quality was based on restoration standards provided in 

NUREG–1569. The “class of use” standard was neither treated nor approved as an ACL. 

The NRC has since determined that the primary and secondary restoration standards in 

NUREG–1569 are inconsistent with the restoration standards in 10 CFR Part 40, Appendix A, 

Criterion 5B(5). The NRC notified licensees and applicants in Regulatory Information Summary, 

RIS 09-05, dated April 29, 2009, that the restoration standards listed in NUREG–1569, 

Section 6.1.3(4) are not consistent with those listed in 10 CFR Part 40, Appendix A, applicant 

must commit to achieve the restoration standards in Criterion 5B(5). 

For all licensees, NRC would require an ACL for any constituents that do not meet the primary 

baseline standards. NRC would perform an SER and environmental review when a licensee 

applies for a license amendment to establish ACLs for a particular constitutent after it 

demonstrates it is not practically achievable to restore the wellfield to either background or 

MCL levels. 
Appendix B 

B–37 

Comment: MR012-047 

A commenter asserted that the issuance of waivers and (aquifer) exemptions should be part 

of the analysis and that NRC must analyze the impact of the waivers and exemptions. 

The commenter stated that by not doing this both the GEIS and SEIS fail the NEPA “hard 

look” standard. 

Response: EPA granting of an aquifer exemption is an administrative action that allows the 

licensee to use ISR technology to extract uranium from the ore body. NRC does not do an 

environmental impact analysis of the EPA decision of whether or not to grant an aquifer 

exemption. NRC environmental review analyzes the potential environmental impact of NRC 

licensing the proposed action to use ISR technology to extract uranium from the ore body if it 

receives an aquifer exemption from the EPA. However, the NRC No-Action Alternative analysis 

is equivalent to the environmental impact analysis of not receiving an aquifer exemption from 

the EPA because the license would not be able to use ISR technology to extract uranium from 

the ore body. 

The commenter appears to consider the ACL as a “waiver” from the primary goal of restoring 

constituents to background levels. Neither the terms of Criterion 5B nor the AEA provision on 

which it is based—AEA Section 84c—support the waiver concept. As stated in Criterion 5B(6), 

ACLs reflect site-specific limits that are found to be “as low as reasonably achievable.” NRC 

performs an SER and environmental review when a licensee applies for a license amendment 

to establish ACLs for a particular constitutent after it demonstrates is not practically achievable 

to restore the wellfield to background or MCL levels. A discussion of the additional Criterion 

5B(6) requirements for ACLs is presented in Appendix C of the final SEIS. 

Comments: MR009-081; MR009-180 

A commenter stated that the SEIS needed to provide a more precise description of the 

Appendix A Criterion 5(B)(5) standards for groundwater restoration and clearly state that the 

standards are baseline or an MCL, whichever is higher, or an ACL and then provide a 

description of an ACL. 

Response: For any given groundwater constituent, licensees and applicants are subject to the 

three groundwater quality standards listed in 10 CFR Part 40, Appendix A, Criterion 5B(5)—

background, MCL or ACL. A licensee must try to restore to background or MCL, whichever is 

higher . After demonstrating that background or MCL is not practically achievable, a licensee 

may request a license amendment for approval of an ACL for a particular constituent. A 

discussion of the NRC requirements for application, review and establishment of a site-specific 

ACL is presented in Appendix C of the final SEIS. 

NRC has revised the SEIS to state that licensees and applicants must commit to achieve the 

groundwater quality standards in 10 CFR Part 40, Appendix A, Criterion 5B(5) for all 

restored aquifers. 

B5.9.10 References 

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

Protection Against Radiation.” 

10 CFR Part 40. Appendix A. Code of Federal Regulations, Title 10, Energy, Part 40, Appendix 

A, “Criteria Relating to the Operations of Uranium Mills and to the Disposition of Tailings or 
Appendix B 

B–38 

Wastes Produced by the Extraction or Concentration of Source Material from Ores Processed 

Primarily from their Source Material Content.” 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

Part 800, “Protection of Historic Properties.”

40 CFR Part 146. Code of Federal Regulations, Title 40, Protection of Environment. Part 146, 

“Underground Injection Control Program: Criteria and Standards.”

71 FR 77266, U.S. Nuclear Regulatory Commission. “EPA proposed amendments to the SPCC 

rule.” December 26, 2006. 

EPA (U.S. Environmental Protection Agency), 1994. National Oil and Hazardous Substance 

Pollution Contingency Plan (as amended). Final Rule, 59 FR 47384. September. 

NRC (U.S. Nuclear Regulatory Commission), 2009a. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

NRC, 2009b. “Uranium Recovery Policy Regarding (1) the Process for Scheduling Licensing 

Reviews and (2) the Restoration of Groundwater at Licensed Uranium In-Situ Recovery 

Facilities,” Regulatory Issue Summary 2009-05. April 29. ADAMS Accession 

No. ML083510622. 

NRC, 2008. Regulatory Guide 3.11, Revision 3, “Design, Construction, and Inspection of 

Embankment Retention Systems at Uranium Recovery Facilities.” Washington, DC: NRC. 

November. 

NRC, 2006. “Regulation of Groundwater Protection at In Sit Leach Uranium Extraction 

Facilities.” SRM to COMJSM–006–001. March 24. ADAMS Accession No. ML060830525. 

NRC, 2005, “Technical Evaluation Report: Review of Cogema Mining Inc.’s Irigaray Mine 

Restoration Report, Production Units 1 Through 9.” Source Materials License SUA–1341. 

ADAMS Accession No. ML062570181. 

NRC, 2004. “Review of Power Resources, Inc’s A- Wellfield Groundwater Restoration Report 

for the Smith Ranch –Highland Uranium Project.”’ June 29. ADAMS Accession 

No. ML041840700. 

NRC, 2003a. License Amendment 15, Crow Butte Resources In-Situ Leach facility, License No. 

SUA-1534, Wellfield #1 Restoration Acceptance. Letter and Attachments from D. Gillen to 

M.L. Griffin dated February 12, 2003. ADAMS Accession No. ML03044055. 

NRC, 2003b. NUREG–1748, “Environmental Review Guidance for Licensing Actions 

Associated with NMSS Programs.” Washington, DC: NRC. August. 

NRC, 2003c. NUREG–1620 “Standard Review Plan for the Review of a Reclamation Plan for 

Mill Tailings Sites under Title II of the Uranium Mill Tailings Radiation Control Act of 1978.” 

Final Report. Washington, DC: NRC.
Appendix B 

B–39 

NRC. 2003d. NUREG–1569, Standard Review Plan for In-Situ Leach Uranium Extraction 

License Applications. Final Report. Washington, DC: NRC. June 2003. 

NRC, 2000. NUREG–1724 “Standard Review Plan for the Review of DOE Plans for Achieving 

Regulatory Compliance at Sites With Contaminated Groundwater Under Title I of the Uranium 

Mill Tailings Control Act.” Draft Report. Washington, DC: NRC. 

WGFD (Wyoming Game and Fish Department), 2010. “Recommendations for Development of 

Oil and Gas Resources Within Important Wildlife Habitats.” Version 6.0. Cheyenne, Wyoming: 

WGFD. April. 

B5.10 Credibility of NRC 

Comments: MR001-006, MR012-009; MR012-010; MR012-024; MR012-028; MR012-032; 

MR012-035; MR012-037; MR012-064. 

Two commenters questioned NRC credibility in their submitted comments. The commenter 

asserted that NRC turned a “blind eye” to the analysis of cumulative impacts and stated the 

analysis of potential groundwater excursions masked the potential effect to the underlying 

aquifer and thus evaded meaningful analysis. The commenter concluded the analysis of 

groundwater impacts was arbitrary and ad hoc, which the commenter stated was not supported 

by NEPA or its implementing regulations. The commenter stated that NRC evaded performing 

meaningful analysis of impacts on surface waters at the Moore Ranch site because the analysis 

disregarded the close proximity of mining operations at the Moore Ranch site. Another 

commenter stated that the groundwater protection rule had “fallen off the table” for the benefit of 

an industry that wished to proceed with materials licensing under a less- than-protective 

regulatory framework. 

Response: With regard to the general comment made regarding NRC credibility, the 

commenter is reminded that NRC is an independent federal agency that has no ownership of 

any nuclear or ISL facility. NRC regulates licensees by conducting a thorough and independent 

review of each application for a license consistent with its congressional mandate and NRC 

regulations for safety and environmental review. Once a license is granted, NRC enforces its 

regulations and license conditions by conducting regular inspections of operating facilities. If 

inspections detect noncompliance, fines and other punitive measures can be taken depending 

on the severity of the infraction. Because the comments were general in nature, no specific 

changes in the Moore Ranch SEIS were made in response to these comments. 

With regard to the specific comments that are related to the commenter views of NRC 

credibility, it can be noted that (a) the analysis of cumulative impacts in Chapter 5 of the Moore 

Ranch final SEIS was revised in response to public comments; (b) the commenter concerns 

regarding the analysis of groundwater impacts are addressed in Section 5.9.12 of this comment 

response appendix; (c) in contrast to the assertion that NRC evaded performing meaningful 

analysis of impacts on surface water, Section 3.5.1.4 of the SEIS discusses the seasonal 

variability in surface water quality that is largely influenced by the CBM operations in the area; 

(d) Section 5.5.1 of the SEIS discusses the cumulative effect on surface water from both the 

proposed licensing of the Moore Ranch Project and the other activities occurring in the area 

including CBM operations; and (e) the status of the proposed rule with new standards applicable 

to ISL facilities is discussed in Section B5.9.6 of this comment response appendix. 
Appendix B 

B–40 

B5.11 Federal and State Agencies 

B5.11.1 Roles of Federal, Tribal, State, and Local Agencies 

Comments: MR002-003; MR013-008; MR009-054 

Three commenters stated that the SEIS should reflect finalization of the MOU between NRC 

and BLM (NRC, 2010). One commenter further noted that although NRC did not recognize 

BLM as a Cooperating Agency on the Moore Ranch draft SEIS, the MOU will allow the two 

agencies to work more closely on ISR uranium recovery projects in states where NRC has the 

licensing authority and BLM has administrative responsibilities for surface management an/or 

minerals. The same commenter also stated that the intent of the MOU is to improve 

interagency communications; facilitate the sharing of special expertise and information; and 

coordinate the preparation of studies, reports, and environmental documents. A second 

commenter requested that NRC update references to the MOU to indicate that it had been 

finalized. The third commenter requested that the SEIS clarify what MOU provisions are 

applicable to the NRC Moore Ranch Project review. 

Response: SEIS Section 1.7.3.1 discusses NRC coordination with the BLM during the 

preparation of the SEIS. Included in that discussion is mention of the MOU, which was in a draft 

form at the time the draft SEIS was published. As indicated by the commenter, the MOU has 

since been finalized. Section 1.7.3.1 has been revised to reflect this fact and the general goals 

of the MOU. 

For the Moore Ranch Project specifically, the MOU formalizes the types of interactions and 

coordination already occurring between NRC and the BLM. No further changes were made to 

the SEIS in response to this comment beyond those changes identified in this response. 

Comments: MR002-001; MR009-200 

Two commenters provided comments on the BLM role with respect to the Moore Ranch Project. 

One commenter stated that BLM has no authority, as the project is located on surface lands 

under private ownership. The other commenter stated that the Moore Ranch Project is not 

located on lands administered by the Rawlins, Wyoming, BLM office. 

Response: SEIS Section 3.2 (Land Use) details the ownership of surface and mineral rights at 

the Moore Ranch Project. As discussed there, the Moore Ranch Project would be located on 

lands with surface rights owned by private entities (more than 85 percent of the lands within the 

proposed project boundaries) and by the State of Wyoming (approximately 14 percent). The 

mineral rights are owned by private entities, the State of Wyoming, and the BLM, although BLM 

rights have been leased to Uranium One. Therefore, where appropriate in this SEIS, NRC has 

clarified discussion to clearly indicate that BLM does not have a role at the Moore Ranch Project 

with respect to surface lands and rights. 

Comment: MR009-013 

One commenter requested that NRC, when discussing the packaging and transportation of 

dried yellowcake in the Executive Summary, state that the SEIS notes that packaging and 

transportation of yellowcake is completed in compliance with NRC and U.S. Department of 

Transportation (DOT) regulations. 
Appendix B 

B–41 

Response: SEIS Section 4.3.1.2 (Transportation Impacts—Operation Impacts) states that 

transportation of yellowcake is performed in accordance with NRC and DOT regulations. NRC 

has clarified this elsewhere in this final SEIS where appropriate.

Comments: MR009-056; MR009-057; MR009-059 

One commenter expressed concern over comments attributed to staff of the WDEQ in public 

meetings with the NRC. The commenter stated that the appropriate groundwater restoration 

standard under Wyoming statute and regulation is “class of use” and not “baseline conditions,” 

as apparently stated by the WDEQ staff. Additionally, the commenter noted that the WDEQ 

staff comments about groundwater restoration standards do not appear in the reference cited in 

the text. 

Response: Final SEIS Section 1.7.3.4 has been modified to reflect the level of discussion cited 

in the reference. Additionally, NRC notes that for NRC licensing purposes, the groundwater 

restoration standard will be baseline conditions, MCLs in 10 CFR Part 40 Appendix A Table 5C, 

or ACLs approved by NRC. 

Comment: MR009-149 

One commenter noted that the SEIS is incorrect in stating that industrial safety aspects 

associated with the use of hazardous chemicals at the proposed Moore Ranch ISR Project 

would be regulated by the Wyoming Division of Mine Inspection and Safety. The commenter 

stated that the Occupational Safety and Health Administration regulates industrial safety 

(including chemical safety) at ISR mines in Wyoming. 

Response: Final SEIS Sections 3.12.3 and 4.13.1.2.3 have been modified to reflect this change 

in regulatory oversight. 

Comment: MR009-212 

One commenter stated that approval of the site decommissioning plan by Federal and State 

agencies other than NRC is not required. 

Response: NRC agrees with the commenter. SEIS Section 4.6.1.4 has been revised to clearly 

indicate that the site decommissioning plan is approved by NRC.

Comment: MR013-008

One commenter requested that tables in the draft SEIS detailing applications or requests that 

have been or will be filed by the applicant be updated in the final SEIS. 

Response: NRC agrees with the comment. Table 1-2 in Section 1.6.2 has been updated to 

reflect the current status of the applicant’s permitting with other federal, tribal, and 

state agencies. 

Comment: MR013-019 

One commenter stated that the WDEQ conducts detailed reviews of all ISR wellfield packages 

in Wyoming. Additionally, the commenter considers the NRC review of one or more multiple 

wellfield packages unnecessary and duplicative. 

Response: Because these comments address details about the NRC licensing and the State of 

Wyoming permitting processes, NRC considers the comments to be beyond the scope of the 

Moore Ranch SEIS.
Appendix B 

B–42 

Comment: MR020-020

One commenter stated that the SEIS contained inaccurate statements about the UIC program. 

Specifically, the commenter stated that the process for exempting an aquifer in Wyoming first 

involves State approval of the exemption request to be followed by EPA approval of the 

State action. The commenter notes that both the State process and the EPA final approval 

are required. 

Response: NRC agrees with the comment. Discussion of the aquifer exemption process has 

been clarified throughout the SEIS, where appropriate, to reflect the State process and the EPA 

authority for final approval. 

B5.11.2 Effects of Changes to Federal or State Regulations on the SEIS

Comments: MR018-002; MR018-003; MR018-004; MR018-005; MR018-007 

One commenter noted that EPA has made revisions to the National Ambient Air Quality 

Standards (NAAQS) for lead and nitrogen dioxide, and that EPA has proposed revisions to the 

primary sulfur dioxide NAAQS and to the 8-hour standard for ozone. 

Response: SEIS Section 3.7.2 has been revised to reflect the EPA revisions to the lead and 

nitrogen oxide NAAQS. Additionally, NRC has modified this section to reflect that the State of 

Wyoming has developed stricter standards for annual and 24-hour sulfur dioxide. Finally, as 

necessary, NRC has reanalyzed air quality impacts in Chapter 4 to reflect these EPA and 

Wyoming standards. 

NRC has decided not to reflect proposed standards in the SEIS, as the SEIS is written with 

the regulations currently in effect at the time of its writing. Should the proposed standards 

be finalized in the future, NRC will reflect the final air quality standards in future 

environmental reviews.

Comment: MR018-006

One commenter noted that, although Table 1-2 in Section 1.6.2 suggests that an air quality 

permit may not be needed for the Moore Ranch Project, the project is still subject to the 

permitting requirements of the Wyoming Air Quality Standards and Regulations. 

Response: NRC has revised Table 1-2 to reflect that an air quality permit may be needed 

pursuant to the standards and regulations identified by the commenter. 

Comment: MR018-095 

One commenter stated that the State of Wyoming has not yet entered into rulemaking to revise 

the standards for annual PM10 or 24-hour PM10. However, the commenter requests that the 

SEIS still note these standards. 

Response: NRC has decided not to reflect proposed standards in the SEIS, as the SEIS is 

written with the regulations currently in effect at the time of its writing. Should the proposed 

standards be finalized in the future, NRC will reflect the final air quality standards in future 

environmental reviews. 
Appendix B 

B–43 

B5.11.3 Clarification of Other Federal/State Regulations and Practices 

Comment: MR009-055 

One commenter requested that the discussions with BLM described in Chapter 1 of the draft 

SEIS be made specific to the proposed Moore Ranch project. 

Response: SEIS Section 1.7.3.1 has been revised to provide specific reference to the 

proposed Moore Ranch ISR facility. 

B5.11.4 References 

NRC (U.S. Nuclear Regulatory Commission), 2010. “Notice of Availability of a Memorandum of 

Understanding Between the Nuclear Regulatory Commission and the Bureau of Land 

Management.” Federal Register. Vol. 74. p. 1088. January 8. 

10 CFR Part 40. Appendix A. Code of Federal Regulations, Title 10, Energy, Part 40, Appendix 

A, “Criteria Relating to the Operations of Uranium Mills and to the Disposition of Tailings or 

Wastes Produced by the Extraction or Concentration of Source Material from Ores Processed 

Primarily from their Source Material Content.” 

B5.12 Cooperating Agencies and Consultations 

Comment: MR020-005 

One commenter suggested it would be appropriate to include, under “1.7.2 National Historic 

Preservation Act of 1966 Consultation,” a reference to coordination with tribes. 

Response: NRC acknowledges this comment. A complete list of the tribes can be found in 

SEIS Section 1.7.3.3 Interactions with Tribal Governments. Additionally a copy of the letter sent 

to each tribe is included in Appendix A. Although each tribe was sent a separate letter on 

February 23, 2009 only a single letter is included. Clarification text was added to Appendix A in 

response to this comment. 

Comment: MR020-006

One commenter states the SEIS is inconsistent is the status and agreement of the Wyoming 

SHPO of the eligible status of sites within the Moore Ranch Project area. 

Response: The comment is noted, and the text has been revised to correct inconsistencies. 

The Wyoming SHPO, in a letter dated November 3, 2009, to the NRC, concurred that the sites 

located within the Moore Ranch Project area are ineligible for listing on the NRHP. In addition, 

the letter states, “We recommend the U.S. Nuclear Regulatory Commission allow the project to 

proceed in accordance with State and Federal laws subject to the following stipulation: If any 

cultural materials are discovered during construction, work in the area shall halt immediately, 

the federal agency and SHPO staff be contacted, and the materials be evaluated by an 

archaeologist or historian meeting the Secretary of the Interior’s Professional Qualification 

Standards (48 FR 22716, September 1983). Additionally, if any future disturbance is planned at 

the locations of sites 48CA964, 48CA6694, or 48CA6696 that evaluative testing be completed 

and submitted to our office with a determination of site eligibility and project effect. If eligible and 

adversely affected, a Memorandum of Agreement implementing appropriate mitigative 
Appendix B 

B–44 

measures will be required.” Section 1.7.2 of the SEIS has been revised to include this 

statement and a copy of the letter has been appended to the document.

Comment: MR020-007 

One commenter noted the NHPA discussion does not identify which parties have been 

determined as consulting parties under 36 CFR 800.2(c). 

Response: NRC agrees with the comment, and Section 1.7.2 was revised to further indicate 

the consulting parties. 

Comment: MR020-008 

One commenter noted there is no documentation of communication of the finding of no effect to 

any parties other than the six cc recipients of the letter. Under 36 CFR 800.4(d)(1), all 

consulting parties must be informed of a finding of no effect. 

Response: NRC acknowledges this comment. The final SEIS Section 1.7.2 National Historic 

Preservation Act of 1966 Consultations was revised to include that all consulting parties were 

informed of a finding of no effect. 

Comment: MR020-009 

One commenter stated that no rationale is provided for the selection of these nine tribes 

for consultation. 

Response: Section 3.9.2.1.1 Ethnology—Identification and Evaluation states that tribes that 

have heritage interest in the proposed Moore Ranch project area were consulted. 

Section 1.7.3.3 Interactions with Tribal Governments has been revised to include information on 

Tribal selection for consultation. 

Comments: MR020-010, MR020-025 

One commenter stated that the list of enclosures documenting that tribes other than the Eastern 

Shoshone were sent the February 23, 2009, consultation letter is not included in the Appendix. 

Therefore, it is not possible to confirm whether Tribal Historic Preservation Officers were 

included in the distribution. 

Response: NRC acknowledges this comment. All Tribal Historic Preservation Officers were 

included on the distribution list on the letters dated February 23, 2009. A footnote has been 

added to the Table A-1 to clarify the distribution list. Note however, that there is only one 

ADAMS Accession number for all letters sent to the tribes. 

Comments: MR020-011 

One commenter noted that the consultation letter included at A-39 appears to be a draft (it is 

dated October 22, 2009, not October 23, 2009 as in the citation at 1-12, and includes formatting 

marks. The commenter requests the appendix include a copy of the final version. 

Response: NRC acknowledges this comment. A copy of the finalized and signed letter to the 

Wyoming SHPO (October 23, 2009) was included in the References for Chapter 4, and the text 

has been revised to reflect the most current letter date. 
Appendix B 

B–45 

B5.12.1 References 

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

Part 800. “Protection of Historic Properties.” 

48 FR 22716. “Archeology and Historic Preservation: Secretary of the Interior's Standards and 

Guidelines.” Federal Register. September 1983. 

B5.13 SEIS Schedule 

Comments: MR001-001; MR003-001; MR004-001; MR005-001; MR006-001 

Commenters requested that the comment period on the Moore Ranch SEIS be extended to 

provide interested stakeholders sufficient time to adequately review the SEIS. Some 

commenters referred to the large size of the Moore Ranch SEIS and the need for more time to 

read and collect referenced information to better contribute to the process through the 

submission of substantive comments. Commenters also noted the comment period overlapped 

with seasonal holidays in December, thus reducing the time to review the document. 

Response: On December 11, 2009 (74 FR 65806), the NRC staff published a notice in the 

Federal Register requesting public review of and comment on the “Draft Environmental Impact 

Statement for the Moore Ranch ISR Project in Campbell County, Wyoming, Supplement 1 to the 

Generic Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities.” In the 

publication of the NOA of the draft SEIS, the staff stated that the close of the public comment 

period closed on February 1, 2010. On February 5, 2010, the NRC staff extended the public 

comment period to March 3, 2010, in response to public requests for extension received via 

comment letters and email. The 82-day period for public comment (i.e., from December 11, 

2009 to March 3, 2010) exceeds the minimum 45-day comment period required under NRC 

regulations. By letter and email, 20 individuals submitted 691 comments on the Moore Ranch 

draft SEIS. 

Comment: MR005-002 

A commenter stated that the public comment period on the Moore Ranch draft SEIS was 

insufficient to allow for meaningful public participation and was inconsistent with the purpose 

and intent of the NEPA, which encourages meaningful public participation in the environmental 

decision-making process. 

Response: The NRC staff initially established February 1, 2010, as the deadline for submitting 

public comments on the Moore Ranch draft SEIS. In response to public comments, the NRC 

staff extended the public comment period to March 3, 2010 (75 FR 6065). 

B5.13.1 References 

74 FR 65806, NRC (U.S. Nuclear Regulatory Commission). “Notice of Availability of Draft 

Environmental Impact Statement for the Moore Ranch In-Situ Recovery (ISR) Project in 

Campbell County, WY; Supplement to the Generic Environmental Impact Statement for In-Situ

Leach Uranium Milling Facilities.” Federal Register. Vol. 74, No. 237. pp. 65806–65810. 

December 11, 2009. 
Appendix B 

B–46 

75 FR 6065, NRC. “Extension of Public Comment Period on the Draft Environmental Impact 

Statement for the Moore Ranch In-Situ Recovery Project in Campbell County, WY; Supplement 

to the Generic Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities.” 

Federal Register, Vol. 75, No. 24, pp. 6065-6066. February 5, 2010. 

B5.14 ISL Process Description 

B5.14.1 Overview 

Comment: MR009-011 

One commenter stated that uranium is not technically leached from solution, but removed. 

Response: NRC agrees with this comment. SEIS text in the Executive Summary was revised 

to accurately describe this uranium milling process. 

Comment: MR012-022

One commenter expressed concern that NRC conducted an analysis of impacts from 

excursions related to ISR uranium recovery from unconfined aquifers. The commenter believes 

that this is contradictory to an NRC position in the GEIS that ISR technology can only be used in 

confined aquifer systems. 

Response: The GEIS is not an NRC requirement, nor does it constitute an agency policy for or 

against a particular type of aquifer or uranium ore formation geometry. As stated in the text box 

in GEIS Section 2.1, the “[h]ydrogeologic (formation) geometry must prevent uranium-bearing 

fluids (i.e., lixiviant) from vertically migrating.” Although this type of isolation may best be 

achieved by the presence of confining, low permeability layers such as shales or clays both 

above and below the uranium-bearing horizon, the GEIS does not identify a specific type of 

geometry that must exist for a license to be granted. Instead, the applicant defines the wellfield 

boundaries “...based on the geometry of the specific uranium mineralization.” (GEIS 

Section 2.1), and NRC evaluates the potential impacts from the proposed approach. The 

impact analysis presented in Section 4.5.2 of this final SEIS is based on the hydrogeologic 

information for the Moore Ranch site. In addition, the NRC staff are conducting a detailed 

technical review of the applicant license application to evaluate whether the proposed Moore 

Ranch ISR facility can be operated in accordance with the applicable NRC regulations in 

10 CFR Part 40. 

B5.14.2 Preconstruction and Construction 

Comment: MR004-002 

Western Watershed Project staff commented that their organization had not received all of the 

reports and analyses they requested. 

Response: NRC staff do not consider this request to be a comment on the draft SEIS. This 

comment is beyond the scope of the SEIS. 

Comment: MR009-012 

One commenter noted that the well pattern for Moore Ranch was not limited to a five-spot 

pattern and that alternate patterns were possible. 
Appendix B 

B–47 

Response: NRC acknowledges the possibility of a pattern other than five-spot, and a 

modification was made to the SEIS to reflect this. 

Comment: MR009-072 

One commenter noted that Section 2.1.1.2, Construction Activities, does not include a 

description of all construction activities similar to Section 2.1.1.2 in the Uranerz Nichols Ranch 

SEIS. Specifically, there is no discussion of well construction and testing methods and other 

structures and systems in this section of the Moore Ranch SEIS. This additional information 

would help to better describe the Proposed Action. 

Response: The NRC staff have reviewed the discussion of construction activities in the SEIS. 

The text has been modified to include discussions of well construction and testing. 

Comment: MR009-168

One commenter noted that the only potential spills during construction could be petroleum 

product leaks from drill rigs, vehicles, and heavy equipment, as there are no chemical or 

radioactive materials present that could be spilled. 

Response: The NRC staff acknowledge this comment. However, no changes have been made 

to the SEIS beyond this comment response. 

Comment: MR020-043

One commenter was concerned that the discussion in the SEIS indicated that fugitive dust and 

combustion emissions during construction would be short term, however, well construction was 

projected to last a number of years. 

Response: The NRC staff have reviewed the discussion of meteorology, climatology, and air 

quality impacts in the SEIS. The short-term impact due to dust and combustion emissions 

during construction was evaluated in terms of the duration of the emissions and the lasting 

impacts beyond emission-causing construction activities themselves. While construction 

activities would be ongoing for a number of years, the impacts from the emission-causing 

activities are not expected to have a lasting impact on air quality when activities cease. No 

modifications have been made to the SEIS beyond this response. 

B5.14.3 Operations

Comment: MR009-067 

One commenter was concerned that the discussion of chemical storage was inconsistent with 

the measures proposed by the applicant for the Moore Ranch facility. 

Response: The NRC staff have reviewed the discussion of chemical storage in the SEIS and 

modified the text to be consistent with the information provided by the applicant in their 

technical report. 

Comment: MR009-073 

One commenter suggested adding a discussion of the management of production bleed and 

other liquid effluents to the SEIS. 

Response: The NRC acknowledges the request, and a discussion about management of 

production bleed and other liquid effluents has been added to the final SEIS. 
Appendix B 

B–48 

Comment: MR009-074 

One commenter noted that the stated five steps identified as part uranium mobilization in the 

SEIS were not part of mobilization, but uranium processing. 

Response: The NRC staff have reviewed the discussion of uranium processing in the SEIS. 

The text has been modified to address the inconsistencies identified by the commenter. 

Comment: MR009-206 

One commenter indicated that the discussion of impacts to wildlife in the SEIS stated that leaks 

from pipelines could expose wildlife to toxic chemicals; however, there are no toxic chemicals 

present in lixiviant. 

Response: The NRC staff have reviewed the discussion of impacts to wildlife in the SEIS. The 

text in the SEIS has been modified to clarify the potential exposures to wildlife. 

Comment: MR018-036

One commenter noted that the SEIS did not appear to address the hydrostatic testing of 

pipelines or testing/purging of wells. 

Response: As noted in SEIS Section 2.1.1.2.4, the applicant has stated that all pipelines would 

be pressure tested before being placed into service. In addition, the applicant has indicated its 

intent to use engineering controls to monitor flow rates and pressure changes in the piping 

system, and alarms to alert the operator of losses in pressure that could indicate problems with 

piping or well integrity (SEIS Section 6.3.2). The commenter is correct that integrity testing of 

wells was not addressed in the draft SEIS, and Section 2.1.1.2.3 has been revised to reflect the 

planned well development and testing program described by the applicant in Section 3.1.2 of its 

technical report for the proposed Moore Ranch ISR facility in Energy Metal Corporation US 

(EMC, 2007; Uranium One, 2008). 

B5.14.4 Aquifer Restoration 

B5.14.5 Gaseous or Airborne Particulate Emissions 

Comments: MR015-015; MR015-016; MR015-023; MR020-039; MR020-045 

One commenter, EPA, stated that the air quality analysis is not adequate because detailed 

emission inventories for drill rig engines, fugitive dust, and facility operations are not presented. 

They indicated the emission inventories are needed so that NRC can decide on the extent of the 

air impact analysis. An additional comment from the same commenter noted on pages 4-45 to 

4-47 that while the number of vehicles and equipment used for the proposed action are less 

than evaluated in the GEIS, the emissions are not included in the air quality impact analysis. 

Response: The draft SEIS included emissions estimates for fugitive dust but did not provide 

detailed drilling rig or operational emissions estimates. In response to public comments, the 

staff updated the SEIS with additional information on the fugitive dust calculations and provided 

emissions estimates for diesel powered drilling and construction equipment. Details of the 

diesel emissions calculations are summarized in a new Appendix D in the final SEIS. The 

staff also provided more details regarding emissions from facility operations in SEIS 

Section 2.1.1.1.6.1. Section 4.7 of the final SEIS, the air quality impact analysis, was 

revised to incorporate by reference the revised emissions information that was added to 
Appendix B 

B–49 

Section 2.1.1.1.6.1. The more detailed emissions estimates support the conclusions in the 

GEIS and SEIS that ISR facilities are not major sources of airborne emissions and draft SEIS 

impact conclusions were not changed by providing the more detailed emissions information. 

B5.14.6 Operational History 

Comment: MR009-112 

One commenter noted that the discussion of evaporation ponds as an alternate waste disposal 

method in draft SEIS Section 2.2.5 was based on an older NRC evaluation of an earlier (1982) 

application for a conventional uranium recovery operation at the Moore Ranch site. The 

commenter noted that although the text in the SEIS did provide an historical context, 

additionally, a more recent basis is available for evaluating evaporation. 

Response: The NRC staff agrees that the discussion of evaporation ponds as an alternate 

wastewater disposal option could be strengthened. The text in SEIS Section 2.1.1.2.1 has been 

modified to improve the clarity of the discussion in response to this comment. 

B5.14.6.1 Historical Operational Experience: Spills and Leaks 

Comment: MR012-031 

One commenter stated that the water resource impact analysis relies heavily on the leak and 

spill surveys presented in two documents that are incomplete and inaccurate. The two 

documents identified by the commenter are the GEIS and the NRC memorandum “Staff 

Assessment of Groundwater Impacts from Previously Licensed In-Situ Uranium Recovery 

Facilities (NRC, 2009). 

Response: NRC conclusions regarding the potential environmental impacts to water resources 

for the Moore Ranch Project are provided in SEIS Sections 4.5.1 and 4.5.2. In determining 

impact conclusions, the NRC staff reviewed information provided by the applicant in its license 

application as amended (including the technical and environmental reports), information and 

data independently collected by the staff, and information and data from the GEIS and the NRC 

memorandum (NRC, 2009). The intent of the GEIS and NRC memorandum is not to provide an 

exhaustive listing of site-specific information, but rather an accurate understanding of the types 

and magnitudes of impacts that have been encountered at NRC-licensed facilities. No changes 

were made to the Moore Ranch SEIS in response to this comment. 

Comment: MR012-034

One commenter stated that for water resource impacts, NRC acknowledges the record of ISL 

operations spills and leaks to a certain extent. The commenter provided the example of the 

Smith Ranch Project as support for their concern over the limited explanation. 

Response: NRC conclusions regarding the potential environmental impacts to water resources 

for the Moore Ranch Project are provided in SEIS Sections 4.5.1 and 4.5.2. These impact 

conclusions are based on facility-specific process descriptions for the Moore Ranch Project and 

site-specific characteristics at the proposed site. In determining impact conclusions, the NRC 

staff reviewed information provided by the applicant in its license application as amended 

(including the technical and environmental reports), information and data independently 

collected by the staff, and information and data provided in the GEIS. Section 2.11 of the GEIS 

presents an historical discussion of ISL operations (including the Smith Ranch Project) and 
Appendix B 

B–50 

Section 2.14 provides reference to specific facilities in Wyoming, Nebraska, and New Mexico. 

The intent of the information in these sections of the GEIS was to inform the reader about which 

issues have historically resulted in potential impacts at ISR facilities and to provide a range of 

conditions that may be expected for each of the four ISR phases. Because the SEIS discussion 

is considered appropriate, no changes were made to the SEIS in response to this comment. 

B5.14.7 Requests for Detailed Information About All ISL Facilities 

Comment: MR012-046 

One commenter stated that instead of disclosing the average groundwater concentrations, the 

SEIS should provide all groundwater sampling data and written lab reports, including details like 

constituent concentrations and sampling date and locations. The commenter stated that if this 

information was not available, the SEIS should disclose that fact. 

Response: As described in NRC guidance (NRC, 2003), an applicant, in support of its license 

application, is asked to provide site baseline information including groundwater quality at and in 

the vicinity of the site. An NRC-accepted list of constituents to be sampled for determining 

baseline water quality is provided in this guidance as well as a method for the applicant to 

propose a list of constituents that is tailored to a particular location. NRC guidance states that 

to determine background groundwater quality conditions, at least four sets of samples, spaced 

sufficiently in time, should be collected and analyzed for each constituent. The applicant 

provided this summary groundwater quality information and it is summarized in SEIS 

Section 3.5.2.3.3. Detailed information, such as the type requested by the commenter, is 

contained in the applicant environmental and technical reports (EMC, 2007a,b). No changes 

were made to the SEIS beyond the information provided in this response. 

B5.14.8 References 

10 CFR Part 40. Appendix A. Code of Federal Regulations, Title 10, Energy, Part 40, 

Appendix A, “Criteria Relating to the Operations of Uranium Mills and to the Disposition of 

Tailings or Wastes Produced by the Extraction or Concentration of Source Material from Ores 

Processed Primarily from their Source Material Content.” 

EMC (Energy Metals Corporation US), 2007a “Application for USNRC Source Material License, 

Moore Ranch Uranium Project, Campbell County, Wyoming, Environmental Report.” Casper, 

Wyoming: Uranium 1 Americas Corporation. ADAMS Accession Nos. ML072851222, 

ML072851229, ML072851239, ML07285249, ML07285253, and ML07285255. October 12. 

EMC, 2007b. “Application for USNRC Source Material License, Moore Ranch Uranium Project, 

Campbell County, Wyoming, Technical Report.” Casper, Wyoming: Uranium 1 Americas 

Corporation. ADAMS Accession Nos. ML072851222, ML072851258, ML072851259, 

ML072851260, ML072851268, ML072851350, ML072900446. October 12. 

NRC (U.S. Nuclear Regulatory Commission), 2009a. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

NRC, 2009b. “Staff Assessment of Groundwater Impacts from Previously Licensed In-Situ 

Uranium Recovery Facilities.” Memorandum from C. Miller to Chairman Jaczko, et al. July 10. 

ADAMS No. ML091770402. 
Appendix B 

B–51 

NRC, 2003. NUREG–1569, “Standard Review Plan for In-Situ Leach Uranium Extraction 

Licensee Applications—Final Report.” Washington, DC: NRC. June. 

B5.15 Financial Surety 

Comment: MR009-089 

A commenter noted that, while the financial assurance cost estimate for the decommissioning 

plan must be approved by NRC, the cost estimate need not be in place until operations are 

ready to commence. 

Response: 10 CFR Part 40, Appendix A, Criterion 9 states that a financial surety arrangement 

must be established prior to the commencement of uranium recovery operations. NRC revised 

the Moore Ranch SEIS Section 2.1.1.1.8 in response to this comment to state that an initial 

surety estimate is required to cover the first year of operation. 

Comments: MR009-099; MR013-021 

Commenters requested that the SEIS financial assurance discussion be more descriptive. One 

commenter noted that financial assurance is a key component of ISR facility licensing and has 

been a contentious issue in the past. Additionally, the commenter considered financial 

assurance as an excellent example of a mitigation measure to protect against a licensee’s 

potential financial difficulties. The commenters provided examples of additional topics to be 

discussed, such as (1) the types of financial assurance instruments available to licensees, 

(2) how financial assurance cost estimates are developed, (3) when a financial assurance cost 

estimate needs to be approved and posted with the agency, and (4) when the cost estimate is to 

be updated. One commenter also requested that reference be made to the requirements in 

10 CFR Part 40, Appendix A, Criterion 9 and that the term financial “assurance” should be used 

rather than financial “surety.” 

Response: The Moore Ranch SEIS discusses financial assurance in Section 2.1.1.1.8, which 

references NRC financial assurance requirements, both 10 CFR Part 40, Appendix A, 

Criterion 9 and Section 2.10 of the GEIS that provide the detail requested by the commenters. 

Furthermore, the NRC staff review financial surety in detail as part of its review for the SER, 

which is conducted in parallel with the environmental review. Section 2.1.1.8 of the Moore 

Ranch SEIS has been modified to direct the reader to Part 40 Appendix A to and to 

Section 2.10 of the GEIS for further details about financial assurance. 

NRC uses the term “financial surety” in the Moore Ranch SEIS to be consistent with its use in 

10 CFR Part 40, Appendix A, Criterion 9. The term “surety instruments” is used to refer to 

mechanisms (e.g., surety bonds, cash deposits, and irrevocable letters of credit) for holding the 

funds deemed sufficient to cover the costs of site decommissioning and restoration. No 

changes were made to the SEIS in response to this comment beyond the information provided 

in this response. 
Appendix B 

B–52 

Comment: MR009-100 

One commenter stated that NRC should modify the SEIS text to indicate that surety instruments 

other than an irrevocable letter of credit are acceptable to the NRC and, therefore, available for 

use by the applicant. 

Response: NRC agrees with the comment and revised the text in Section 2.1.1.8 of the Moore 

Ranch SEIS to indicate other forms of financial surety instruments acceptable to the NRC. 

Comment: MR017-024 

One commenter stated that the Moore Ranch draft SEIS failed to analyze the applicant financial 

assurance and decommissioning plan and did not compare the current applicant financial 

assurance and decommissioning plans with previous restoration funding in terms of dollars, 

plan, and likely results. 

Response: The Moore Ranch SEIS discusses financial assurance in Section 2.1.1.8, which 

explains that an initial surety estimate is required to cover the first year of operation and that 

annual revisions to the surety estimate would be required by NRC and WDEQ to reflect existing 

operations and planned construction or operation the following year. This discussion also notes 

that the NRC staff review financial surety in detail as part of the NRC SER, which is prepared in 

parallel with the environmental review. The commenter request for a comparison to previous 

restoration funding is beyond the purpose and scope of the SEIS. Therefore, no changes 

were made to the SEIS in response to this comment beyond the information provided in 

this response. 

B5.15.1 Reference 

10 CFR Part 40. Appendix A. Code of Federal Regulations, Title 10, Energy, Part 40, 

Appendix A, “Criteria Relating to the Operations of Uranium Mills and to the Disposition of 

Tailings or Wastes Produced by the Extraction or Concentration of Source Material from Ores 

Processed Primarily from their Source Material Content.” 

B5.16 Alternatives 

Comments: MR012-006; MR017-027 

Comments were received stating that NRC should reevaluate the alternatives analyses in the 

GEIS and Moore Ranch SEIS. A commenter stated that the scope of the SEIS (and the GEIS) 

forestalled viable alternatives by assuming that uranium mining will occur, the ISL process will 

be used, and that the proposed Moore Ranch site is appropriate. The commenter further noted 

that the SEIS did not explore a range of options within ISL mining. 

Response: NEPA requires Federal agencies to consider alternatives to their proposed Federal 

actions as well as to their environmental impacts. Alternatives can be divided into two classes: 

primary alternatives which are alternatives that can substitute for the agency-proposed action to 

accomplish the action in another manner and secondary alternatives that allow the proposed 

action to be carried out in a different manner. The previous comments concern both primary 

and secondary alternatives to the proposed Federal action. 

Reasonable alternatives for a particular Federal action are defined by the proposed Federal 

action and the purpose and need for the proposed Federal action. As a regulatory agency, the 
Appendix B 

B–53 

proposed Federal action for the site is an NRC decision to grant or deny the license application 

of a private party. The purpose and need for the proposed federal action does consider the 

applicant goals and objectives to extract uranium from a particular location, which helps define 

what are reasonable alternatives to the proposed federal action. 

Reasonable alternatives considered in a site-specific environmental review depend on the 

proposed action and site conditions. As discussed in Section 2.1 of the final SEIS, NRC 

considered reasonable alternatives, including the No-Action Alternative, not approving the 

license application and the alternative of approving the application. Section 2.2 of the final SEIS 

provides a discussion of alternatives that were considered but were eliminated from detailed 

study and the reasons for their having been eliminated. These alternatives included 

conventional mining and milling, conventional mining and heap leaching, siting another ISR 

facility location, alternate lixiviants, and alternate wastewater treatment methods. These 

alternatives were eliminated from detailed study because they would cause greater 

environmental impacts than the proposed action. Section 2.1.1.2 of the final SEIS discusses 

alternative wastewater disposal methods. 

While the NRC staff consider reasonable alternatives to the proposed action in the 

environmental review, the only alternative within NRC’s decision-making authority is to approve 

or not approve the license application. The NRC has no authority or regulatory control over the 

applicant selection of uranium recovery technology to be used at the site. NRC regulatory 

authority is limited to evaluating the applicant’s request for a license to use ISR technology at 

the site. If NRC decides to grant the license request, the applicant must comply with the 

license. NRC regulatory requirements and any other relevant local, State or Federal 

requirements to operate their facility. 

Comment: MR012-008 

A commenter noted that NRC failed to consider the reasonable alternative of altering proposed 

project boundaries to reduce the potential environmental impact to surface water, and NRC also 

did not eliminate Wellfield 2 from consideration because of the hydraulic connection between 

groundwater in the proposed target aquifer [the 70 Sand aquifer and an overlying aquifer (the 

68 Sand aquifer)]. 

Response: NRC staff note that the footprint of the subsurface ore zone cannot be altered; 

therefore, development of the wellfield is constrained by the occurrence of the ore zone. 

However, since publication of the draft SEIS, the applicant has proposed to avoid well 

installation in the main channels of ephemeral drainages. The commenter is also correct that 

the production zone in Wellfield 2 would include the 70 and 68 Sand in the regions where the 

“70 underlying shale” is thin or absent. The decision to combine these aquifers into one 

production zone was made by the applicant, not NRC. NRC notes the groundwater quality of 

the “68 Sand,” as measured by the applicant, exceeded the EPA MCL drinking water standards 

for U, Ra 226, gross alpha and selenium. NRC also notes that the applicant would be required 

to obtain exempt aquifer status for the “68 Sand” from EPA before it may be treated as part of 

the production zone. No changes were made to the SEIS beyond the information provided in 

this response. 

Comments: MR015-001; MR015-010 

A commenter noted that the consideration of only Class I UIC injection wells as the waste 

disposal method was inadequate. The commenter noted that other waste disposal alternatives, 

such as (1) treatment and disposal via a Class V injection well; (2) treatment and discharge to 
Appendix B 

B–54 

surface waters under an NPDES permit; and (3) other potential wastewater disposal methods, 

such as land disposal and evaporation ponds, should have been considered in the SEIS. 

Response: In response to public comments, the final Moore Ranch SEIS was revised to 

expand the discussion of alternative wastewater disposal options that were not proposed by the 

license applicant. Section 2.1.1.2 of the final SEIS discusses the previously referenced waste 

disposal options and Table 2-3 compares the options, and Section 4.14.1.2 discusses the 

potential impacts from implementing the alternative wastewater disposal options. If licensed, 

the licensee would have to request a license amendment before using one of these alternative 

wastewater disposal options. NRC would perform an environmental and safety review on the 

proposed wastewater disposal method before deciding whether to grant the request. 

Comment: MR018-033 

A commenter stated that the SEIS needed to analyze alternatives that minimize the amount of 

surface disturbance and topsoil removal, and that pipelines should be colocated with roads to 

minimize surface disturbance. 

Response: Table 2-3 of the final SEIS compares the potential impact to land area from 

implementing alternative wastewater disposal options and shows that the ISR uranium recovery 

method results in significantly less land disturbance than either evaporation ponds or 

land application. 

Comment: MR020-001 

A commenter stated that chemical precipitation and reverse osmosis were dismissed for cost 

rationales rather than environmental or human health effects, and that evaporation ponds were 

eliminated as a waste disposal mechanism without adequate analysis. 

Response: The SEIS considered chemical precipitation and reverse osmosis and eliminated 

them from detailed analysis because they would result in a brine residual and formation of 

sludge being formed. As noted in Section 2.2.5, these alternatives would require onsite storage 

(resulting in additional land disturbance and potential impacts to cultural and biotic resources). 

they create waste that could potentially be characterized as hazardous or mixed waste, 

increasing the regulatory threshold. They also require additional transportation to ship wastes 

offsite, therefore, increasing the potential for occupational exposure and transportation 

accidents. Evaporation ponds at the Moore Ranch site were previously evaluated when Conoco 

Inc. proposed to use conventional milling at the proposed Moore Ranch site (NRC, 1982), and 

the use of evaporation ponds as an alternative wastewater disposal option is considered in 

Section 4.14.1.2.1 of the Moore Ranch final SEIS. No changes were made to the SEIS in 

response to these comments beyond the information provided in this response. 

B5.16.1 Reference 

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 
Appendix B 

B–55 

B5.17 Land Use 

B5.17.1 Ownership Issues, Surface, and Mineral Rights 

Comment: MR002-002 

One commenter noted that the BLM administers all minerals under the Stock Raising 

Homestead Act patented lands and that multiple mineral development conflicts should be 

avoided on split-estate land. The BLM is managing all the mineral rights on approximately half 

of the Moore Ranch land that is split-estate land. 

Response: The NRC staff acknowledged in GEIS comment response G5.19.2 on the 

Ownership Issues, Surface, and Mineral Rights, that ISL operators need to not only lease 

mineral rights but also obtain the consent of surface owners to access the land; explore, 

construct, and operate their ISL facilities. Staff also recognized in GEIS comment response 

G5.19.3 on the Amount of Land Affected and Type; Degree and Duration of Potential Impacts, 

that a lease for uranium extraction on a permitted area an ISL operator would secure, would 

likely take precedence over future mineral rights for oil and gas, CBM, or other mineral 

resources in the same area. For this project, however, where 465 CBM wells and related 

infrastructure are present either on or near the proposed Moore Ranch permitted area, the 

uranium extraction mineral lease would likely need to be intermixed with other and different 

mineral leases, such as for gas extraction by CBM. The NRC staff acknowledge that these 

multiple mineral development leases should be intermixed without potential conflict under the 

BLM administration. But consistent with the GEIS, the NRC staff can only acknowledge, in 

general terms, that the potential Moore Ranch ISL operator would need to reach agreements 

with preexisting mineral rights lease holders under the BLM administration. Because such 

agreements between mineral rights lease holders and the BLM are private and, therefore, 

beyond the scope of this SEIS, no changes to the Moore Ranch SEIS were made beyond 

this response. 

Comment: MR018-099

A staff member of the Industrial Siting Division of the WDEQ indicated that the Industrial Siting 

Council may require a permit for the ISR facility. 

Response: As indicated in SEIS Section 1.6.2, a new uranium ISR milling site would need 

several permits from the WDEQ. NRC acknowledges that the Moore Ranch ISR may require a 

permit from the Industrial Siting Division of the WDEQ. The Council works with the Industrial 

Siting Division to determine if a Section 109 Permit pursuant to Wyoming Statute (W.S.) 

§ 35-12-109 of the Industrial Development Information and Siting Act would be required. 

According to this Division, permits are required of all projects with a construction cost of $175.5 

million or more, and some business types need such a permit regardless of the cost of 

construction. Because it has not been determined at this time whether such a permit would be 

required, no changes were made to the SEIS beyond the information provided in this response. 

B5.17.2 Amount of Land Affected and Type, Degree, and Duration of 

Potential Impacts 

Comment: MR009-063 

A commenter suggested that NRC indicates that construction of a uranium ISR facility is small 

compared to other industrial facilities, as was indicated in the Nichols Ranch SEIS. 
Appendix B 

B–56 

Response: The Nichols Ranch SEIS indicated that, comparatively, trucking activities during 

construction would be minor compared to other industrial activities because the Nichols Ranch 

project construction was deemed to be a fairly small construction project. This statement 

provides a relative comparison because no specific information is provided on other industrial 

construction projects. Thus, this statement does not provide important or critical information 

needed to support decisionmaking. 

Because the information and clarification provided in this response rely on information already in 

the SEIS and, comparatively, on information in the Nichols Ranch SEIS, no changes to the 

Moore Ranch SEIS were made beyond this response. 

Comment: MR009-140 

A commenter indicated there are no coal extraction operations in the Moore Ranch Project area. 

Response: The discussion in Section 3.10, Visual and Scenic Resources, was revised to be 

consistent with the discussion of land use in Section 3.2 of the final Moore Ranch SEIS 

indicating there are no active coal operations in the proposed license area. 

Comment: MR009-152 

A commenter indicated that it is incorrect to state that operating two wellfields sequentially 

would limit impact to the land and open one decommissioned wellfield to other uses like grazing. 

Response: While the NRC staff indicated, consistent with the GEIS, that land impact could 

diminish in sequential operation of wellfields because initial decommissioning and reclamation 

could start at a wellfield where aquifer restoration is completed while operations would continue 

at other wellfields, the NRC staff agree that complete restoration of the land uses, such as 

grazing, to preconstruction conditions and lifting of all access restrictions would only occur after 

license termination. To further stress flexibility in operation, decommissioning and reclamation, 

the NRC staff noted that the applicant could decommission and reclaim the site in stages. 

Nevertheless, NRC revised the discussion in Section 4.2.1.2 of the final SEIS in response to 

the comment. 

Comment: MR009-171 

A commenter noted that in the discussion of the No-Action Alternative, the SEIS stated that 

CBM production in the proposed license area would continue, and the 61 ha [150 ac] would be 

restricted from CBM production. The commenter noted that Section 4.14.1.3 of the license 

application states that the applicant believes that uranium recovery development and CBM 

activities can be coordinated. 

Response: The comment is noted. Section 4.5.1.2 of the Moore Ranch final SEIS has been 

revised to clarify CBM production in the proposed license area. 

Comment: MR009-287 

A commenter indicated that either CBM or oil and gas exploration would not be limited over the 

lifetime of the Moore Ranch ISR Project because they can coexist. 

Response: As noted and corrected for comment MR009–171, the NRC staff acknowledge that 

either CBM or oil and gas exploration would not be restricted within the approximate 66 ac of 

the Moore Ranch license area that would be used for the operation of the facility, as the 
Appendix B 

B–57 

applicant explained uranium ISR operations and CBM and oil and gas exploration could coexist. 

The text in Table 8-1 of the SEIS was corrected accordingly. 

Comment: MR018-029 

A commenter indicated that the construction design should account for natural features of the 

land (i.e., topography and drainage) so natural drainage would not be disrupted. 

Response: It is part of standard engineering and best management practice that a site 

construction be designed and conducted to minimize disruption to and avoid blockage of natural 

surface water drainage features. For the Moore Ranch ISR Project, the NRC staff find that, 

based on the information the applicant provided on its limited construction area, its limited and 

intermittent number of surface water and wetlands features on site, and its implementation of 

best management practices, the potential impacts to natural surface water drainage features 

and to wetlands associated with the construction of roads, the installation of power lines, the 

construction of wells and pipelines, building of the plant, and the related vehicular traffic are 

expected to be small, consistent with the GEIS findings. 

For example, during construction of the proposed Moore Ranch ISR Project, construction of 

Wellfield 2 would have the potential to impact Upper Wash #2 to Simmons Draw because this 

intermittent channel crosses proposed Wellfield 2. One culvert, located on the access road 

connecting the central plant to the main access road, would be constructed to maintain the 

current surface drainage conditions. Power line poles would be not be installed in or near 

intermittent streams. 

Because of the configuration of the site topography and that of the ore bodies, an estimated 

13 wells from Wellfield 2 may be installed in ephemeral channels or delineated wetlands, only if 

unavoidable. No wells would be installed in existing ponds. If some wells would be installed in 

intermittent streams, they would be drilled during the dry season, and erosion and 

sedimentation control measures would be implemented during the drilling period to minimize 

impacts. Upon completion of the well construction, reseeding and mulching would occur to 

stabilize loose soil. 

A PVC pipeline that would need to bisect wetlands and ephemeral channels would be buried 

perpendicular to the channels during the dry season in narrow trenches cut with small 

excavating equipment. Excavated native soil would be used to backfill the trenches to restore 

the natural channel preexisting grade. Reseeding and mulching would be implemented to 

restore soil stability. Also, a single trunkline connecting the pipeline network to the header 

houses would be located in uplands so it would not cross any washes or stream channels. 

Finally, the central processing plant and support buildings would be constructed away and 

landward of all intermittent channels on flat terrain and above the peak flood elevation of the 

intermittent channels. 

These examples illustrate that construction design and planned activities would take into 

account the natural features of the land to help minimize potential impacts to natural surface 

water drainage features and to wetlands. 

Because this response addresses the comment by providing confirmation and clarification with 

information already in the SEIS, no changes to the Moore Ranch SEIS were made beyond 

this response. 
Appendix B 

B–58 

Comment: MR018-030

One commenter indicated that concentrated runoff that would cause erosion should be avoided 

by appropriately designing roads, pipelines, and other structures. 

Response: As detailed in the NRC staff response to related comment MR018-029, the NRC 

staff find that for the Moore Ranch Project, the applicant information on construction design and 

planned construction activities would account for the presence and characteristics of the natural 

features of the land so that natural drainage would not be disrupted and surface runoff from 

roads, pipelines, corridors, and other structures would not be concentrated to potentially cause 

additional erosion. 

Because this response refers to the detailed response provided for related comment 

MR018-029 and because confirmation and clarification is provided in this response with 

information already in the SEIS, no changes to the Moore Ranch SEIS were made beyond 

this response. 

Comment: MR018-035 

A commenter suggested that during drilling operations, portable tanks should be used to 

contain drilling mud and other fluids instead of excavating mud pits in the ground. This would 

reduce surface disturbance and reclamation cost and would also reduce risks of contamination 

and erosion. 

Response: The applicant is proposing the use of mudpits during wellfield construction and 

drilling activities. Mudpits typically remain open for less than 30 days and the applicant would 

follow the WDEQ-LQD guidelines on topsoil and subsoil management at uranium ISR facilities. 

The NRC staff concluded that impacts to soils would be small based on the limited size of the 

wellfield areas, the applicant’s proposed topsoil removal and stockpiling activities, and the short 

duration of mud pit usage and pipeline trenching. The NRC staff recognizes that alternative 

methods are available to limit the potential impacts from the use of mud pits during well drilling 

activities. The text in Section 4.4.1.1 was clarified to acknowledge the availability of alternative 

methods to mitigate impacts from mudpits. 

B5.17.3 Mitigation and Reclamation Issues 

Comment: MR009-016 

A commenter indicated that land use restrictions would be lifted at the end of decommissioning 

and reclamation activities and noted that NRC wrote, “The potential impact to land use would 

diminish as restoration activities were completed and the use of wellfield header houses 

was complete.” 

Response: NRC staff believe there is no apparent contradiction or inconsistency as this 

comment implies. Consistent with the GEIS and the SEIS on this Moore Ranch Project, NRC 

staff indicated impact to land use during the aquifer restoration phase would diminish because 

decommissioning and reclamation activities could be initiated at a particular wellfield as the 

aquifer restoration phase would end. This is the case at uranium ISR projects where the 

operations and restoration of different wellfields are planned to be staggered over time. For the 

Moore Ranch Project, the applicant is planning to operate and restore two separate wellfields 

sequentially. Wellfield 2 would begin to be restored while operations at Wellfield 1 would 

continue (SEIS Section 2.1.1.2.3). Thus, as aquifer restoration activities end at Wellfield 2, 
Appendix B 

B–59 

some decommissioning and restoration activities could be initiated while operations or aquifer 

restoration continue at Wellfield 1. That is why the NRC staff indicated that land use impact 

would diminish, as aquifer restoration activities would be completed. 

Because clarification is provided in this response with information already in the SEIS, no 

changes to the Moore Ranch SEIS were made beyond this response. 

Comment: MR009-090; MR013-007 

Two commenters pointed out that the NRC should use the phrase “unrestricted use” when 

referring to post-reclamation land use. 

Response: The NRC acknowledges the comments, and has added language to SEIS 

Section 2.1.1.1.5 to clarify terms for “unrestricted use.” 

Comment: MR013-016

The commenter states that the draft SEIS structure indicates that aquifer restoration is separate 

from the surface reclamation stage of an ISR facility lifecycle. The commenter seeks 

clarification on whether 10 CFR 40.42, “Expiration and termination of licenses and 

decommissioning of sites and separate buildings or outdoor areas,” can be applied to 

groundwater restoration. The commenter also seeks clarification on the timeline in which a 

decommissioning plan is required to be submitted to the NRC. 

Response: According to the Commission Decision regarding Hydro Resources, Inc. (NRC, 

2000), the NRC staff are required to review a decommissioning plan prior to issuing a license. 

Section 6.5 of NUREG–1569 (NRC, 2003) contains staff guidance for reviewing 

decommissioning plans. Sections 6.1 through 6.4 address the decommissioning/restoration 

activities to be included in the application including groundwater restoration, soils reclamation, 

building decommissioning, and post-decommissioning surveys. Therefore, the intent of the 

aforementioned Commission Decision and NUREG–1569 is to review a decommissioning plan 

that addressed full facility build-out for the life of the facility. 

Unlike other facilities, the precise as-built conditions are unknown prior to operations because 

continued exploration may result in alterations to proposed wellfields. Such alterations affect 

the required wellfield infrastructure. Therefore, a more detailed decommissioning plan would be 

required 12 months prior to decommissioning a facility or a portion thereof. This plan would 

comply with §40.42. Regarding financial assurance, the Commission stated in the Hydro 

Resources, Inc. decision that a surety is not required prior to licensing, but one is required prior 

to operations. 

 

As stated in letters to applicants dated July 7, 2008 (NRC, 2008), the timeliness and 

decommissioning regulations apply to ISRs; therefore, alternate schedules must be submitted if 

restoration/decommissioning would require more than 2 years. Because the timeliness in 

decommissioning rule applies not only to entire facilities but to portions thereof, restoration 

schedules apply to individual wellfields. 

Comment: MR018-033 

A commenter indicated that alternatives to minimize surface disturbance and topsoil removal 

need to be analyzed and pipelines should be located along roads to minimize such disturbance. 
Appendix B 

B–60 

Response: As described in the Moore Ranch SEIS, measures and alternatives were taken into 

account to minimize surface disturbance and soil removal. First, the minimum amount of land 

needed for construction of the plant and related construction was considered and the topsoil to 

be stripped would be stockpiled for reuse following WDEQ Land Quality Division (LQD) 

guidelines. Topsoil and subsoil to be excavated at other areas (e.g., well pad, mud pit, pipeline 

trenches and crossing) would be replaced where removed, whenever possible. Where evident 

and practical, segregation of topsoil and subsoil would be conducted at this site, and the subsoil 

would be replaced first in excavations, followed by topsoil, then regrading and reseeding 

activities. Also, the two wellfields construction would be staggered over several years so soil 

disturbance would be further minimized because it would not occur during the same 

construction season over the whole area of the two wellfields. 

Most major pipelines from header houses to the processing plant would be installed in trenches 

that would not be located along access roads at this site. Further inquiry would be needed to 

determine if cost, more favorable topography, shortest routes, and other factors have prompted 

the applicant to design its major pipeline routes away from the site access roads and if the 

applicant has considered, in this particular situation, alternatives for minimizing surface and soil 

disturbance in locating trenches over undisturbed land away from access roads. 

During the decommissioning phase, all roads at the Moore Ranch ISR with exceptions to be 

determined later by interested parties site, would be reclaimed by removing road surfacing 

materials and culverts, recontouring, and preparing and reseeding the soil. Other areas within 

the permit area such as the wellfields, header houses, and pipeline and well areas would be 

reclaimed by regrading the ground surface to the approximate preconstruction topographic 

contours, reestablishing natural drainage, replacing salvaged soil, and revegetating those areas. 

These examples illustrate that measures and alternatives considered would be implemented 

along with these and other accepted best management practices during the construction and 

decommissioning phases to minimize and mitigate impacts to surface and soil disturbances. 

Because this response addresses the comment by providing confirmation and clarification with 

information already in the SEIS, no changes to the Moore Ranch SEIS were made beyond 

this response. 

B5.17.4 References 

10 CFR Part 40. Code of Federal Regulations, Title 10, Energy, Part 40, “Domestic Licensing of 

Source Material.” 

NRC (U.S. Nuclear Regulatory Commission), 2008. Letter from K. McConnell, Deputy Director, 

U.S. Nuclear Regulatory Commission, to M. Collings, President, Power Resources, Inc. Subject: 

Compliance with 10 CFR 40.42’s Timely Decommissioning Requirements. July 7. ADAMS 

No. ML081480293. 

NRC, 2003. NUREG–1569, “Standard Review Plan for In-Situ Leach Uranium Extraction 

License Applications.” Final Report. Washington, DC: NRC. June. ADAMS 

No. ML032250177. 

NRC, 2000. Commission Memorandum and Order in the Matter of Hydro Resources, Inc. 

CLI–00-08. May 25. 
Appendix B 

B–61 

B5.18 Transportation 

Comment: MR009-032 

In reference to draft SEIS text on page xxi; line 19, a commenter suggested that in addition to 

less yellowcake shipments during the aquifer restoration phase, NRC should add that fewer 

chemical supply shipments would also be realized during this period. 

Response: The NRC staff agree with the commenter that during aquifer restoration there 

would be fewer chemical supply shipments because uranium processing activities would 

diminish during the aquifer restoration phase. The text of the draft SEIS was modified to 

acknowledge a decrease in chemical shipments during aquifer restoration in response to 

this comment. 

Comments: MR009-159, MR009-160 

A commenter noted that Table 4-2 in the draft SEIS contains several values that do not match 

the applicant response to the NRC RAI (Uranium One, 2009). Specifically, the commenter 

indicated the percentage increase in truck traffic at mile sign 118.726 should be 0.3, and not 

0.2; the percentage increase in auto traffic at mile sign 149.24 should be 4.1, not 4.2; the 

percentage increase in auto traffic at mile sign 131.793 should be 6.7 not 7.2; and the 

percentage increase in auto traffic at mile sign 137.12 should be 6.6, and 7.1. The commenter 

noted that similar corrections should be made to draft SEIS Table 4-3 as well. 

Response: The NRC staff checked the information, and found inconsistencies in the 

information that was submitted in the applicant RAI that were corrected in the draft SEIS table. 

Therefore, no changes were made to SEIS Tables 4-2 and 4-3. 

Specifically, based on applicant provided information the percent of auto traffic should be the 

projected auto traffic volume divided by auto traffic count (derived from the reported all vehicle 

count minus the truck count). For the comments regarding mile sign 131.73 and 137.12, the 

values in the applicant spreadsheet do not follow this approach and no information was 

provided to explain why these values would be calculated differently, so this was assumed to be 

an error in the applicant table. Regarding the comment on values for mile sign 118.726, the 

draft SEIS value is not 0.2 as the commenter suggests (the value is 0.3, the value 

recommended by the commenter), so no changes to that value were needed. Regarding the 

comment on values for mile sign 149.24, the value in applicant Table 4.2-1 and the draft SEIS 

table is 3, not 4.1 or 4.2 as the commenter suggests. 

Comment: MR018-011 

One commenter, referring to sections 3.2.2 and 3.3.2, stated that transportation routes would be 

determined by the Wyoming Department of Transportation District Engineer. 

Response: While the comment is not specific, the staff have interpreted the comment as 

referring to sections in the GEIS that describe the affected environment for transportation in the 

Wyoming milling regions. This is because there are no such discussions in the Moore Ranch 

draft SEIS Section 3.2.2 and there is no Section 3.3.2 in that report. While the comment period 

for the GEIS has ended, the staff understand that individual states can specify routes that are 

acceptable to them for hazardous material transportation. For yellowcake shipments that travel 

through multiple states, NRC applicants and their carriers are required to comply with all 
Appendix B 

B–62 

applicable state laws in addition to the applicable transportation regulations of the NRC in 

10 CFR Part 71 and DOT regulations in 49 CFR 171 to 189. Because the comment was not 

specific to the material in the SEIS no changes to the SEIS were made in response to 

the comment. 

Comment: MR018-052; MR018-066 

One commenter suggested the transportation impacts were trivialized because the SEIS did not 

account for hauling all waste generated from all phases including construction, operations, 

restoration, and decommissioning. The commenter also expressed the view (referring to 

executive summary page xvii, in particular) that the volume of contaminated soil that would need 

to be shipped offsite for disposal could be significant. The commenter also indicated the SEIS 

did not provide waste volumes for decommissioning wastes. 

Response: Sections 2.1.1.1.7 and 4.3 of the draft SEIS provided a discussion of the estimated 

magnitude of traffic generated by the proposed action. Section 4.3, in particular, includes 

tabulated estimates of traffic generated for each phase of the project. The traffic estimates in 

Section 4.3 include shipments of both and municipal solid wastes. To respond to the comment, 

the NRC staff reviewed the traffic estimates and found the waste shipment estimates for 

decommissioning low; therefore; more detailed estimates were developed. To develop the 

decommissioning waste shipment estimates, the NRC staff calculated annual and cumulative 

decommissioning waste volumes that were added to Section 2.1.1.1.6.3 (solid waste) and 

decommissioning waste shipment estimates that were added to Section 2.1.1.1.7 

(transportation). The decommissioning waste volumes were based primarily on information 

submitted in the applicant surety estimate (EMC, 2007a), which includes a detailed accounting 

of decommissioning costs, including costs to excavate contaminated soil and ship the soil to a 

licensed facility for disposal as byproduct material. The waste volumes include estimated 

contaminated soil volumes that could be generated in wellfields from leaks and spills during 

operations. Because a significant proportion of the decommissioning waste is from wellfields 

and the wellfields are planned to be decommissioned using a phased approach over a four-year 

period, the highest expected annual average daily waste transportation is expected to occur 

during periods when two wellfield decommissioning actions overlap and the plant facilities 

decommissioning is also underway. The resulting annual volume of wastes equates to about 

one truck shipment per day. As a result of this revision, information in Table 4-4 was updated, 

however, because the magnitude of trucking is still low relative to the exiting road traffic, the 

impact conclusions were not changed. 

Comment: MR018-083 

Referring to draft SEIS page 5-8, a commenter noted that section 5.3 states that transportation 

impacts for solid wastes would be small, however, they requested that impacts be reevaluated 

because the local landfill is expected to be closing in the near future, and waste would have to 

be shipped over a greater distance. 

Response: In response to the comment, the staff reevaluated the circumstances regarding the 

status of the Midwest landfill in Edgerton, Wyoming. While the commenter is correct that the 

landfill is planned to close in 2010, WDEQ permitted the landfill operator to operate as a transfer 

facility that would transfer wastes to the balefill in Casper, Wyoming. As a result, the direct 

transportation impacts would not change, as the solid wastes from the proposed action would 

be shipped to the location that is indicated in the draft SEIS. The transfer operation from 

Edgerton to Casper would have some additional indirect transportation impacts (including 

additional traffic and air emissions), however, at the stated annual waste volumes discussed in 
Appendix B 

B–63 

the SEIS (which, along with related truck shipment estimates, have been updated in response to 

other comments) the contribution to truck traffic from annual shipments of solid waste for landfill 

disposal is expected to be approximately one truck per day or less (see revisions to 

Sections 2.1.1.1.6.3, 2.1.1.1.7, and 4.3 in the final SEIS). This additional amount of traffic on 

roads that serve over 200 trucks per day (Section 4.3) is not expected to represent a significant 

change from current conditions and, therefore, the impact conclusions in the SEIS were not 

changed in response to the comment. 

B5.18.1 References 

10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71. “Packaging and 

Transportation of Radioactive Material.” 

EMC. 2007a. “Application for USNRC Source Material License, Moore Ranch Uranium Project, 

Campbell County, Wyoming, Technical Report.” Casper, Wyoming: Uranium 1 Americas 

Corporation. ADAMS Accession Nos. ML072851222, ML072851258, ML072851259, 

ML072851260, ML072851268, ML072851350, ML072900446. October 2, 2007. 

Uranium One (Uranium One Americas, Inc.), 2009 “Re: Additional Information Requested for 

the Moore Ranch In-Situ Uranium Recovery Project License Application Environmental Report, 

First Set of Responses.” Letter (June 19) from J. Winter to M. Fliegel, NRC. Casper, Wyoming: 

Uranium One Americas, Inc. 

B5.19 Geology and Soils 

B5.19.1 Soil Disturbance Concerns 

Comment: MR009-017 

A commenter noted that topsoil removal in wellfields would affect a much smaller area than 

indicated by a statement in the SEIS Executive Summary. 

Response: Section 2.1.1.1 of the SEIS described that the proposed license area for the Moore 

Ranch Project comprises a surface area of about 2,879 ha [7,110 ac], of which less than 61 ha 

[150 ac] would be affected by the proposed ISR activities. Within the affected area, the main 

activities resulting in topsoil removal would be construction of the processing plant facility and 

development of the wellfields (i.e., drilling of wells, excavation of pipelines, and construction of 

wellfield access roads). In contrast, the Executive Summary of the SEIS stated that these same 

activities would involve the removal of topsoil covering about 61 ha [150 ac]. The NRC staff 

acknowledge that the latter statement is misleading because it implies that all topsoil throughout 

the area would be removed. The text of the Executive Summary has been revised accordingly. 

Comment: MR018-013 

 A commenter noted that the applicant could significantly reduce the overall amount of surface 

disturbance of soils by using portable tanks and closed loop mud systems to contain drilling 

mud and other fluids instead of digging and reclaiming hundreds of mud pits. 

Response: Mud pits are commonly used during drilling activities to control the spread of fluids, 

minimize the potential area of soil contaminated by used drilling fluids and cuttings, and 
Appendix B 

B–64 

enhance evaporation (SEIS Section 4.5.2.1.1). Section 4.4.1.1 of the SEIS identified that mud 

pits would be constructed by removing the topsoil from a designated pit area, placing it in a 

separate location, then excavating the subsoil to the desired depth and depositing it next to the 

pit area. After drilling was complete and the mud pit was no longer needed (typically within 

about 30 days from the initial excavation), the excavated subsoil would be used to fill in the pit, 

and the topsoil would be replaced on top. Given the brief period of time each mud pit is used, 

the limited size of each construction area, and the implementation of best management 

practices to restore and revegetate the topsoil in the filled-in pits, the SEIS concluded that the 

potential environmental impacts to soils from mud pits would be small. The NRC staff 

acknowledge that, as an alternative to excavated mud pits, the use of portable tanks and closed 

loop mud systems is a viable construction technique that would further mitigate the 

environmental impact of soil disturbance in the project area for the large number of wells 

(approximately 850) that the applicant proposes to drill in developing Wellfields 1 and 2. 

However, the difference in technology would not affect the conclusion that the proposed drilling 

activities are expected to have a small impact on soils in the proposed project area. No 

changes have been made to the SEIS beyond this response. 

Comments: MR018-034, MR018-041, MR018-093 

Several commenters noted the importance of vegetation in mitigating the environmental impacts 

caused by disturbed soil. One commenter noted that the amount of disturbed land surface 

should be limited whenever possible because vegetation is the main factor controlling erosion. 

Another commenter stated that disturbed areas should be revegetated as soon as possible with 

saved topsoil and plants suitable for wildlife. A commenter suggested vegetation should be 

mowed rather than bladed to minimize soil disturbance because soils that remain in place may 

be reclaimed more easily than soils that have been removed. 

Response: The NRC staff acknowledge that vegetation is an important factor in controlling 

erosion and maintaining the site ecology. Section 4.4.1 of the SEIS identified that soils within 

the proposed wellfields have a moderate to severe risk from both wind and water erosion. 

Although the practice of mowing vegetation rather than blading to minimize soil disturbance is 

not feasible for the proposed construction activities that require excavation of topsoil, the 

applicant has identified that soil disturbance at the proposed project area would be limited to 

less than about 2 percent of the total license area. Moreover, much of the disturbed soil will be 

localized in the area that includes the construction of the central plant and associated facilities 

(SEIS 2.1.1.1). Most of the remainder of the disturbed soils would result from well drilling 

operations, trenching and burial of pipelines, and construction of secondary access roads. The 

applicant described that disturbed soils would be restored and reclaimed on a scale of weeks or 

months (e.g., drilling sites and open pipeline trenches) or several years (e.g., roads and 

buildings), following best management practices. Topsoil would be segregated and salvaged 

during excavation activities and protected from erosion while it was stockpiled. The applicant 

identified mitigation measures to minimize soil impacts, including reestablishing temporary or 

permanent native vegetation as soon as possible after disturbance in accordance with WDEQ 

guidelines and implementing best management practices to retain sediment within the disturbed 

areas. Because the information used to determine the significance of disturbed soil impacts is 

provided in the SEIS, no changes beyond this response have been made to the SEIS. 
Appendix B 

B–65 

B5.19.2 Soil Impacts from Surface Spills 

Comment: MR017-010 

A commenter was concerned that even small spills may have a cumulatively significant effect on 

soils and groundwater. 

Response: Section 4.4.1.2 of the SEIS described that impacts from surface spills and leaks 

from the proposed Moore Ranch Project would be limited by (i) engineering controls to detect 

pressure changes in the piping system, (ii) a containment system for spills in the central 

processing plant, and (iii) a leak detection system for pond liners. The potential for spills would 

be further mitigated by implementation of onsite standard operating procedures and by the need 

to comply with NRC and WDEQ requirements for spill response and reporting of surface 

releases. For example, Section 4.5.2.1.2.1 of the SEIS noted that contamination surveys would 

be performed after repairing wellfield leaks, and contaminated soils could be immediately 

remediated if concentrations exceeded regulatory requirements or might be cleaned up later 

during decommissioning. Monitoring wells would be in place to provide an extra level of 

surveillance in the wellfield to detect any impacts to the near-surface aquifers from either 

surface spills or casing leaks. Based on these considerations, the long-term impact to soils and 

groundwater from spills would be expected to be SMALL. Because information used to 

determine the significance of the effect of spills on soils and groundwater is included in the 

SEIS, no changes to the SEIS were made beyond this response. 

Comments: MR009-021; MR017-011 

Two commenters noted that spills during construction would not include radioactive materials or 

hazardous waste, except for fuel. One commenter claimed inconsistent information about the 

control and management of spills during construction. 

Response: Neither the SEIS (2009; Section 4.5.2.1.1) nor NUREG–1910 (Section 4.3.4.2.1) 

suggests the potential for radioactive or hazardous toxic spills during the construction phase, 

other than spills of fuels and lubricants from construction equipment. 

The applicant is required to establish a detection monitoring program to protect USDW from 

potential spills and leaks, in compliance with 10 CFR Part 40, Appendix A, Criterion 7A and 

40 CFR 144.54. Once a facility is licensed, the applicant is also required to implement 

corrective action to prevent movement of any spills or leaks into USDW, in compliance with 

40 CFR 144.55. 

The applicant is required to obtain construction and industrial stormwater NPDES permits from 

the State (through WDEQ) prior to commencement of ISR activities (SEIS 2009; Table 1-2). As 

part of this permit, the applicant would implement best management practices, such as 

implementation of a spill prevention and cleanup plan to minimize soil contamination 

(NUREG–1910, Sections 7.4 and 4.3.4.2.1). 

Under these circumstances, cumulative impacts of small spills on soil and near-surface aquifers 

would be small. 

Comments: MR018-048, MR018-051 

A commenter expressed concern about management of contaminated media, such as whether 

soils and other media contaminated by spills and other releases would be transported to solid 

waste disposal or treatment facilities in Wyoming. 
Appendix B 

B–66 

Response: Contaminated media, such as soils, would be managed in the same manner as any 

other waste generated at the site. The NRC noted in Section 4.14 of the SEIS that ISR facilities 

generate radiologically contaminated wastes, including contaminated soils, structures, and 

liquids that are classified as byproduct material. If soils, construction material, piping, or other 

media become contaminated with byproduct material, then that media would be handled, 

stored, and disposed of in the same manner as byproduct material. The NRC requires an ISR 

facility to have an agreement in place with a licensed disposal facility to accept byproduct 

material before ISR operations begin. The existing facilities that are licensed by NRC to accept 

byproduct material for disposal are the Pathfinder-Shirley Basin uranium mill tailings 

impoundment in Mills, Wyoming, and the Rio Algom Ambrosia Lake uranium mill tailings 

impoundments near Grants, New Mexico. Additionally, two sites in Utah and one in Texas are 

licensed by NRC Agreement States to accept byproduct material for disposal. Because the 

information provided in the SEIS about the disposal of contaminated materials generated by the 

proposed Moore Ranch Project is sufficient to support the evaluation of environmental impacts, 

no changes were made to the SEIS in response to this comment. 

B5.19.3 Permanent Change to Rock Formations 

Comment: MR009-018 

A commenter disagreed with the statement in the Executive Summary of the SEIS that ISR 

operations would permanently change the composition of the uranium-bearing rock. 

Response: The ISR operations would dissolve and remove uranium from the target 

sandstones, thereby lowering the uranium concentration in the rock. In this regard, the change 

in composition of the rock is permanent, but the uranium mineralization in the sandstones is 

only a minor component of the total composition of the rock. The NRC staff agree that the 

statement, as written, could convey to interested stakeholders the impression that ISR 

operations could result in significant, large-scale impacts on site geology when no such impacts 

would occur. In response to the comment, the sentence in the Executive Summary of the SEIS 

was revised accordingly. 

B5.19.4 References 

10 CFR Part 40. Appendix A. Code of Federal Regulations, Title 10, Energy, Part 40, 

Appendix A, “Criteria Relating to the Operations of Uranium Mills and to the Disposition of 

Tailings or Wastes Produced by the Extraction or Concentration of Source Material from Ores 

Processed Primarily from their Source Material Content.” 

40 CFR Part 144. Code of Federal Regulations, Title 144, Protection of Environment, Part 144, 

“Underground Injection Control Program.” 

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. June. 
Appendix B 

B–67 

B5.20 Groundwater Resources 

B5.20.1 General Concerns About ISL and Groundwater Contamination 

Comment: MR016-014 

A commenter expressed skepticism about the SEIS’s assurances regarding spills and leaks, 

given ISL history. 

Response: An applicant is required to obtain construction and industrial stormwater (NPDES) 

permits from the State (through WDEQ) prior to commencement of ISR activities. As part of this 

permit, the applicant would implement best management practices, such as a spill prevention 

and cleanup plan to minimize potential impacts on soil and groundwater due to leaks and spills 

on the ground surface (NUREG–1910, Sections 7.4 and 4.3.4.2.1). 

The applicant is required to establish a detection monitoring program to protect USDW from 

potential spills and leaks, in compliance with 10 CFR Part 40, Appendix A, Criterion 7A and 

40 CFR 144.54. Once a facility is licensed, the applicant is also required to implement 

corrective action to prevent movement of any spills or leaks into USDW in compliance with 

40 CFR 144.55. 

To be compliant with these regulations, the applicant would install a leak detection system on 

impoundments for early detection of any potential leaks (NUREG–1910, Section 2.3.2). The 

applicant would conduct mechanical integrity testing of each well to check for leaks or cracks in 

the casing (NUREG–1910, Section 2.4.1.3), in compliance with 40 CFR 146.8. The applicant 

would install meters and control valves in individual well lines to monitor and control flow 

rates and pressures for each well to maintain water balance and to aid in identifying leaks 

(NUREG–1910, Section 2.3.1.1). The applicant would measure and record pipeline pressure to 

monitor for potential leaks and spills that might result from the failure of fittings and valves 

(NUREG–1910; Section 2.4.1.2). The applicant would implement corrective action to prevent 

movement of any spills or leaks into USDW. Under these circumstances, potential impacts on 

groundwater due to spills and leaks would be small to moderate. No changes were made to the 

SEIS beyond the information provided in this response. 

B5.20.2 Importance of Water and Consumptive Water Use 

Comments: MR009-020; MR009-022; MR020-026 

A commenter noted that consumptive water use would be minimal during construction and 

would be limited to water used for well drilling and dust suppression activities. Another 

commenter noted that the assessment of groundwater impacts due to consumptive water use 

during construction by relating the consumptive water use to the existing water supply is not 

helpful. A commenter noted an incorrect statement in the SEIS about water source for the 

consumptive water use during construction. 

Response: Section 4.5.2.1.1 of the SEIS discusses consumptive water use during the 

construction phase of the proposed Moore Ranch Project. The applicant has stated that most 

water used for the proposed Moore Ranch Project would come from a well completed in the 40 

and 50 Sand aquifer at depths of 143 to 180 m [470 to 590 ft] below the ground surface, much 

deeper than the shallower aquifers beneath the site. Consumptive water use during the 

construction phase of the proposed Moore Ranch Project would generally be limited to dust 
Appendix B 

B–68 

control, drilling support, and cement mixing. Impacts from groundwater consumptive use during 

construction would be minor and temporary. 

No changes were made to the SEIS beyond the information provided in this response. 

Comment: MR009-185 

A commenter noted that groundwater consumptive use during aquifer restoration would be 

reduced by 75-80 percent by using reverse osmosis. 

Response: Groundwater consumptive use during aquifer restoration is generally reported to be 

greater than during ISR operations. One reason for increased consumptive use during 

restoration is that no water is reinjected during groundwater sweep. The rate of groundwater 

consumptive use during aquifer restoration would be lowered during the reverse osmosis phase, 

because up to 70 percent of the pumped groundwater treated with reverse osmosis can be 

reinjected into the aquifer. Groundwater consumptive use could be further decreased during the 

reverse osmosis phase if brine concentration is used, in which case up to 99 percent of the 

pumped water could be suitable for reinjection (NUREG–1910, Section 4.3.4.2.3). The SEIS 

text was modified in response to this comment. 

Comments: MR010-003; MR011-003 

A commenter claimed that the large volume of waste water alone will have significant impacts 

on the State. 

Response: During ISR operations, the average production bleed rate at the Moore Ranch 

Project is estimated at a percentage of the maximum injection rate, which would be 114 L/min 

[30 gal/min] (SEIS 2009, Section 2.1.1.2.3). The production bleed is removed from the circuit 

and needs to be disposed. The purpose of the production bleed during ISR operations is to 

maintain a negative water balance to ensure that there is a net inflow of groundwater into the 

wellfield to minimize the potential movement of lixiviant and its associated contaminants out of 

the wellfield (NUREG–1910, Section 2.4.1.2). 

The applicant is required to dispose of production bleed produced during ISR operation and 

restoration while ensuring public health and safety in compliance with 10 CFR Part 40, 

Appendix A 5A for groundwater protection; 5B for secondary groundwater protection; and 5C for 

maximum values for groundwater protection. The applicant proposed deep well disposal of 

production bleed at Moore Ranch and has applied for a UIC Class I injection permit from 

WDEQ, as part of the license application. The permit application is currently under WDEQ 

review. WDEQ would grant the permit only if deep disposal practice is protective of human 

health and the environment. 

B5.20.2.1 Site Characterization 

Comments: MR009-023; MR020-022 

A commenter pointed out inconsistent information on the existence of production wells within 

the project area. Another commenter wanted to know how domestic wells within the permit area 

are to be handled.

Response: There is one domestic well and four stock wells within the license area 

(environmental report, 2007, Section 3.4.1.2). The domestic well within the permit boundary is 

permitted for industrial and domestic uses by Rio Algom Mining Corporation. Although this well 
Appendix B 

B–69 

is permitted for domestic uses, there is currently no occupied residence within the project area 

(SEIS 2009, Section 3.5.2.3.4). Four stock wells within the licensed area are not licensed 

through the State Engineers Office. There is no irrigation groundwater well within the permit 

area (environmental report, 2007, Section 3.4.1.2). 

At Moore Ranch, the uranium-bearing 70 Sand occurs between 30-100 m [100-330 ft] below 

ground surface (environmental report, 2007, Appendix A). There are three domestic water wells 

ranging from 41.7 to 134 5 m [137 to 440 ft] in depth within the 3.2-km [2-mi] radius of the 

Moore Ranch Site (SEIS 2009, Section 3.5.2.3.4), but only one of them lies within the 

permit boundary. 

The applicant is required to obtain an aquifer exemption permit from the State (through WDEQ) 

first. Then, the applicant is required to obtain the final approval from the EPA on the State 

action. If the domestic well is completed in the exempted portion of the ore-bearing aquifer, the 

well cannot be used as a source of drinking water in compliance with 40 CFR Part 146. In this 

case, the domestic well is required to be properly plugged and abandoned prior to 

commencement of ISR operations. Similarly, if industrial or livestock wells are completed in the 

exempted portion of the aquifer, these wells are required to be properly plugged and abandoned 

to avoid potential negative impacts on targeted bleed rates during ISR operations and also to 

minimize potential adverse impacts on the environment. Upon completion of ISR operations, 

the applicant is required to return groundwater quality in the exempted portion of the 

production aquifer to restoration standards, in compliance with 10 CFR Part 40, Appendix A, 

Criterion 5B(5). 

The other two domestic wells are outside the permit boundary, but within the 3.2-km [2-mi] 

radius of the Moore Ranch Site. Therefore, these two domestic wells would be protected 

through the excursion monitoring and remediation in compliance with 40 CFR 144.54 and 

40 CFR 144.55 during ISR operation and post-operation periods (NUREG–1910, 

Sections 2.11.4 and 8.3.1.1). 

Comments: MR016-007; MR016-008

A commenter noted that NRC does not consider requiring an alternative site for the facility, 

altering boundaries of the facility, or extensive testing requirements for detailed hydrological 

characterization of the site for protection of underground drinking water resources. 

Response: ISR operations under NRC regulations are risk-informed and performance based. 

An applicant is required to meet State, NRC, and other Federal agency requirements and 

regulations. This includes, but is not limited to, permit requirements in compliance with 

40 CFR 144.51, monitoring and reporting in compliance with 40 CFR 144.54, implementing 

corrective action to protect USDW in nonexempted portions of the ore-bearing aquifer and 

surrounding aquifers, and meeting restoration standards, in compliance with 10 CFR Part 40, 

Appendix A, Criterion 5B(5). 

If the applicant meets these and other related regulatory requirements, the applicant, under 

NRC regulation, has flexibility in proposing permit boundaries, designing wellfields and 

monitoring well rings, and selection of restoration techniques. NRC is interested in whether the 

applicant is in compliance with regulatory requirements, but it is up to the applicant how to meet 

these regulatory requirements. 
Appendix B 

B–70 

Although the applicant has flexibility with wellfield designs, the applicant is still required to seek 

approval from the State (through WDEQ) when they finalize their locations. At the time the draft 

SEIS was prepared, the applicant had not yet finalized the wellfield designs. Therefore, the 

decision on the acceptability of the locations and wellfield designs for Wellfield 2 (applicable 

also to other wellfields) would be made by WDEQ. The permit boundary is proposed by the 

applicant, but the applicant needs an approval from the State. The decision on the aquifer 

exemption is to be made by WDEQ and EPA. The applicant is not required to propose 

alternative sites, if the applicant is committed to meet NRC, State, and other Federal Agency 

regulations and requirements for the proposed ISR actions. 

The applicant is required to acquire sufficient data to determine hydrogeological characteristics 

of the production aquifers, confining layers, and other important aquifers, in compliance with 

10 CFR 51.45, which requires a description of the affected environment containing sufficient 

data to aid the Commission in its conduct of an independent analysis for evaluating public 

health and safety (including potential impacts on underground water sources) associated with 

the proposed ISR actions. 

At the Moore Ranch Site, the 68 Sand and the 70 Sand coalesce at Wellfield 2, and hence, the 

68 Sand is expected to be designated as an exempted aquifer. However, the final decision on 

the aquifer exemption for the 68 Sand is to be made by WDEQ and the EPA. 

Comments: MR009-079; MR009-273 

A commenter noted that “monitoring well” is not the correct nomenclature for wells from which 

baseline water quality levels are obtained. The commenter wanted to know when the baseline 

water quality, wellfield delineation, and restoration standard, UCLs are to be determined with 

respect to the time for submission of a license application. 

Response: An acceptable set of baseline water quality samples should be taken from all 

wellfield perimeter monitor wells, all upper and lower aquifer monitor wells, and at least one 

production/injection well per acre in each wellfield (NUREG–1569, 5.7.8.3). Therefore, the term 

“monitoring” well is correctly used in the text, but it has been replaced with “baseline monitoring 

well” to improve the clarity. 

The applicant is required to establish baseline water quality prior to the submission of a license 

application (NUREG–1910, Section 2.2). The excursion parameters and UCLs are determined 

based on the baseline water quality sampled from monitoring wells placed in the ore-bearing, 

underlying, and overlying aquifers, when applicable (NUREG–1910, Section 2.4.1.3). 

Therefore, the UCLs should be established prior to ISR operations. The applicant is required to 

collect enough information to generally locate the ore body and understand the natural system 

during the prelicensing period (NUREG–1910; Section 2). After the license is issued, the 

applicant is required to acquire more detailed geologic and hydrologic information as the site to 

be developed is brought into production. Hence, details for wellfield delineation and restoration 

standards would be developed after the license issuance. 

B5.20.2.2 Aquifer Exemption and Baseline Water Quality 

Comments: MR009-025; MR018-016; MR018-020; MR018-023; MR020-014; MR020-032 

A commenter noted an incomplete definition for suitability of an aquifer for deep well disposal 

activities. Another commenter asked to remove the TDS (total dissolved solids) threshold of 
Appendix B 

B–71 

3,000 ppm in assessing the suitability of a aquifer for deep well disposal. Several commenters 

noted that “aquifers with TDS concentration greater than 3,000 ppm are not a potentially 

useable underground source of drinking water” is not a correct statement. 

Response: The applicant is required to obtain a UIC Permit from the State (through WDEQ) for 

deep well disposal within the permit boundary at the Moore Ranch Site. Suitability criteria for an 

aquifer for deep well disposal are provided in the WDEQ Water Quality and Regulations for 

Underground Management of Hazardous Waste (2005, Chapter 8, Section 6). According to 

these regulations, not only water quality of the targeted deep aquifer (groundwater in the 

targeted deep aquifer is required to be at least Class IV; the total dissolved content is to be in 

excess of 10,000 ppm), but also geologic and hydrogeological characteristics of the targeted 

deep aquifer, economic feasibility of water production from the targeted deep aquifer, and 

potential impacts of deep disposal of process fluids on the existing water rights and other 

mineral resources need to be considered for determining suitability of an aquifer for deep 

well disposal. 

As the commenter pointed out, any water with TDS ≤10,000 ppm may be considered as a 

USDW in accordance with 40 CFR 146.3. WDEQ classified groundwater as Class I (suitable for 

domestic uses), if it has a TDS ≤500 ppm; Class II (suitable for agricultural uses), if it has a TDS 

≤2,000 ppm and Class III (suitable for livestock), if it has a TDS ≤5,000 ppm (WDEQ Water 

Quality Rules and Regulations, Table 1). For a deep aquifer to be considered for deep disposal, 

groundwater in this aquifer should meet Class IV use with a TDS in excess of 10,000 ppm 

(WDEQ’s Water Quality Rules and Regulations; Sections 4 and 6). Several updates were made 

throughout the SEIS text in response to these comments. 

Comments: MR009-174; MR009-178; MR020-20; MR020-021; MR020-027; MR020-032 

A commenter requested clarification on who would issue an aquifer exemption, the State of 

Wyoming or EPA. Another commenter stated that the Moore Ranch SEIS did not accurately 

define an aquifer exemption and that the definition only covered part of the criteria for an aquifer 

exemption. The commenter noted that exempting an aquifer from being a USDW does not 

guarantee that it would not, in the future, be used as a drinking water source, unless there is a 

State law to this effect. The commenter also noted that the draft SEIS incorrectly restated the 

definition of an USDW, as defined in 40 CFR 144.3. 

Response: The EPA issues the aquifer exemption status. The EPA criteria for an aquifer 

exemption is found in 40 CFR 146.4. The regulation states that an aquifer, or a portion thereof, 

may be determined to be an “exempted aquifer,” if it meets the following criteria: (a) it does not 

currently serve as a source of drinking water; and (b) it cannot now and would not in the future 

serve as a source of drinking water; or (c) the TDS content of the groundwater is more than 

3,000 and less than 10,000mg/l, and it is not reasonably expected to supply a public water 

system. A USDW , as defined in 40 CFR 144.3, is an aquifer or its portion which (1) supplies 

any public water system; or (2) contains a sufficient quantity of groundwater to supply a public 

water system; and (i) currently supplies drinking water for human consumption; or (ii) contains 

fewer than 10,000 mg/l TDS; and (iii) is not an exempted aquifer. The Federal regulation of 

exempt aquifers is enforced by EPA, who has the responsibility to ensure that an exempted 

aquifer is not used as a source of drinking water. Section 4.5.2.1.2.3 of the final SEIS was 

revised to reflect this regulation. 
Appendix B 

B–72 

B5.20.2.3 Control of Operational Impacts, Excursion of ISL Solutions, and History 

Comments: MR009-028; MR009-076; MR009-077; MR009-176 

A commenter asked for inclusion of a discussion on the potential for vertical excursions due to 

well casing failure. The commenter noted that an increase in flow rate is not effective for 

recovering vertical excursions. Regarding excursion monitoring, the commenter noted that 

monthly sampling instead of biweekly sampling would be required to detect excursions. The 

commenter suggested that excursions would be less likely during restorations than 

during operations. 

Response: Poor well integrity involving a cracked well casing or leaking joints between casing 

sections could cause vertical excursions (NUREG–1910, Section 2.4.1.3). The applicant is 

required to take preventative measures against vertical excursions prior to operations, including 

well integrity tests (NUREG–1910, Section 1). The applicant is required to conduct mechanical 

integrity testing of each well to check for leaks or cracks in the casing, in compliance with 

40 CFR 146.8. 

An applicant typically recovers horizontal excursion by adjusting the flow rates of nearby 

injection and production wells to increase process bleed in the area of excursion. On the other 

hand, a applicant typically recovers vertical excursions by adjusting injection and production 

flow rates in the area of excursion and pump directly from the affected monitoring wells or from 

other wells drilled for that purpose (NUREG–1910; Section 2.4.1.4). Therefore, adjusting the 

flow rates of the nearby injection and production wells to increase in process bleed in the area 

of excursion is not necessarily effective to recover vertical excursions, and vertical excursion, 

are often more difficult to recover than horizontal excursions (NUREG–1910, Sections 2.4.1.4 

and 2.11.4). 

In accordance with NUREG–1910 and NUREG–1569, applicants are required to sample 

monitoring wells at least biweekly during well operations to detect potential excursions. 

Because (i) groundwater restoration takes place when a wellfield is no longer used to produce 

uranium, and (ii) the applicant is required to restore groundwater quality in the production 

aquifer to NRC-approved restoration standards during aquifer restoration in compliance with 

10 CFR Part 40, Appendix A, Criterion 5B(5), excursions during restoration would be less likely 

than during ISR operations. 

Comments: MR015-036; MR020-018; MR020-031 

A commenter noted that the SEIS concluded that drinking water impacts would be small, if all 

preventive measures are in place. The commenter noted that the SEIS did not address 

potential impacts to groundwater if there was an excursion during operation, restoration, and 

postoperation. The commenter questioned the conclusion that no environmental impacts 

occurred because of historical excursions. Another commenter asked for a thorough analysis of 

the potential environmental impacts of excursions on groundwater restoration estimates. 

Response: Potential impacts to nonexempted aquifers at the ISR site would depend on the 

frequency and longevity of excursions, if they were to occur. The applicant must establish and 

maintain groundwater monitoring programs for early detection of vertical and horizontal 

excursions; have procedures to analyze excursions, determine how to control and remediate 

excursions to ensure public health and safety, and report it to NRC during operation, restoration, 

and postrestoration periods (NUREG–1910, Section 2.4.1.4; NUREG–1569, Section 5.7.8.3). 
Appendix B 

B–73 

The applicant is required to establish an excursion monitoring system and corrective action 

plans in compliance with 10 CFR Part 40, Appendix A Criterion 7A; 40 CFR 144.54, and 

40 CFR 144.55. 

As noted in NUREG–1910, the applicant would acquire more geologic and hydrogeological 

information during construction and operations for determining the locations of production, 

injection, and monitoring wells in proposed wellfields at the Moore Ranch Site. Once the exact 

location of production, injection, and monitoring wells is finalized and additional hydrogeological 

data are acquired, more site-specific assessments for potential impacts of excursions on 

groundwater resources can be made. However, at the time the SEIS was prepared, the 

applicant had not finalized wellfield designs (Uranium One, 2009), which would require approval 

from WDEQ. 

Section 2.11 of the GEIS discusses historical operation of ISR uranium milling facilities which 

includes a discussion of excursions in Section 2.11.4. In addition, NRC staff evaluated 

groundwater impacts from three previously licensed in-situ uranium recovery sites in 2009, in 

response to direction from the Commission. The staff acknowledged that certain parameters 

can require a long time to reach preextraction concentration levels and that in most cases 

excursions were reported and controlled. The staff concluded that in all cases there was no 

threat posed to human health or to the surrounding aquifers. 

Excursions from the exempted aquifer that migrate into nonexempted aquifers would result in an 

environmental impact during ISR operation and restoration. The impacts would be SMALL if the 

excursions are temporary and recoverable. The applicant would establish and maintain 

excursion monitoring, control, and remediation (corrective action) programs at the ISR site. 

With respect to restoration cost estimates for excursions, the applicant is required to return 

groundwater quality in the exempted production aquifer to the NRC-approved restoration 

standards in compliance with 10 CFR Part 40, Appendix A, Table 5C. The applicant is required 

to provide financial sureties, as part of license application, to cover costs associated with 

restoration and remediation at the ISR facility, in compliance with 10 CFR Part 40, Appendix A, 

Criterion 9. NRC reviews financial sureties annually and additional costs associated with 

potential restoration delays due to excursions are covered by revised financial sureties, which 

require NRC approval. Additional information on financial sureties are provided in Section B5.15 

of this comment-response appendix, and Section 2.1.1.1.8 of the final SEIS, discussing financial 

surety, was revised in response to public comments. 

Comments: MR016-009, MR012-023 

Two commenters noted that ISR mining would be in an unconfined aquifer, which is a significant 

departure from past practice. 

Response: The uranium-bearing proposed production aquifer (the 70 Sand) is not completely 

saturated in most parts of the Moore Ranch Site (SEIS 2009; Section 3.5.2.3). As the 

commenter pointed out, the unconfined nature of the uranium-bearing production aquifer at the 

Moore Ranch ISR Site is different from typical, confined uranium-bearing production aquifers 

(NUREG-1910, Section 2.1.2). However, permit requirements as part of a license application, 

implementation of a closed circuit between production and injection wells during ISR operation, 

enforced groundwater protection and remediation standards, and the requirements for excursion 

monitoring and control practice are similar for confined and unconfined ore-bearing aquifers. No 

changes to the SEIS were made beyond the information provided in this response. 
Appendix B 

B–74 

Comments: MR016-011; MR016-012; MR020-028 

A commenter noted that potential impacts due to consumptive water use during ISR operation 

to nearby wells that are in hydraulic connection with the production zone need to be included in 

the discussion on page. 4-27 of the SEIS. Another commenter questioned “small” potential 

impacts on groundwater during ISR operations, given that the applicant expects that miles of 

drawdown be needed to recover excursions. 

Response: Potential impacts to nearby wells completed in the 68-70 Sand (underlying aquifer), 

the 70 Sand (production aquifer), and 70-72 Sand (overlying aquifer) within 3.2 km [2 mi] of the 

Moore Ranch ISR facility were evaluated on page 4-27 in the SEIS (2009; pages 4-27 and 

4-28). The overlying 72 Sand is separated from the production aquifer through an upper 

Mudstone, E Coal, and Lower Mudstone confining unit. The underlying 68 Sand is separated 

from the production zone through a lower confining unit that consists of sequence clays and 

silts; although, as noted in the previous comments, the 68 Sand and the 70 Sand coalesce 

(environmental report 2007, 3.4.3.2). In the areas where the 68 and the 70 Sand coalesce, the 

applicant committed to not install any production wells in the 68 Sand and assumed in their 

analysis that drawdown in both the 68 and 70 Sand would be identical, which is conservative (in 

general, if there is no production well in the 68 Sand, drawdown in the 68 Sand would be 

smaller than in the 70 Sand). According to the applicant numerical simulation results, expected 

drawdown near the permit boundaries at the end of ISR operation would be on the order of 

meters, if the bleed production is maintained at less than 3 percent during production. 

Therefore, based on this conservative analysis, miles of drawdown would not be expected, even 

if the bleed rate was increased from 3 percent in the event of an excursion. No changes were 

made to the SEIS beyond the information provided in this response. 

Comments: MR009-182; MR012-023; MR012-024; MR012-025; MR012-029 MR016-010 

A commenter stated that the NRC new approach to analyzing impacts from ISR operations in an 

unconfined aquifer was insufficient. The commenter asserted that NRC did not meaningfully 

evaluate potential excursions from the 70 Sand to the underlying 68 Sand at the Moore Ranch 

site and instead chose to include in the production zone where the 68 and 70 Sands coalesce. 

The commenter stated that by fiat NRC evaded evaluating the potential impacts to the 

underlying, good quality aquifer and the alternatives and mitigation measures that would follow 

from such an analysis. Another commenter noted that in the area where the 68 and 70 Sands 

coalesce, the 68 Sand would also need to be designated as an exempt aquifer. 

Response: The NRC staff initially rely on applicant information as well as information and 

conclusions from a separate NRC detailed safety review, which is documented in the NRC 

environmental review. The Moore Ranch SEIS described the expected environmental impacts 

arising from ISR operations in the “70 Sand” unconfined aquifer. The commenter is correct that 

the SEIS did not include a comprehensive technical analysis of ISR operations in the “70 Sand” 

unconfined aquifer. This analysis can instead be found in the NRC SER of the Moore Ranch 

Technical Application. The SER includes an extensive review of ISR operations in the “70 Sand” 

unconfined aquifer, which were provided in the technical application. Specifically, NRC 

reviewed the field tests provided by the applicant to demonstrate the field behavior of the 

“70 Sand” unconfined aquifer. NRC also reviewed the applicant comprehensive groundwater 

flow model, which included software specifically designed for unconfined aquifers to simulate 

flow behavior in the ISR production and restoration phases at Moore Ranch. Finally, NRC 

reviewed an applicant excursion scenario simulation provided to demonstrate excursion 

behavior and excursion capture in the “70 Sand” unconfined aquifer. The applicant will also be 
Appendix B 

B–75 

required to provide NRC with its Wellfield Hydrologic Test Data package to verify the field 

behavior of the 70 Sand aquifer and to support the results of the groundwater flow simulations. 

Operations in the 70 Sand unconfined aquifer would not commence until NRC has reviewed and 

approved this wellfield package to ensure the operations in the Moore Ranch 70 Sand 

unconfined aquifer can be conducted safely and minimize any expected environmental impacts. 

The commenter is correct that the production zone in Wellfield 2 would include the 70 and 

68 Sand in the regions where the “70 underlying shale” is thin or absent. In those regions 

where the 70 and 68 Sand coalesce, the 68 Sand will be considered part of the production zone 

and would be exempted. Therefore, any movement or recovery fluids into the exempt zone of 

the 68 Sand would not be considered an excursion. The applicant decided to combine these 

aquifers into one production zone, not NRC. NRC notes the groundwater quality of the 

“68 Sand,” as measured by the applicant, exceeded the EPA MCL drinking water standards for 

uranium Ra 226, gross alpha and selenium. NRC notes that the applicant would be required to 

obtain exempt aquifer status for the “68 Sand” from EPA before it may be treated as part of the 

production zone. Therefore, NRC concludes the potential environmental impact to the “68 

Sand” where it coalesces with the “70 Sand” in Wellfield 2 has been adequately addressed. No 

changes were made to the final SEIS beyond the information provided in this response. 

Comment: MR020-031

A commenter noted that the Moore Ranch SEIS stated that NRC staff had reviewed reports of 

60 excursions at 3 NRC licensed ISR facilities and concluded that none resulted in 

environmental impacts. The commenter contended that movement of a contaminant into an 

USDW is an environmental impact and requested that the final SEIS explain how the NRC 

defines environmental impacts in these cases. 

Response: The commenter is correct that movement of a contaminant into a USDW may 

constitute an environmental impact. However, NRC does not define an excursion as 

contamination that moves into a USDW. An excursion is defined as an event where a 

monitoring well in overlying, underlying, or perimeter well ring detects an increase in specific 

water quality indicators, usually chloride, alkalinity and conductivity, which may signal that fluids 

are moving out from the wellfield. These specific water quality parameters are used because 

they are present in high concentrations in the ISR production fluids and are “conservative” in the 

sense that they move at roughly the same rate as the groundwater flow and are not significantly 

attenuated by adsorption or reduced by other factors. Therefore, they serve as early indicators 

of imbalance in the wellfield flow system to notify operators to take appropriate actions. The 

perimeter monitoring wells are located in a buffer region surrounding the wellfield within the 

exempted portion of the aquifer. These wells are specifically located in this buffer zone to 

detect and correct an excursion before it reaches a USDW. The overlying and underlying 

monitoring wells are located in aquifers that are separated from the ore zone by aquitards, 

which NRC has determined have sufficient thickness and integrity to prevent an excursion. 

However, in all cases, any excursion that lasts longer than 60 days is required to undergo 

corrective action to meet the drinking water protection standards in 10 CFR Part 40, Appendix A 

5(B) 5. To date, no excursions from an NRC-licensed ISR facility has contaminated a USDW. 

No changes were made to the SEIS beyond the information provided in this response. 

B5.20.2.4 Exploratory Drill Wells, Abandoned Wells, and Old Mines 

Comments: MR016-016; MR018-026 

Two commenters noted that the applicant would be required to take preventive measures for 

inadequately plugged oil wells within the radius of influence of the injection activities. Similarly, 
Appendix B 

B–76 

another commenter noted that all properly plugged or unplugged drill holes need to be 

identified; and those that are not properly abandoned need to be adequately plugged and 

abandoned before ISR operations commence. 

Response: As part of site characterization, the applicant is required to identify locations of 

abandoned wells, including depth, type of use, condition of closing, plugging procedure, and 

date of completion within the site and within 0.4 km [0.25 mi] of the wellfield boundary in 

compliance with 10 CFR 51.45, which requires a description of the affected environment 

containing sufficient data to aid the Commission in its conduct of an independent analysis 

[NUREG–1569, Section 2.2.3.1(e)]. 

The applicant discussed abandoned drill holes at the Moore Ranch site in the environmental 

report (2007, Section 3.3.4). From the 1970s to mid-1980s, nearly 2,700 rotary drill holes and 

130 core holes were completed by Conoco. Drill holes completed by Conoco were reported to 

be plugged in accordance with Wyoming Statute WS 35-11-401,in effect at the time, except for 

several drill holes that required additional abandonment work, according to WDEQ-LQD 

District III personnel. 

The applicant noted that EMC conducted verification drilling in late 2006 totaling 157 

holes and 20 monitor wells. All drill holes were plugged in accordance with Wyoming 

Statute WS35–11–401, as documented. The applicant provided a list of all drill holes known 

to the applicant in environmental report (2007, Table 3.3-1) and a location map of these known 

drill holes in the environmental report (2007, Figure 3.3-13). 

The applicant did not report any abandoned oil wells within the Moore Ranch site. The NRC 

staff are not aware of any abandoned oil wells within the Moore Ranch site. The closest oil 

production to the Moore Ranch Site is in the Pine Tree field within 1.6 km [1 mi] to the 

west of the Moore Ranch Permit area is primarily from the Shannon Formation at depths of 

3,050–3,350 m [10,000 to 11,000 ft]. 

The applicant is required to submit information about abandoned drill and exploratory wells, dry 

holes, and wells within the Moore Ranch Site, as part of the UIC permit application in 

compliance with 40 CFR Parts 144 and 146. Therefore, WDEQ would also evaluate the 

applicant survey and findings for abandoned drill and exploratory wells and dry holes prior to 

commencement of ISR operations. 

B5.20.3 Aquifer Restoration and Decommissioning: Methods and 

Operational Experience 

Comment: MR009-084 

A commenter noted an incorrect restoration process step. 

Response: Groundwater recovered from the restoration field is passed through an ion 

exchange (IX) unit prior to reverse osmosis and electro dialysis reversal units. Reverse 

osmosis electro dialysis reversal units, as down-end treatment units, are used to separate clean 

water (permeate) from brine. A correction has been made in the SEIS. 
Appendix B 

B–77 

Comments: MR009-086; MR015-032 

A commenter noted that bioremediation suggested previously as a remediation process has 

been removed from SEIS (2009). Another commenter noted that the draft SEIS should evaluate 

alternative methods that could be used to meet restoration goals. 

Response: ISR actions under NRC regulations are risk-informed and performance-based. 

Therefore, the applicant has flexibility in choosing and implementing proper remediation 

techniques to achieve NRC-approved restoration standards in compliance with 10 CFR Part 40, 

Appendix A, Criterion 5B(5). No additional changes were made to the SEIS in response to 

these comments. 

Comments: MR009-087; MR015-033 

A commenter asked whether a 6-month stability period would be sufficient for long stabilization 

at the ISR facility. Another commenter noted that the stability monitoring period has been 

extended to a minimum of 12 months. 

Response: The applicant confirmed in their license application revisions that they extended the 

stability monitoring program to a minimum of 12 month. The SEIS has been revised to include 

this correction. 

Comments: MR009-081; MR010-004; MR011-004; MR012-017; MR012-018; MR012-041; 

MR012-042; MR012-045; MR013-011; MR015-031; MR016-013; MR016-014; MR016-015; 

MR017-020; MR017-022; MR017-004 

Several commenters raised concerns about the NRC assessments for operational impacts of 

ISR activities on groundwater by noting that the assessments are not consistent with the 

existing data. A few commenters asked for clarification on groundwater restoration standards. 

A commenter noted that groundwater restorations are difficult at best at ISR sites. A 

commenter pointed out that for cases in which baseline levels are not recovered after 

restoration, potential effects on surrounding USDW are not evaluated in the SEIS. Another 

commenter expressed disbelief on proper containment of contamination after aquifer restoration 

allegedly based on historical data. A commenter asked for additional information on the 

historical analysis of aquifer restoration at ISR sites. Several commenters disagreed with the 

NRC assessment that impacts on groundwater would be small and temporary after restoration, 

and noted that aquifers used for ISR operations have never been restored to 

baseline/preextraction conditions. A commenter claimed that baseline sampling procedure is 

biased and inflated and there is no successful groundwater restoration to preoperational 

baseline levels at ISR sites. 

Response: Under the Federal Underground Injection Control (UIC) program, the ISR 

production aquifer must receive an exemption from EPA, that the aquifer, or part of the 

exempted aquifer, is not now, and would never be a source of drinking water and, thus, would 

no longer be protected under the Safe Drinking Water Act (SDWA). Hence, groundwater in 

exempted aquifers cannot be considered as a source of drinking water supply even after 

restoration. 

NRC licensees are required to return water quality parameters to the standards in 10 CFR Part 

40, Appendix A, Criterion 5B(5). As stated in the regulations: “5B(5)—At the point of 

compliance, the concentration of a hazardous constituent must not exceed—(a) The 

Commission approved background concentration of that constituent in the groundwater; (b) The 
Appendix B 

B–78 

respective value given in the table in paragraph 5C if the constituent is listed in the table and if 

the background level of the constituent is below the value listed; or (c) An alternate 

concentration limit is established by the Commission.” 

To establish the preoperational nonradiological and radiological groundwater baselines within 

the proposed permit boundaries and adjacent properties, to collect samples over a period of at 

least 1 year, from at least four sets of groundwater samples with sufficiently spaced time. An 

acceptable set of samples should include all wellfield perimeter monitor wells, all lower and 

upper aquifer monitor wells, and at least one production/injection well per acre in each wellfield. 

Baseline samples are collected with a sampling density of not less than one for [16,187 m2

[4 ac]. Because the applicant is required to collect baseline water quality before ISR operations 

begin, the baseline sampling procedure outlined previously would provide adequately unbiased 

preoperational groundwater quality measures at the proposed ISR site. 

These standards are implemented during aquifer restoration to ensure protection of public 

health and safety in compliance with 10 CFR Part 40, Appendix A, Criterion 5B(5) for protection 

of groundwater and USDW in surrounding nonexempted aquifers. The applicant is required to 

provide financial sureties to cover planned and delayed restoration costs in compliance with 10 

CFR Part 40, Appendix A, Criterion 9. The NRC reviews financial sureties annually. Although 

the goal of groundwater restoration is meeting baseline values or MCLs whichever is greater, it 

is recognized under the EPA standards and NRC regulations that ACLs can be used in 

circumstances where achieving those standards is impracticable or impossible. ACLs must 

present no substantial present or potential hazard to human health or the environment. A 

discussion of the NRC requirements for application, review and establishment of a site-specific 

ACL is presented in Appendix C. 

All ISR restorations completed under the NRC regulations have met restoration standards in 

compliance with their licenses. Examples of successfully completed groundwater restorations 

or delayed restoration activities are provided in NUREG–1910, Section 2.11.5. Licensees are 

also required to establish routine regional aquifer monitoring programs as a license condition. 

The data from those monitoring programs do not show impacts to USDWs attributable to an ISR 

Facility (NRC 2009). 

B5.20.4 Miscellaneous Groundwater Comments 

Comments: MR009-062; MR009-096; MR018-018; MR018-024; MR020-023; MR020-033; 

MR018-027; MR018-028 

A commenter asked that a sentence be included in the SEIS stating two Class I wells would be 

required in the Lance Formation for deep disposal of process fluids. Another commenter asked 

to remove the information on (i) depths to targeted deep aquifers for deep well disposal, and 

(ii) injection capacity to these aquifers. The commenter marked some corrections on the depth 

to the Lance Formation and the number of injection wells proposed in the Lance Formation for 

deep well disposal. Another commenter noted that the suitability of Lance Formation for deep 

well disposal was not supported by evidence in the SEIS. A commenter asked for an 

explanation of why the Teapot-Tackla Parkman and Lance Formations are considered as a 

USDW, if Class I wells are to be installed below these formations for deep well disposal. 

Another commenter noted that deep well disposal activities should not affect coal production 

near the ISR site. Another commenter noted the existing groundwater wells within the Moore 

Ranch area are usually shallower than the CBM wells, and they would not likely be impacted by 
Appendix B 

B–79 

deep disposal. The commenter also noted that oil field water supply wells are not likely be 

affected by deep well disposal. 

Response: The final SEIS has been revised to acknowledge that from two to four Class I UIC 

wells could be drilled at the proposed Moore Ranch Project for disposal of liquid effluent as 

discussed in Section 4.5.2.1.2.3. The WDEQ will evaluate the suitability of the formations 

proposed for deep well injection and would only grant a UIC permit if the applicant can 

demonstrate that liquid effluent could be safely isolated in a deep aquifer. The State of 

Wyoming is currently reviewing a permit application for up to four Class I disposal wells at the 

proposed Moore Ranch Project as noted in Table 1-2 of this SEIS. The cumulative impacts 

analysis in the SEIS considers other past, present, and reasonably foreseeable activities 

affecting groundwater resources and includes discussion of CBM and oil and gas operations as 

noted by the commenters. 

Comments: MR009-180; MR015-030; MR020-029; MR020-030; MR015-034 

Several commenters raised concerns about how NRC determines ACLs and how ACLs assure 

public health and safety. A commenter asked for a proper definition of an ACL. Commenters 

want to know at what point NRC would make the decision to set ACLs and what public health 

and safety standards NRC uses to approve or reject ACLs. Other commenters questioned the 

accuracy of the assessment of a SMALL groundwater impact during aquifer restoration because 

of potentials for permanent degradation to groundwater quality and lack of information on how 

often NRC approves ACLs. 

Response: NRC revised the draft SEIS to state that licensees and applicants must commit to 

achieve the groundwater quality standards in 10 CFR Part 40, Appendix A, Criterion 5B (5) for 

all restored aquifers. These standards state the concentration of a hazardous constituent must 

not exceed (a) the Commission approved background concentration of that constituent in 

groundwater; (b) the respective value in Table 5C if the constituent is listed in the table and if 

the background level of the constituent is below the value listed or; (c) an alternative 

concentration limit established by the Commission. An ACL is not a primary restoration goal 

and will only be considered after a license has demonstrated that primary restoration goals are 

not practically achievable at a specific site. ACLs that present no significant hazard may be 

proposed by the licensees for Commission consideration. The Commission may establish a 

site-specific ACL for a hazardous constituent as provided in 5B(5) if it finds that the proposed 

limit is as low as reasonably achievable, after considering practicable corrective actions, and 

that the constituent will not pose a substantial present or potential hazard to human health or 

the environment as long as the ACL is not exceeded. Appendix C of the SEIS discusses the 

NRC requirements for application, review and establishment of a site-specific ACL. In addition, 

ACL application review procedures for NRC staff are available in the following documents: 

January 1996 Staff Technical Position: Alternate Concentration Limits for Title II Uranium Mills, 

NUREG–1620 and NUREG–1724. 

Comments: MR009-181; MR009-184; MR009-275; MR009-288 

A commenter claimed that the WDEQ requires a hydraulic connection between monitoring and 

production wells, but no specific NRC guidance is required. The commenter emphasized that 

monitoring wells are not within the production zone. The commenter also noted that at Moore 

Ranch, monitoring wells are to be placed in the 60 Sand only in areas where the 70 Sand and 

the 68 Sand coalesce. 
Appendix B 

B–80 

Response: The requirement for the hydraulic connection between the monitoring wells and the 

production wells is addressed in NUREG–1569, Section 5.7.8.1(4) of, which is NRC guidance. 

Ore zone monitoring wells are placed to detect any lixiviant moving out of the production zone. 

Thus, ore zone monitoring wells are placed outside the production zone to detect horizontal 

excursions (NUREG–1910, Sections 2.11.4 and 8.3.1.1, Figure 2.3-1). 

Monitoring wells below the ore zone are required within the production zone for early detection 

of vertical excursions. In the areas of Wellfield 2 where a confining unit exists between the 

70 Sand and the 68 Sand, the applicant would place monitoring wells in the 68 sand at a 

spacing of 1 per 4 acres (RAI Response to 5.12). Although the applicant has not finalized their 

wellfield designs, which would require WDEQ approval, the applicant noted that monitoring 

wells would be placed at a spacing of 1 well per 4 acres in the underlying 60 Sand in the areas 

where the 70 and 68 sand coalesce. 

B5.20.5 References 

10 CFR Part 40. Appendix A. Code of Federal Regulations, Title 10, Energy, Part 40, Appendix 

A, “Criteria Relating to the Operations of Uranium Mills and to the Disposition of Tailings or 

Wastes Produced by the Extraction or Concentration of Source Material from Ores Processed 

Primarily from their Source Material Content.” 

40 CFR Part 144. Code of Federal Regulations, Title 144, Protection of Environment, Part 144, 

“Underground Injection Control Program.” 

40 CFR Part 146. Code of Federal Regulations, Title 40, Protection of Environment. Part 146, 

“Underground Injection Control Program: Criteria and Standards.”

EMC (Energy Metal Corporation US), 2007a. Environmental Report. Application for USNRC 

Source Material License Moore Ranch Uranium Project Campbell County, Wyoming. 

EMC, 2007b. Technical Report. Application for USNRC Source Material License Moore Ranch 

Uranium Project Campbell County, Wyoming. 

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

NRC, 2009. “Staff Assessment of Groundwater Impacts from Previously Licensed In-Situ 

Uranium Recovery Facilities.” Memorandum from C. Miller to Chairman Jaczko, et al. ADAMS 

Accession No. ML091770402. July 10. 

NRC, 2003. NUREG–1569, “Standard Review Plan for In-Situ Leach Uranium Extraction 

License Applications.” Final Report. Washington, DC: NRC. June. ADAMS 

No. ML032250177. 

Uranium One (Uranium One Americas), 2009. RAI Response to technical report 7.2.9.2.2 and 

3.1.3. Surface Water Impacts. ML 092450317. Received on August 27, 2009. 

Uranium One, 2008. RAI Response to 5.12. Groundwater and Surface Water Monitoring 

Programs. ML 082060527. Received on July 11, 2008. 
Appendix B 

B–81 

B5.21 Surface Water Resources 

B5.21.1 Impacts to Surface Drainages and Surface Waters 

Comments: MR009-019; MR009-047; MR009-167; MR012-037; MR018-031; MR018-032; 

MR018-038; MR018-039; MR018-040; MR018-047 

A commenter noted that potential impacts to surface water resources in the Wyoming East 

Uranium Milling Region are rated as SMALL. The commenter noted that because waste water 

would be disposed into a deep aquifer during ISR operation, there would not be any surface 

water impacts during operations and restoration. The commenter also noted that water pumped 

during the placement of production wells in intermittent channels would not be released directly 

into the channel. 

On the other hand, several commenters raised concerns about surface water impacts due to 

ISR activities. A commenter noted that NRC disregarded close proximity of mining operations to 

surface water features at Moore Ranch. A commenter suggested that pipelines should be 

routed around wetlands or be constructed perpendicular to wetland features to minimize impact. 

Another commenter noted that wells placed in ephemeral channels may lead to increased 

erosion, increased risk of breached structures, and potentials for releases of processed fluids to 

ephemeral channels. The commenter also noted that runoff and erosion from roads, culverts, 

and ephemeral channels could cause accelerated channel alterations. 

Response: The SEIS concluded that the potential impacts of ISR activities on surface waters in 

the Wyoming East Uranium Milling Region would be SMALL (NRC 2009, Section 4.3.4.1). The 

applicant analyzed and reported natural and man-made surface water features at and near 

the proposed Moore Ranch Project and assessed the potential site-specific impacts from 

ISR activities. 

The applicant is required to obtain industrial and construction NPDES permits from WDEQ as 

part of license application (SEIS 2009, Table 1-2) for the protection of surface water 

and wetlands). 

These permits involve best management practices for spill prevention and control and disposal 

of water produced during placement of wells at the ISR site during construction. Moreover, the 

applicant would install meters and control valves in individual well lines to monitor and control 

flow rates and pressures for each well to maintain water balance and to aid in identifying leaks 

(NUREG–1910, Section 2.3.1.1). The applicant would also measure and record pipeline 

pressure to monitor for potential leaks and spills that might result from the failure of fittings and 

valves (NUREG–191, Sections 2.4.1.2). 

If the UIC permit is granted WDEQ, then liquid effluent produced during ISR operations would 

be disposed into UIC-permitted deep aquifers. Thre would be no impact to surface water from 

normal operations. Potential impacts to surface waters would occur from accidental spills or 

leaks. The applicant noted that installation of monitor, injection, and production wells in main 

ephemeral stream channels would be avoided, if possible. The applicant would seek approval 

from WDEQ for the final wellfield layouts (SEIS 2009, Section 6.3.1.2). The location, 

distribution, and alignment of pipeline networks would be associated with the exact position of 

injection and production wells in each wellfield. The location, design, and distribution of pipeline 

on and near the wetlands and intermitent channels within the permit boundary comply with the 
Appendix B 

B–82 

WDEQ construction permit. If a well were to be installed in an intermittent channel, the 

applicant would install the well within the high water marks with adequate structural wellhead 

protection (e.g., concrete berms or reinforced steel/concrete well covers) to protect the well 

during potential flood conditions. The applicant would reseed disturbed areas during 

construction soon after wellfields are constructed to minimize the risk of potential for erosion. 

The applicant would use diversion ditches and culverts to prevent excessive erosion and to 

control runoff. In areas where runoff has concentrated, the applicant has committed to use 

energy dissipaters to slow the flow of runoff to minimize erosion and sediment loading in surface 

water runoff. The applicant would implement best management practices to monitor and reduce 

erosion impacts in accordance with storm water management plans developed as part of 

itsWYPDES permit. The applicant is committed to implement soil erosion mitigation in 

accordance with WDEQ Rules and Regulations, Chapter 3, Environmental Protection 

Performance Standards and to construct roads to minimize erosion through practices such as 

surfacing with a gravel road base, constructing stream crossings at right angles with adequate 

embankment protection and culvert installation, and providing adequate road drainage with 

runoff control structures and revegetation. 

Comment: MR012-073 

A commenter noted that NRC did not address how the impacts of surface water contamination 

and erosion due to livestock grazing would interact with surface water impacts from the 

ISR activities. 

Response: Surface water is not a source of consumptive water use at the proposed Moore 

Ranch Project; hence, surface water impacts due to livestock grazing (erosion or surface water 

contamination) would be insignificant for the ISR related activities. Any potential spills or 

discharge to surface water features (which may have direct or indirect impacts on livestock 

grazing) during the ISR lifecycle would be controlled by the Construction and Industrial 

WYPDES permits. The applicant would obtain the WYPDES permits from WDEQ before ISR 

operations began. No further modification to the SEIS was required beyond the information 

provided in this response. 

B5.21.2 General Water Resource Concerns 

Comments: MR018-001; MR018-014; MR018-015 

A commenter noted that the draft SEIS did not contain the most recent hydrological information 

submitted to the WDEQ/LQD because this information was submitted to the WDEQ/LQD after 

the printing of the draft SEIS. 

Response: The applicant would acquire more geologic and hydrogeological information during 

construction and operations before finalizing locations of production, injection, and monitoring 

wells. Once the applicant finalizes wellfield layouts and designs, the applicant would seek 

approval for the locations and wellfield designs from the WDEQ. This informaiton was 

unavailable at the time the draft SEIS was issued. 

The final SEIS has been revised to reflect current hydrological data that has become available 

since the publication of the draft SEIS. 
Appendix B 

B–83 

Comment: MR018-012 

A commenter noted that the State of Wyoming Constitution gives control of the “waters of the 

State,” both surface and ground, to the State Engineer and that water used by any projects 

would be required to obtain the necessary permits (GEIS, Sections 3.2.4 and 3.3.4). 

Response: This comment relates to GEIS Sections 3.2.4 and 3.3.4. The text in these sections 

states that water resources are described in terms of surface waters, wetlands, “Waters of the 

United States,” and groundwater. The commenter noted that the State of Wyoming has 

jurisdictional control over the waters of the State. The comment is noted. The final SEIS, 

Table 1-2, identifies environmental approvals required for the proposed Moore Ranch Project 

including permits related to both surface water and groundwater as noted by the commenter. 

No changes were made to the document in response to this comment. 

Comment: MR020-022

A commenter stated that the Moore Ranch SEIS identified three wells permitted as domestic 

wells that are completed at depths close to that of the 70 Sand production zone that could be 

impacted by ISR operations. The commenter noted that these statements indicate there is a 

potential of current use of these wells as a drinking water source, even though there are no 

residences located in the proposed license area. The commenter stated that even though these 

wells are not being used primarily for human consumption, it does not rule out the possibility of 

their use as current drinking water sources. The commenter further noted that the Moore Ranch 

SEIS did not adequately explain why these wells would not be used in the future as a drinking 

water source. Finally, the commenter asked if there was a process for the State of Wyoming to 

rescind the permits for domestic use. 

Response: Three domestic water wells are located within the 3.2 km [2-mi] buffer for the 

proposed Moore Ranch license area. One well, UM 1575 2 33 42 75, is located within the 

proposed license area. Rio Algom Mining Corporation installed this well in 1972, and the 

Wyoming State Engineer’s Office (WSEO) permit for this well, P12299.0W, states that the well 

is for domestic and industrial use with a note that it may be used for uranium exploration drilling. 

The well is located about 1,219 m [4,000 ft] to the southwest of the Wellfield 1 monitoring well 

ring. It is, therefore, hydrologically upgradient of the wellfield. The well is screened from 

106–134 m (348–440 ft) below ground surface. Review of geologic cross sections of this area 

indicates that the screen depth would place it in the “60 Sand” aquifer. The “60 Sand” aquifer is 

below an aquitard under the 68 Sand aquifer, which is below another aquitard under the 

Wellfield 1 “70 Sand” production zone. Given the vertical stratigraphic and horizontal separation 

of this well from ISR operations in the “70 Sand,” it would not likely be impacted by ISR 

operations. It could be used for domestic purposes in the future. The two other domestic wells, 

9 Mile #1 and 9 Mile #2, are located at the limit of the 3.2 km [2-mi] buffer to the southeast of the 

proposed license area. According to the 9 Mile #1 permit, P9309.0W, the well was installed in 

1971 and is screened at 58–76 m [190–250 ft] below ground surface. According to P12240.0W, 

the 9 Mile #2 well was installed in 1965 to a total depth of 55 m [180 ft] below ground surface 

with no screen interval information. Both wells are located at least 4.8 km [3 mi] away and 

hydrologically upgradient from Wellfield 2. No cross sections were available to assess in which 

aquifer the wells were completed. The Moore Ranch application indicated there is no current 

use of these wells for domestic purposes. Given their distance from and upgradient location 

from the ISR operations, they would not likely be impacted by operations. These wells could 

also be used for domestic purposes in the future. 
Appendix B 

B–84 

The WSEO, which issues permits for all groundwater wells, does not have a process to rescind 

permits. The WSEO can cancel permits if they do not meet well installation and completion 

specifications; but they do not cancel permits based on water quality. No changes were made 

to the SEIS in response to this comment beyond the information provided in the response. 

B5.21.3 References 

40 CFR Part 144. Code of Federal Regulations, Title 144, Protection of Environment, Part 144, 

“Underground Injection Control Program.” 

EMC (Energy Metal Corporation US), 2007a. Environmental Report. Application for USNRC 

Source Material License Moore Ranch Uranium Project Campbell County, Wyoming. 

EMC, 2007b. Technical Report. Application for USNRC Source Material License Moore Ranch 

Uranium Project Campbell County, Wyoming. 

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

Uranium One (Uranium One Americas), 2009. RAI Response to technical report 7.2.9.2.2 and 

3.1.3. Surface Water Impacts. ML 092450317. Received on August 27, 2009. 

Uranium One, 2008. RAI Response to 5.12. Groundwater and Surface Water Monitoring 

Programs. ML 082060527. Received on July 11, 2008. 

B5.22 Wetlands 

Comments: MR018-043; MR018-044; MR018-046; MR020-019 

A commenter noted that jurisdictional determination of water at the Moore Ranch Site was not 

adequately addressed in Section 3.5.1 and 4.5.1 of the SEIS. Another commenter noted that 

although wetlands within the permit boundary may not be considered jurisdictional waters of the 

United States, all naturally occurring wetlands are considered waters of the State and they are 

protected under Wyoming Law; therefore, all naturally occurring wetlands should be protected 

during the proposed project. The commenter noted that the magnitude of impacts to wetlands 

would be based on the effect the proposed project had on wetlands and hydrologic function, not 

whether a permit is required. 

Response: Table 2.8-14 of applicant’s technical report (2007) includes a list of wetlands within 

the Moore Ranch project area and the applicant jurisdictional recommendation.. The applicant 

recommended all wetlands in the project area to be non-jurisdictional under Section 404 of the 

Clean Water Act due to lack of connection to navigable waters, and they do not support 

interstate commerce. Since publication of the draft SEIS, the proposed Moore Ranch Project 

has received a determination from the U.S. Army Corps of Engineers (USACE, 2010). The 

proposed activities are consistent with activities authorized under Nation Wide Permit #12. 

NRC recognizes that surface waters and wetlands, whether they are jurisdictional or not, are 

protected by the State. In case the applicant conducts ISR related activities on or near wetlands 

within the permit boundary, the applicant is required to monitor, control, mitigate, and remediate 

any potential spills in accordance with 40 CFR 144.54; 40 CFR 144.55; and 40 CFR Part 40, 
Appendix B 

B–85 

Appendix A, Criterion 7A. The applicant is required to obtain industrial and construction 

WYPDES permits from WDEQ as part of the license application (SEIS 2009, Table 1-2) prior to 

commencement of ISR activities. As part of these permits, the applicant would implement best 

management practices, such as implementation of a spill prevention and cleanup plan, to 

minimize soil contamination. The applicant is also committed to implementing soil erosion 

mitigation in accordance with WDEQ Rules and Regulations, Chapter 3, Environmental 

Protection Performance Standards (environmental report 2007, Section 5.3). 

Potential impacts to surface waters and wetlands are discussed in SEIS (2009, Section 4.5.1). 

NRC analyzes potential impacts to surface waters and wetlands based on independent review 

of the site characteristics. The GEIS concluded that most construction impacts to surface water 

would be SMALL, but could potentially be MODERATE if a U.S. Army Corps of Engineers 

permit is required. All fragmented wetlands and ponds within the permit boundary are formed 

by discharges from CBM and livestock wells (SEIS 2009, Section 3.5.1.2.1) 

B5.22.1 References 

10 CFR Part 40. Appendix A. Code of Federal Regulations, Title 10, Energy, Part 40, Appendix 

A, “Criteria Relating to the Operations of Uranium Mills and to the Disposition of Tailings or 

Wastes Produced by the Extraction or Concentration of Source Material from Ores Processed 

Primarily from their Source Material Content.” 

40 CFR Part 144. Code of Federal Regulations, Title 144, Protection of Environment, Part 144, 

“Underground Injection Control Program.” 

EMC (Energy Metal Corporation US), 2007a. Environmental Report. Application for USNRC 

Source Material License Moore Ranch Uranium Project Campbell County, Wyoming. 

EMC, 2007b. Technical Report. Application for USNRC Source Material License Moore Ranch 

Uranium Project Campbell County, Wyoming. 

NRC, 2009. NUREG–1910, “Generic Environmental Impact Statement for In-Situ Leach 

Uranium Milling Facilities.” Washington, DC: NRC. May. 

Uranium One (Uranium One Americas), 2009. RAI Response to technical report 7.2.9.2.2 and 

3.1.3. Surface Water Impacts. ML 092450317. Received on August 27, 2009. 

Uranium One, 2008. RAI Response to 5.12. Groundwater and Surface Water Monitoring 

Programs. ML 082060527. Received on July 11, 2008. 

USACE (U.S. Army Corps of Engineers), 2010. “Subject: Response to a Preconstruction 

Notification (PCN).” Letter to J. Winter from M.A. Bilodeau, Program Manager, Department of 

the Army Corps of Engineers. May 10.
Appendix B 

B–86 

B5.23 Ecology 

B5.23.1 General Ecology 

Comment: MR018-094 

One commenter noted that based on operational and mitigative practices described in the SEIS, 

they had no concerns regarding aquatic ecology. 

Response: The NRC acknowledges the comment and notes that support of the practices 

described within the SEIS is outside the scope of responses. No changes have been made to 

the SEIS in response to this comment. 

B5.23.2 Concerns About the Sage-Grouse 

Comment: MR017-014; MR017-017 

One commenter suggests that extra care should be taken to protect sage-grouse and its habitat 

and minimize potential impacts. 

Response: NRC recognizes that sage-grouse are a species of great concern in Wyoming and 

has consulted with stakeholders as described in section 1.7. Section 3.6.1.2.2 describes the 

limited habitat found on and in the vicinity of the proposed Moore Ranch site to support sagegrouse existence. No large expanses of contiguous sagebrush occur within several kilometers 

of the proposed Moore Ranch project and few sage-grouse have been documented in the area. 

No sage-grouse leks have been discovered either on or near the proposed Moore Ranch 

Project; the nearest known sage-grouse lek is located approximately 4.0 km [2.5 mi] to the 

northwest of the Moore Ranch Project area (BLM, 2009). Changes were also made in 

Section 3.6.3 to include the U.S. Fish and Wildlife Service’s (FWS) rule listing the sage-grouse 

as a candidate species, the revised WGFD Recommendations for Development of Oil and Gas 

Resources Within Important Wildlife Habitats, and the BLM revised National Sage-Grouse 

Habitat Conservation Strategy (75 FR13909; WGFD, 2010; BLM, 2010). However, the NRC is 

not bound by the WGFD recommendations or BLM guidelines and does not have the statutory 

authority to enforce wildlife mitigation measures upon a licensee. Mitigative measures would be 

negotiated by the applicant and the agency with statutory authority. NRC believes that the 

sage-grouse analyses are supported by sufficient technical bases, whether tiered from the GEIS 

or based on supplemental staff analyses. Based on this information, no changes were made to 

the SEIS. 

B5.23.3 General Comments on Threatened and Endangered Species 

Comment: MR002-006 

One commenter noted that the survey conducted to determine threatened or endangered 

species was not included in the draft SEIS, so it could not be determined if it was accurate. 

They recommended that the final appendix should include these surveys. 

Response: The NRC summarizes the baseline ecological survey results submitted by the 

applicant for inclusion in the SEIS. The applicant submitted an environmental report for the 

application for source material license at the proposed Moore Ranch ISR project in October 

2007. The environmental report can be located using the ADAMS accession numbers 

ML72851222, ML072851229, ML072851239, ML07285249, ML07285253, and ML07285255. 
Appendix B 

B–87 

NRC does not have the obligation to ensure, or the regulatory authority to enforce, that surveys 

are conducted according to those standards established by other agencies with regulatory 

authority. NRC is not obligated to provide supporting documentation as an attachment to the 

SEIS and has made the documents provided by the applicant available to the public through the 

NRC website. Because the requested information is available, no changes were made to 

the SEIS. 

Comment: MR002-009 

One commenter noted that while the draft SEIS indicates that no bald eagles roost within the 

Moore Ranch boundaries, recent information shows that they roost nearby, and that the Final 

SEIS should be updated and expanded accordingly. 

Response: Information cited by the commenter indicates the presence of bald eagle roosts 

within the proposed Nichols Ranch ISR project area, which is approximately 13.7 km [8.5 mi] 

from the proposed Moore Ranch ISR project. NRC staff reviewed the cited BLM Environmental 

Assessment for Yates Petroleum Corporation, All Day Plan of Development (BLM, 2008). 

Because of this response, Sections 3.6.3 and 4.6.1.1.4 were amended to reference the nearby 

eagle roost sites. 

Comments: MR009-196; MR009-197 

One commenter suggested that the NRC misapplied conclusions made in the GEIS (NUREG–

1910) to the proposed Moore Ranch ISR project. 

Response: NRC recognizes that the proposed Moore Ranch ISR project is not located within a 

core population area for sage-grouse and does not support active sage-grouse leks. The NRC 

reference to the WGFD Recommendations for Development of Oil and Gas Resources Within 

Important Wildlife Habitats in the SEIS suggests examples of mitigation measures that could be 

observed to reduce potential impacts to wildlife, including sage-grouse, but the 

recommendations are not limited to sage-grouse mitigation measures. The inclusion of the 

WGDF recommendations as examples of mitigation measures do not imply that the applicant is 

bound to them. The WGFD has no specific authority to require adoption or implementation of 

the recommendations, and NRC cannot enforce mitigation measures on an applicant. NRC 

believes the inclusion of this document as a reference in the SEIS is warranted since the sagegrouse is listed as a federal candidate species, sage-grouse occur in the project county and 

region, and NRC has referenced this document for mitigation examples in other SEIS projects 

for proposed ISR facilities. Based on the aforementioned reasons, no changes were made to 

the SEIS. 

Comment: MR009-208 

One commenter stated that a conflicting statement is made regarding potential impacts to 

threatened and endangered species as a result of the proposed Moore Ranch Project. 

Response: NRC states in section 4.6.1.2.4 that “No impacts to federally-listed threatened and 

endangered species would be expected to occur...”. Stating that no impacts are expected does 

not equate to “there would be no impacts.” Section 4.6.1.2.4 has been amended to state that 

“Continued mitigation would be implemented to ensure potential impacts to threatened and 

endangered species remain SMALL.” This change is to clarify that NRC does not expect 

impacts to threatened and endangered species; however, any potential impacts that could occur 

would be SMALL. 
Appendix B 

B–88 

Comment: MR002-004 

One commenter noted that FWS plans to reopen the comment period on the proposed rule to 

list the mountain plover as a threatened species, and that the Endangered Species Act requires 

Federal agencies to confer with the FWS on any action that is likely to jeopardize the continued 

existence of any species proposed for listing. 

Response: The mountain plover (Charadrius montanus) is a small ground bird that is currently 

listed as a species of greatest conservation need, as designated by the WGFD. The mountain 

plover is known to occur throughout the State of Wyoming; however, it was not observed by 

private and agency biologists within the project area during repeated surveys over multiple, 

consecutive years between 2003 and 2007. Therefore, the Moore Ranch project is not 

expected to have impacts to mountain plovers. As stated in Section 5.5.4 of the Environmental 

Report, the applicant would conduct annual wildlife monitoring at the project site during the 

lifespan of the project including, annual raptor surveys between late April and early May, or as 

required, which is also the breeding season for the mountain plover. Should mountain plovers 

or plover nests be observed during monitoring events, the applicant would consult with the 

FWS. At this time, any applicable permits would be obtained from the appropriate agencies. 

No changes were made to the SEIS beyond the information provided in this response. 

B5.23.4 Concerns About Mitigation and Timing 

Comment: MR002-005 

One commenter encouraged NRC and project planners to develop and implement protective 

measures, should mountain plovers occur within the project area, and provided a list of potential 

protective measures. 

Response: As discussed in comment MR002-004, the mountain plover is known to occur 

throughout the State of Wyoming but has not been observed within the Moore Ranch project 

area. The applicant would obtain WGFD or BLM approval before beginning operations. Should 

mountain plovers or plover nests be observed within the Moore Ranch project area during 

surveys, Uranium One would consult with appropriate agencies to develop and implement 

protective measures, as directed. Since mountain plovers are not a concern for the Moore 

Ranch project at this time, no changes were made to the SEIS. 

Comments: MR009-198; MR018-089; MR018-090; MR018-091; MR018-092; MR018-098; 

One commenter recommends the applicant conduct annual sage-grouse lek surveys, conduct 

additional wildlife surveys prior to new disturbance, conduct winter bald eagle and raptor nest 

surveys, review BLM and/or FWS raptor nest records, and avoid raptor nests during restriction 

time periods. Another commenter believes that annual sage-grouse surveys are not necessary. 

Response: Sections 3.5.5.3.1 of the Uranium One environmental report states that 

supplemental information to the wildlife surveys conducted by the Uranium One consultant for 

the project area was obtained from several sources, including WGFD, FWS, and BLM records 

from surveys conducted by their respective agency biologists in and near the vicinity of the 

proposed Moore Ranch project. The environmental report further explains that “because much 

of the project area has been included in wildlife monitoring efforts annually since 2003, the 

WGFD reduced the study area for raptors and other migratory birds to the portions of the 

proposed Moore Ranch License area and 1-mile perimeter not already encompassed by 

overlapping studies in recent years.” (EMC, 2007a). Sage-grouse and threatened and 

endangered species survey areas were not reduced. Wildlife surveys conducted by the 
Appendix B 

B–89 

Uranium One consultant targeted bald eagle winter roost sites, sage-grouse leks, nesting 

raptors and eagles, mountain plovers, and other avian species of concern. As stated in 

Section 6.4.2 of the SEIS, Uranium One would conduct annual wildlife monitoring at the project 

site during the lifespan of the project, including annual raptor surveys between late April and 

early May, or as required. The survey would cover all areas of planned activity and a 1-mile 

area around the activity for the life of the project. Section 4.6.1 of the SEIS explains that if 

threatened or endangered species were identified in the project site during surveys, mitigation 

plans to avoid and reduce impacts to potentially affected species would be developed. 

NRC does not have the statutory authority to request that an applicant conduct additional 

surveys, commit to conduct surveys during the project, enforce mitigation measures, or modify 

the information presented in the application when NRC has completed an acceptance review. If 

the applicant agrees to conduct additional studies, monitoring, or adhere to threatened and 

endangered species guidelines, then the licensee would implement those commitments. 

B5.23.5 Habitat Loss and Fragmentation 

Comment: MR018-087 

One commenter suggested that removal of sagebrush would reduce forage for pronghorn and 

deer, and restoration projects should strive to restore sagebrush and native plant species. 

Response: NRC explains in Section 4.6 that the proposed project construction and operation 

may result in the disturbance of 61 ha [150 ac] of land, incrementally, for up to 12 years through 

the life of the ISR facility. Section 4.6 of the SEIS also discusses the potential impacts to big 

game and increased the potential for non-native plant species 

NRC acknowledges that in arid environments, natural revegetation could take years, and certain 

vegetative communities could be difficult to reestablish through artificial plantings. However, 

temporary and permanent revegetation planned by the applicant in a phased (sequential) 

schedul, would increase the rate at which a disturbed area is returned to a state similar to 

preconstruction and restore the wildlife forage lost during the project. Section 2.1.1.5.3 

describes that revegetation practices would be conducted in accordance with WDEQ-LQD 

regulations and the ISR permit, including an extended reference area, which would ensure the 

disturbed area is reclaimed with the same vegetation type as adjacent undisturbed areas. Since 

the commenter concerns regarding big game and vegetation have been addressed in the SEIS, 

no changes were made in response to this comment. 

B5.23.6 Comments on Migratory Birds 

Comment: MR002-007 

One commenter suggested that a migratory bird conservation plan be developed for the project, 

and that the FWS be consulted regarding potential impacts to eagles. The commenter pointed 

out that an eagle permit is required if a project “takes” eagles or their nests (active or inactive). 

The commenter wanted information regarding the status of the bald eagle included in the 

final SEIS. 

Response: SEIS Section 4.6.1.1.2.3 states that raptor nest surveys would be conducted 

annually. If nests were discovered during these surveys, the applicant would take appropriate 

mitigation measures, such as moving the nest, to ensure the protection of the species. 
Appendix B 

B–90 

The NRC acknowledges that consultation with the FWS concerning the eagle take permit rule is 

appropriate for the Moore Ranch ISR Project. NRC contacted the FWS on March 15, 2010, to 

discuss whether an eagle permit would be appropriate for the proposed Moore Ranch ISR 

project (NRC, 2010). The FWS concluded that the NRC would not need to further pursue 

consultation with the FWS regarding bald eagles and would not need to obtain an eagle take 

permit at this time. Accordingly, Section 4.6.1.1.4 has been updated to reflect this new 

information. Because NRC did not need to enter into consultation with the FWS regarding an 

eagle take permit, this consultation would not be added to the description of agency 

consultations in Section 1.7. However, the memorandum summarizing the teleconference with 

FWS (NRC, 2010) has been added to Appendix A of the final SEIS and Section 4.6.1.1.4 has 

been updated to reflect the information described in this comment response. 

Regarding the status of the bald eagle (Haliaeetus leucocephalus), page 3-31, line 4 of the draft 

SEIS explains that the bald eagle was delisted from threatened status in 2007, but is still 

protected under the Bald and Golden Eagle Protection Act and the Migratory Bird Treaty Act. 

Suitable habitat is present on the Moore Ranch site for golden eagles; however, suitable habitat 

for bald eagles is limited within the proposed license area because of the lack of trees. No bald 

or golden eagles were observed during surveys conducted by the applicant between 2003 and 

2007. Since the eagle status information is provided in the SEIS, no changes were made to 

the SEIS. 

Comment: MR017-009 

One commenter expressed a concern of potential impacts to wildlife from selenium 

contamination. 

Response: NRC acknowledges that wildlife may be temporarily exposed to contamination from 

spills and leaks in the SEIS Section 4.6.1.2.2. The license application for the Moore Ranch 

Project did not propose use of land application. The commenter references a document that 

uses the Highland Uranium in-situ uranium mine located in Converse County, Wyoming, as a 

study area and reports elevated concentrations of selenium in food sources, soil, and water 

within the study area (Ramirez, 2000). Note that the Highland mine used land application 

through irrigation for wastewater disposal, which is not planned at the proposed Moore Ranch 

site. In addition, the report does not discuss leaks or spills known to occur at the study area. 

SEIS Section 4.6.1.1.3 explains that there are no aquatic habitats on the proposed Moore 

Ranch site that support fish or macroinvertebrates. Therefore, there would be no impact to 

aquatic wildlife. 

The potential of toxic chemical impacts is discussed in the SEIS, and NRC has determined that 

the potential impacts to wildlife from evaporation ponds or chemical spills and leaks would be 

SMALL. The commenter does not provide new information that should be considered; 

therefore, no changes were made to the SEIS. 

B5.23.7 General Vegetation Comments 

Comment: MR009-195 

One commenter suggests that the WGFD Recommendations for Development of Oil and Gas 

Resources Within Important Wildlife Habitats are not appropriate to include as general 

potential mitigation measures for the proposed project because an SEIS should consider 

site-specific characteristics. 
Appendix B 

B–91 

Response: NRC has provided a comprehensive site-specific analysis of the proposed Moore 

Ranch ISR project. NRC references the WGFD Recommendations for Development of Oil and 

Gas Resources Within Important Wildlife Habitats in the SEIS to provide examples of mitigation 

measures that could be implemented to reduce potential impacts to wildlife. The inclusion of the 

WGDF recommendations as examples of mitigation measures do not imply that the applicant is 

bound to them. The WGFD has no specific authority to require adoption or implementation of 

the recommendations, and NRC cannot enforce applicant implementation of mitigation 

measures. NRC believes the inclusion of this document as a reference in the SEIS is warranted 

since sage-grouse is listed as a federal candidate species, sage-grouse occur in the project 

county and region, and NRC has referenced this document for mitigation examples in other 

SEIS projects for proposed ISR facilities. Based on the aforementioned reasons, no changes 

were made to the SEIS. 

Comment: MR009-291 

One commenter asserted that not all vegetation would be lost within the wellfield footprint, and 

that vegetation loss with the entire wellfield should not be considered an unavoidable impact. 

Response: NRC has provided Table 8-1 in the SEIS to summarize environmental 

consequences per resource area. The description of unavoidable consequences for ecological 

impacts from the proposed project includes the short-term loss of vegetation covering 

approximately 23 ha [57 ac], which is the footprint of the proposed wellfields. NRC agrees with 

the commenter that not all of the vegetation within the wellfield would be lost during the life of 

the proposed project; however, the expected impact to vegetation also includes the disturbance 

from the central plant and from developing the infrastructure that includes laying pipeline and 

constructing access roads. As described in Section 4.6.1.1.1, an estimated 61 ha [150 ac] of 

upland grassland would be affected by construction disturbance, and similarly for 

decommissioning, under current development plans. Table 8-1 of the SEIS has been modified 

to clarify that direct and short-term impacts of an estimated 61 ha [150 ac] of vegetation would 

be impacted. 

B5.23.8 Impacts to Terrestrial Ecology and Wildlife Discussion 

Comment: MR009-193 

One commenter questioned the applicability of referring to the document, “Recommendations 

for Development of Oil and Gas Resources Within Important Wildlife Habitats” published by the 

WGFD within the SEIS because it was specifically developed for the oil and gas industry. 

Response: NRC would establish site-specific license conditions for the Moore Ranch ISR 

Project, but only within the limits of the legislative authority granted by Congress. State and 

other Federal agencies would also establish permit conditions for the proposed Moore Ranch 

Project based upon their statutory and regulatory authority. The WGFD has the lead for the 

protection of sage-grouse. Although there are no regulations regarding the protection of the 

sage-grouse, the WGFD, in cooperation with the Wyoming Governor Sage-Grouse 

Implementation Team (SGIT), has developed guidelines for various industries operating in 

different locations within Wyoming. The NRC staff have been working with the SGIT and its 

sub-committees to better define the State agency roles and to develop guidelines for the ISR 

uranium industry. In addition, the WGFD recently issued an update to “Recommendations for 

Development of Oil and Gas Resources Within Important Habitats” (April 2010), which contains 

revised guidelines for sage-grouse protection that would be applied to the uranium extraction 

industry. These guidelines address (1) standard mitigation practices (for all wildlife); (2) specific 

best management practices for sage-grouse; and (3) stipulations for development in 
Appendix B 

B–92 

sage-grouse core areas that would be monitored by the WGFD. If a license were to be granted, 

the Moore Ranch ISR facility would be routinely inspected by WGFD for compliance with the 

requirements and conditions of the sage-grouse guidelines. For more information on the 

sage-grouse issue, the reader is referred to Section B5.25 of this comment-response appendix. 

Chapter 7 of the GEIS provides a general overview of the types of best management practices, 

mitigation measures, and management actions that have historically been used at ISR facilities 

to avoid or reduce potential environmental impacts. 

No change was made to the Moore Ranch SEIS beyond the information provided in 

this response. 

Comment: MR009-207 

A commenter noted that the NRC states (in Section 4.6.1.2.2.4) that impacts to reptiles and 

amphibians would be small. However, in Section 4.1.1.1.2, the SEIS states that there would be 

no impacts to amphibians and reptiles. 

Response: NRC states in Section 4.6.1.1.2.4 that “no impacts to reptiles or amphibian 

populations would be expected.” Stating that no impacts are expected does not equate to 

“there would be no impacts.” Section 4.6.1.2.2.4 has been revised to state that the potential 

impact (to reptiles and amphibians) would be SMALL. This change is to clarify that NRC does 

not expect impacts to reptiles or amphibians; however, any potential impacts that could occur 

would be small. 

Comments: MR017-013; MR017-019 

One commenter stated that the NRC should take a hard look at wildlife impacts and explore 

alternatives or requirements that would reduce or eliminate adverse environmental impacts. 

Response: The SEIS was prepared in accordance with NRC guidance in NUREG–1748 (NRC, 

2003) and is consistent with NRC regulations at 10 CFR Part 51 that implement NEPA. The 

draft SEIS was published for public comment in December 2009. In March 2010, the FWS 

listed the sage-grouse as a candidate species. Subsequently, the Wyoming BLM made 

amendments to the National Sage-Grouse Habitat Conservation Strategy and the Wyoming 

Governor SGIT continues to discuss an evaluation process for impacts to sage-grouse. NRC 

has included a discussion regarding those recommendations in the SEIS and has changed 

some of the significance levels for wildlife impacts. It should be noted that the proposed project 

is not located within a core population area for sage-grouse. NRC has made a reasonable effort 

to provide a discussion of potential mitigation measures that would limit impacts to wildlife; 

however, NRC does not have the statutory authority to enforce wildlife mitigation measures at a 

licensed facility. NRC believes that the wildlife analyses are supported by sufficient technical 

bases, whether tiered from the GEIS or based on supplemental staff analyses. Because the 

comment does not provide any additional information to incorporate into the SEIS, no changes 

were made to the SEIS beyond the information provided in this response. 

Comment: MR018-088 

One commenter suggests that allowing hunting activities for big game would help in the 

management of pronghorn and deer. 
Appendix B 

B–93 

Response: NRC understands that mule deer and pronghorn are abundant in the proposed 

Moore Ranch Project area. No crucial big game habitat or migration corridors occur on or within 

several kilometers of the proposed license area. Section 1.7.3.5 explains that the WGFD is 

responsible for controlling all game in Wyoming. Section 3.2 of the SEIS explains that over 85 

percent of the land is owned by private entities, and about 14 percent of the land is owned by 

the State of Wyoming. NRC does not have regulatory authority to require that the applicant 

allows hunting activities during operations. The applicant can make arrangements with the 

private land owners or engage in consultation with the WGFD regarding hunting arrangements. 

No changes were made to the SEIS in response to this comment. 

B5.23.9 Inconsistencies Between Sections 

Comments: MR009-029; MR009-201, MR009-202 

One commenter suggested that the BLM and WGFD recommendations to reduce impacts to 

ecology are inconsistently applied. 

Response: NRC has explained in the response to MR009-193 that the BLM and WGFD 

recommendations referenced by the commenter are not required mitigation measures; but serve 

as mitigation examples that can reduce impacts to ecology resources. The documents are 

referenced where some, but not all, potential applicable mitigations measures are relevant. The 

SEIS has been modified to clarify that these recommendations are examples. 

B5.25.10 References 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

74 FR 46836, FWS. “Eagle Permits; Take Necessary To Protect Interests in Particular 

Localities.” Federal Register: Volume 74, No. 175, pp. 46836-46879. September 11, 2009. 

75 FR 13909, FWS. “Endangered and Threatened Wildlife and Plants; 12-Month Findings for 

Petitions to List the Greater Sage-Grouse Centrocercus urophasianus) as Threatened or 

Endangered.” Federal Register: Volume 75, No. 55, pp. 13909-13959. March 23, 2010. 

BLM (U.S. Bureau of Land Management), 2010. Instruction Memorandum No. 2010-071. 

Subject: Gunnison and Greater Sage-grouse Management Considerations for Energy 

Development (Supplement to National Sage-Grouse Habitat Conservation Strategy). 

Washington, D.C. U.S. Department of Interior, BLM. March 5. 

BLM, 2009. “Sage-Grouse Management.” <http://www.blm.gov/wy/st/en/field_offices/ 

Buffalo/wildlife/data.html#SG>. (14 April 2009). 

BLM, 2008. “Bureau of Land Management Buffalo Field Office Environmental Assessment for 

Yates Petroleum Corporation All Day POD Plan of Development WY–070–08–026.” Cheyenne, 

Wyoming: BLM. August 28. 
Appendix B 

B–94 

EMC (Energy Metal Corporation US), 2007. “Application for USNRC Source Material License, 

Moore Ranch Uranium Project, Campbell County, Wyoming, Environmental Report.” Casper, 

Wyoming: Uranium 1 Americas Corporation. ADAMS Accession Nos. ML072851222, 

ML072851229, ML072851239, ML07285249, ML07285253, ML07285255. October 2.

FWS (U.S. Fish and Wildlife Service), 2009. “50 CFR Parts 13 and 22 Eagle Permits; Take 

Necessary To Protect Interests in Particular Localities; Final Rules.” Washington, DC: 

U.S. Department of the Interior. September 11, 2009. 

NRC (U.S. Nuclear Regulatory Commission), 2010. “Summary of Teleconference with Pedro 

Ramirez, Wyoming Field Office, U.S. Fish and Wildlife Service, Regarding Eagle Take Rule for 

the Proposed Nichols Ranch ISR Project (Docket No. 040-09067) and the Proposed Moore 

Ranch ISR Project (Docket No. 040-09073). Washington, DC: NRC. March 25. ADAMS 

No. ML100760621. 

NRC, 2003. NUREG–1748,“Environmental Review Guidance for Licensing Actions Associated 

With NMSS Programs—Final Report.” Washington, DC: NRC. August. 

Ramirez, Jr., P. and B. Rogers, 2000. “Selenium in a Wyoming Grassland Community 

Receiving Wastewater from an In-Situ Uranium Mine.” Contaminant Report Number: 

R6/715C/00. Cheyenne, Wyoming: FWS, Region 6. September. 

WGFD (Wyoming Game and Fish Department), 2010. Recommendations for Development of 

Oil and Gas Resources Within Important Wildlife Habitats. Version 6.0. Cheyenne, Wyoming: 

WGFD. April. 

B5.24 Meterology, Climatology, and Air Quality 

B5.24.1 Permitting and Regulations 

Comment: MR020-002 

One commenter, referring to page xxi of the Executive Summary (environmental impacts from 

air quality) of the draft SEIS, noted the sections state the proposed project would not be subject 

to Title V of the Clean Air Act without providing a basis for either statement. The commenter 

also requested a detailed air emission inventory should be developed and used to evaluate 

Clean Air Act programs that may apply, including Prevention of Significant Deterioration New 

Source Review, Maximum Achievable Control Technology, National Emission Standards for 

Hazardous Air Pollutants, and Title V (Permits). 

Response: While the NRC staff analysis of emissions within the context of Clean Air Act 

regulations supports the assessment of potential environmental impacts that is required by the 

NEPA, as amended, the authority to enforce Clean Air Act Regulations in Wyoming rests with 

the WDEQ. In that role, the WDEQ, at the time of this writing, is currently evaluating the 

applicant’s air quality construction permit application and deciding whether to issue a permit to 

the applicant in the near future. Construction permits recently issued to other proposed ISR 

facilities (WDEQ, 2009; WDEQ, 2010) include a condition that the applicant must obtain a 

permit to operate in accordance with Chapter 6, Section 2(a)(iii) of the Wyoming Air Quality 

Standards and Regulations. According to the language of that cited requirement, such a permit 

applies to facilities that are not subject to the provisions of Chapter 6, Section 3 of the Wyoming 
Appendix B 

B–95 

Air Quality Standards and Regulations. Section 1 of the Wyoming Air Quality Standards and 

Regulations refer to Section 3 as the state operating permit program required under Title V of 

the Clean Air Act. Section 1 also refers to the required Section 2 operational permit as a minor 

source permit to operate. This information indicates the WDEQ has concluded that each of the 

other proposed ISR facilities is not considered a major source of emissions nor are they subject 

to Title V operating permit requirements. In the review of the proposed action, the NRC staff 

have not identified any emissions information that would suggest the proposed Moore Ranch 

facility would be permitted differently; however, this would not be known for certain until a 

permitting decision has been made by the WDEQ. The Executive Summary has been modified 

to clarify the air impacts information. 

Regarding the other Clean Air Act programs mentioned by the commenter, it is the NRC staff’s 

understanding that these programs apply to major stationary sources of emissions and, based 

on the discussion in the preceding paragraph, do not need to be evaluated further in the SEIS. 

Should the WDEQ determine that some or even all of the aforementioned regulatory programs 

apply to the proposed action, then the applicant would need to comply with any applicable 

permitting requirements the WDEQ has the authority to enforce. 

In response to these and other comments, the staff also updated the discussion of proposed air 

emissions in Section 2.1.1.1.6.1 of the SEIS and provided, in a new Appendix D, supporting 

calculations of mobile non-road diesel emissions from well drilling activities and construction 

equipment. The staff also updated portions of the air impact analysis (Section 4.7) and the 

Executive Summary to reflect this additional information and provide additional supporting 

bases for air impact conclusions. The commenter should be aware that the executive summary 

is a brief summary of the impact findings and does not normally contain a detailed description of 

supporting bases. The complete bases for impact conclusions are documented in the impact 

analysis in Section 4.7. 

B5.24.2 Baseline Air Quality 

Comment: MR020-024 

One commenter, referring to the description of the affected environment for air quality on 

page 3-39 (Section 3.7.2), noted the proposed project is 117 mi from Wind Cave National Park, 

which is the nearest Clean Air Act Class 1 Prevention of Significant Deterioration Area and 77 

miles from Cloud Peak Wilderness area, which is a Sensitive Class II area. They requested the 

SEIS identify all nearby Class I and II Areas. 

Response: In response to these comments, the staff verified the commenter information and 

added the recommended Prevention of Significant Deterioration sites to Section 3.7.2 of the 

final SEIS. 

B5.24.3 Impact Assessment 

Comments: MR009-093; MR009-217; MR020-046 

A commenter requested clarification in the air quality impact analysis (SEIS, Section 4.7) of 

what mitigations would be implemented by the applicant to reduce air emissions. Another 

commenter suggested the air impact analysis should include a discussion of how down-flow IX 

columns and vacuum dryers are beneficial to protecting public health and safety. The same 

commenter noted that the first paragraph in Section 2.1.1.1.6.1 mentions uranium particulate 
Appendix B 

B–96 

emissions; however, the application of vacuum dryer technology would eliminate significant 

uranium particulate emissions. 

Response: In response to the request for clarification of the proposed mitigations, text was 

added to the description of the proposed action in SEIS Chapter 2, to the air and public and 

occupational health impact in SEIS Sections 4.7 and 4.13, and to the air impact analysis 

executive summary. Because the proposed ISR facility is not considered a major source of 

nonradiological air pollution (see revised Section 4.7 in the final SEIS and responses to other air 

quality public comments in this section) the most significant mitigation proposed by the applicant 

to mitigate potential nonradiological air quality impacts is their proposed fugitive dust control 

measures that call for application of water or other agents to unpaved roads to control fugitive 

dust emissions (Uranium One, 2009). Regarding the comment about down-flow IX and vacuum 

dryer technology (both related to potential radiological air impacts), the staff clarified that these 

technologies are part of the proposed action in SEIS Sections 2.1.1.1.6 and 4.13.1.2.1 

regarding public and occupational health impacts where the health and safety impacts of 

radiological air emissions are evaluated. The staff also corrected the first paragraph of draft 

SEIS Section 2.1.1.1.6.1 to more accurately reflect the reduced emissions from the proposed 

application of vacuum dryer technology. 

Comments: MR009-213; MR009-215; MR009-216; MR009-218 

One commenter suggested corrections be made to statements in the draft SEIS air quality 

impact section that summarize GEIS analyses. Specifically, regarding statements about 

emissions that may be associated with suspension of dried spill areas and radiological impacts 

(page 4-45, line 25 and page 4-47, line 1 of the draft SEIS), the commenter suggested such 

emissions were not considered in the GEIS. The commenter noted the draft SEIS included no 

information about site-specific characteristics that suggest this process would impact air quality 

and they suggested deleting the statement. Regarding a statement (page 4-46, line 40 in the 

draft SEIS) about other potential sources of nonradiological emissions, including fugitive dust 

and fuel from equipment, the commenter noted the GEIS does not discuss fuel emissions. 

Response: While some of the sections of the GEIS refer to dried spills as an inhalation hazard 

(e.g., Section 4.2.3.2, Operation Impacts to Geology and Soils), this process is not discussed in 

the sections of the GEIS that evaluate air impacts or public and occupational health impacts. 

The statements in the GEIS describe resuspension of dried spill deposits as a potential route for 

exposure from spills, but the GEIS does not elaborate on the magnitude of the impact other than 

to reference an earlier bounding analysis (Mackin et al., 2001). 

The referenced bounding analysis in Mackin et al., (2001) involved a dose calculation based on 

a conservative, hypothetical exposure scenario (i.e., a maximally exposed individual) that 

evaluated annual radiation dose to an individual. In this scenario, the individual was assumed 

to live in a residence and farm land that was contaminated by a 58,000 L [15,322 gal] spill of 

pregnant lixiviant. The analysis evaluated radiation doses from exposure to external radiation 

fields, inhalation of resuspended soil, and consumption of produced crops and livestock. The 

calculated doses are 1.4 to 2.6 mSv/yr [140 to 260 mrem/yr] at years 1 and 25. While the 

calculated doses are above the NRC 10 CFR Part 20 public dose limit of 1 mSv/yr 

[100 mrem/yr], the results are potentially misleading due to the conservative and, in some 

instances, unrealistic assumptions in the exposure scenario used in this dose calculation (see 

the following). Some of the conservative assumptions in the referenced analysis include that 

(i) a large spill would go undetected and unreported, (ii) all spilled radionuclides would remain in 

the top 15 cm of soil for the initial soil radionuclide inventory (no initial leaching or runoff), 
Appendix B 

B–97 

(iii) there would be no attenuation of air concentrations from the effect of downwind mixing and 

dispersion (e.g., inherent characteristic of the mass loading model used), and (iv) the 

unreported soil contamination would not be detected by NRC required site decommissioning 

radiological surveys prior to NRC release of the site for unrestricted use. Actual doses from 

more plausible scenarios are likely to be far lower than the aforementioned conservative 

estimates and are, therefore, not evaluated further in this comment response. An operating 

facility would also have an NRC-approved monitoring system in place and the NRC staff would 

inspect the facility at least annually to verify compliance with NRC public and worker dose limits. 

In response to these and other comments, the staff removed the mostly redundant discussion of 

potential radiological air impacts from the air quality impacts section of the draft SEIS 

(Section 4.7), including specific references to resuspension of dried spill areas. Based on the 

preceding discussion, the statements had placed undue emphasis on resuspension of spill 

deposits as an air quality emission concern when the supporting risk analysis information 

suggests otherwise. Corrections were also made because, for practical reasons, the SEIS 

addresses radiological impacts from air releases in the Public and Occupational Health and 

Safety Impacts Section (4.13) and not in the Meteorology, Climatology, and Air Quality Impacts 

Section (4.7) that addresses the potential nonradiological impacts to air. Section 4.13 did not 

specifically evaluate potential dose impacts from resuspension of dried wellfield spill areas 

because it focused on more severe radiological accident scenarios that are expected to have 

greater consequences than a scenario involving resuspension of dried spill areas. The staff 

also changed discussions of fuel emissions to refer to combustion engine emissions to clarify 

the original intent of the statements. 

Comments: MR012-009; MR012-012; MR015-006 

One commenter expressed concern about the greenhouse gas emissions from the proposed 

Moore Ranch ISR facility and the impact of these emissions on climate change. Another 

commenter suggested the draft SEIS ignores climate change impacts based on what was stated 

as the imprecise nature of the science. The commenter noted that the exact extent and timing 

of climate change is not certain, but that many adverse impacts have already been documented 

and such impacts will continue into the future. Citing draft guidance from CEQ (2010) (to help 

Federal agencies improve their consideration of greenhouse gas emissions and climate change 

in evaluations of proposals for Federal actions), the commenter stated that despite the evolving 

nature of climate change science, Federal agencies have an obligation to consider both 

greenhouse gas emissions emitted from proposed projects and the impacts the action has on 

natural resources that could also be affected by climate change. 

Response: As one commenter noted, the state of the science of climate change is evolving. 

The NRC staff acknowledge the changing state of the science on climate change and the 

evolving Federal role in evaluating the potential environmental impacts of Federal actions. The 

NRC approach to evaluating potential climate change impacts from NRC licensing actions is 

also evolving and continues to evolve as more information becomes available that NRC staff 

can use to evaluate potential impacts. 

To address these and other comments regarding the need for the NRC staff to consider and 

evaluate the potential impact of greenhouse gas emissions on the global climate, the staff have 

calculated annual and cumulative CO2 emissions from applicant use of diesel construction 

equipment during construction and decommission of the production wellfields and facilities. 

Because operating ISR facilities are not major sources of CO2 or other greenhouse gas 

emissions, the NRC staff expect construction equipment emissions (including well drilling rigs) 
Appendix B 

B–98 

produced during both construction and decommissioning phases to represent the majority of 

greenhouse gas emissions from the proposal. The emissions estimates are documented in a 

new Appendix D and are summarized in Section 2.1.1.1.6. The NRC staff also added an 

evaluation of potential impacts to climate from the calculated construction equipment emissions 

from the proposed facility in Section 4.7. The cumulative air impact analysis was also updated 

to evaluate the impact of the emissions in the context of other past, present, and reasonably 

foreseeable future actions. 

Comments: MR012-013; MR012-014; MR012-015; MR012-019 

One commenter provided a number of comments related to climate change and the potential 

impacts of climate changes on the potential environmental impacts from the proposed Moore 

Ranch ISR facility. They provided a report from the U.S. Global Change Research Program 

entitled "Global Climate Change Impacts in the United States" (Karl et al., 2009) as the technical 

basis for predictions of climate change in the region where the facility is proposed. They 

suggested the report shows that climate changes in the region have the potential to impact the 

proposed facility and, therefore, such impacts should be evaluated by NRC in the SEIS. 

Specifically, they noted the area can expect reduced snowpack and spring runoff and disruption 

of precipitation over the next decades. Regarding the potential increase in precipitation, they 

requested NRC disclose and evaluate how increased soil saturation, flooding, and aquifer 

recharge would interact with project impacts. 

Response: With regard to future changes in climate altering the potential impacts of the 

proposed action, the staff evaluated the report cited by the commenter, and found that the 

projected changes in climate over the 10-year time scale of the licensing period for the 

proposed facility were limited in degree and unlikely to significantly change the intensity of the 

potential impacts evaluated in the final SEIS. For example, the projected changes in 

precipitation for a high-emissions scenario were discussed for the latter part of this century 

(years 2080 through 2090) as 10 to 15 percent above current values for the area of Wyoming 

where the proposed site would be located. Changes during the next 10 years would be 

expected to be much less than the values reported for the end of the century. The staff could 

not identify information in that report to suggest that over the next 10 years there would be the 

types of changes indicated by the commenter (e.g., soil saturation, flooding, recharge effects). 

Projected temperature changes are also cited in the report as long-term consequences. The 

cited report includes projected changes in average temperature for year 2020 as ranging from a 

slight decrease in the present temperature to a maximum of approximately 2 degrees higher 

than present temperatures. The resource area that would be expected to be the most sensitive 

to small changes in ambient temperature would be the local ecology. Potential changes to the 

regional ecology from a rise in average temperature (including invasive species, fire, erosion, 

desertification) would occur whether the site were licensed or not, but localized effects could be 

exacerbated to some degree by proposed site activities and the changes in the ambient 

temperature. In response to these comments, NRC staff added discussion of the potential 

impacts from projected changes to climate in Section 5.7 (Cumulative Air Quality Impacts) of the 

final SEIS. 

In Section 5.7.1.4, the NRC staff determined that the overall effect of projected climate change 

on the proposed Moore Ranch facility would be SMALL. The small, predicted increases in 

temperatures and precipitation over the next decade would have no effect on the proposed 

Moore Ranch Facility in any of the ISR phases. 
Appendix B 

B–99 

Regarding the portion of a comment that suggested potable water sources outside the ore zone 

would be sacrificed, as discussed in the GEIS, the NRC licensees are required to return 

wellfield water quality parameters to the standards in 10 CFR Part 40, Appendix A, 

Criterion 5(B)(5) or another standard approved in their license (NRC, 2009). In general, 

favorable hydrogeological conditions for effective isolation of ore-bearing aquifers and 

containment of recovery solutions; integrity and continuity of impermeable confining layers;, 

successful implementation of restoration techniques; and continuous and effective monitoring of 

wellfields during ISL operations, restorations, and stabilization periods are expected to limit 

potential environmental impacts. The NRC staff are not aware of any incident in which 

nonexempt portions of an ore-bearing aquifer have been contaminated by ISL operations under 

NRC regulations. Additional comments and responses related to potential groundwater 

resource impacts are provided in Section B5.20. As no specific changes were suggested by the 

comment, no changes to the draft SEIS were made in response to the comment. 

Comment: MR012-021 

Referring to the Chapter 5 (cumulative impact analysis) discussion of climate change in the draft 

SEIS, a commenter suggested the draft SEIS failed to consider the impacts of climate change 

by not disclosing all greenhouse gas emissions. The commenter noted the emissions for the 

proposed site discussed in the draft SEIS are incomplete because they do not include the 

emissions from other nuclear fuel cycle facilities such as facilities involved in uranium 

conversion, uranium enrichment, and nuclear fuel fabrication. 

Response: Evaluation of environmental impacts from other nuclear fuel cycle facilities is 

beyond the scope of the current licensing action regarding whether or not to grant a license to 

the proposed Moore Ranch ISR facility. NRC evaluates the potential safety and environmental 

impacts of other fuel cycle facilities when those facilities are proposed or their licenses are 

amended. Because the requested information is beyond the scope of the current licensing 

action, no changes were made to the SEIS in response to the comment. 

Comments: MR015-004; MR015-014; MR015-017; MR015-019; MR015-024; MR015-025; 

MR020-040; MR020-041 

One commenter stated that the draft SEIS lacked information on air pollutant emissions, and the 

impact analysis is inadequate to assess the impacts of those emissions. The commenter also 

stated that ISR projects would likely result in a deterioration of air quality due to emissions from 

drill rig engines, fugitive road dust, and uranium processing activities. The commenter 

suggested that projects similar in scope require hundreds of wells and multiple deep injection 

wells, and without a complete air quality analysis, such activity is likely to have significant 

adverse local air quality impacts. The commenter was particularly concerned about the air 

emissions from the truck-mounted diesel drilling rigs and the drilling of hundreds of wells for the 

Moore Ranch ISR project. The commenter suggested this level of development may have 

cumulative emission rates in excess of several hundred tons per year of nitrogen oxides, 

particulates, and other priority air pollutants. They requested a screening analysis be conducted 

for air emissions to identify far field impacts including visibility parameters for Class I and 

sensitive Class II air sheds. They also requested that a near field air analysis be conducted to 

evaluate direct air impacts. 

Response: In response to this and other comments, NRC staff reviewed the applicable 

sections of the draft SEIS and added more detailed information on emissions from drilling rigs, 

construction equipment, and unpaved roads (i.e., fugitive road dust) to Section 2.1.1.1.6.1 and 

Appendix D. The NRC staff also added information to Section 3.7.2 on nearby Class I and 
Appendix B 

B–100 

Class II areas that could potentially be impacted by emissions generated by the proposed 

action; and added text to Section 4.7 to clarify the NRC staff approach to evaluating impacts 

and improve the transparency of the NRC bases for impact conclusions. 

 

The NRC staff estimates of annual nitrogen oxide and particulate emissions from drilling rigs 

and construction equipment are approximately 18.1 t/yr [20 T/yr] and 0.79 t/yr [0.87 T/yr] as 

discussed in Appendix D. The NRC staff estimated the nitrogen oxide emissions could be as 

high as 29.9 t/yr [33 T/yr] if the applicant drilled all four deep disposal wells in one year; 

however, this would be a 1 year maximum, as no additional deep wells would need to be drilled 

in later years. Applicant estimates of fugitive road dust are 14.5 t/yr [16 T/yr] (EMC, 2007), and 

their close proximity to State Highway 387 limits the number of miles traveled on unpaved roads 

and the resulting dust emissions. The magnitude of the annual diesel emissions calculated by 

the NRC staff and dust emissions provided by the applicant are well below the several hundreds 

of tons suggested by the commenter. 

The differences among the commenter assumed emissions and the NRC staff and the applicant 

calculations might be the result of differing levels of understanding about the details of the 

proposed action. Perhaps the commenter is more familiar with oil and gas drilling that 

penetrates to far greater depths than the water wells proposed for the Moore Ranch ISR 

Project. Oil and gas wells can take longer to drill, require greater horsepower drilling rig 

engines, consume fuel at a higher rate, and produce greater hourly emissions. Another factor 

that may not have been considered by the commenter is the phased approach the applicant 

plans for wellfield development, constructing approximately one wellfield per year rather than all 

wellfields at once. The difference between the emissions assumed by the commenter and 

those calculated by NRC staff is significant because the commenter assumes emissions would 

be at levels that are well above the current stationary source threshold for major emitters, 

whereas the NRC staff estimates are well below this threshold. Had the NRC staff estimates 

been at the same levels assumed by the commenter, the level of the NRC staff concern for 

potential air quality impacts would be similar to that of the commenter. However, given that the 

calculated values are much lower than the values assumed by the commenter and well below 

the major source threshold, NRC staff conclude that the emissions would be unlikely to change 

the current attainment status of the region surrounding the site nor would the emissions be likely 

to destabilize the local air quality. Therefore, additional detailed quantitative air analyses are 

not warranted to support the evaluation of nonradiological air impacts. Short-term and 

intermittent, visible air emissions are possible to the local area surrounding the site when 

vehicles travel on unpaved roads. Such impacts would be reduced, but not eliminated, by road 

treatments proposed by the applicant (Uranium One, 2009). 

The scope of the air impact analysis in Section 4.7 is intentionally limited to consideration of 

non-radiological air quality impacts. This is because, as noted in the draft SEIS, radiological air 

emissions are regulated by NRC and are addressed in Section 4.13 as a public and 

occupational health and safety topic, whereas nonradiological emissions are regulated by the 

State and the EPA and are best evaluated separately in Section 4.7. 

Comment: MR015-018 

One commenter indicated the proposed project may adversely impact nearby Federal Class I 

areas, which require special protection of air quality and air quality related values such 

as visibility. 
Appendix B 

B–101 

Response: The mobile nonroad diesel emissions from construction and mobile fugitive road 

dust emissions from all phases are the emissions from the proposed action that have the 

greatest potential to impact nearby Prevention of Significant Deterioration areas based on the 

NRC staff understanding of the types and magnitudes of emissions associated with ISR facilities 

and the information provided by the applicant on this specific proposal. As discussed in 

Section 2.1.1.1.6.1, the applicant estimated fugitive road dust emissions to be approximately 

13.6 t/yr [15 T/yr] if not controlled; however, the applicant proposes to control these emissions 

by water application or other means of road treatment. 

All other emissions information reviewed by the NRC staff support the conclusion that NRC staff 

expect the proposed action would not be comparable to nor considered a major source of 

emissions (e.g., a stationary source that emits or has the potential to emit 90.7 t/yr [100 T/yr] of 

an air pollutant to 9.1 t/yr [10 T/yr] of any individual hazardous air pollutant, or 22.7 t/yr [25 T/yr] 

of any combination of hazardous air pollutants as defined in Sections 501 and 112 of the Clean 

Air Act). While NRC staff recognize the stationary source requirements, by definition, do not 

apply to mobile sources of emissions, these requirements apply to the same types of air 

pollutants that are emitted by the mobile sources proposed by the applicant and the threshold 

values are the levels of emissions that trigger a substantial increase in the requirements that 

must be met to ensure the protection of air quality. NRC staff conclude that such emissions 

(i.e., well below the major source thresholds) in an area with meteorology favorable for 

dispersion would be unlikely to impact air quality in the nearest Class I area to the proposed 

action. The Class I area, Wind Cave National Park, is located about 188 km [117 mi] to the east 

of the Moore Ranch site. Cloud Peak Wilderness Area, the closest Class II area to the 

proposed action located about 124 km [77 mi] to the northwest of the Moore Ranch site is also 

unlikely to be impacted by the magnitude of proposed emissions-generating activities. In 

addition to the magnitude of emissions and distance, the predominant wind direction at the 

proposed site is from the southwest and, therefore, would carry emissions to the northeast, 

away from the Class II area. 

While the NRC staff analysis of emissions within the context of Clean Air Act regulations 

supports the assessment of potential environmental impacts that is required by the NEPA, as 

amended, the authority to enforce Clean Air Act Regulations in Wyoming rests with the WDEQ, 

and they are responsible for making applicability and compliance decisions regarding the 

regulations that implement the Clean Air Act. In that role, the WDEQ is currently evaluating the 

applicant air quality construction permit. If a permit is granted, it is expected to clarify what 

additional air quality permits would be required for the proposed action and could specify 

additional controls to limit emissions (e.g., radon, fugitive road dust controls) based on the NRC 

staff review of other ISR facility construction air permits (WDEQ, 2009; WDEQ, 2010). Should 

the air quality in the nearby Class I areas become degraded in the future, the WDEQ has the 

authority and would be expected to take appropriate corrective actions to reestablish attainment 

air quality in these protected areas. 

In response to this and other comments about the potential impacts of air emissions, NRC staff 

updated the discussion of proposed air emissions in Section 2.1.1.1.6.1 of the draft SEIS and 

provided, in a new Appendix D, supporting calculations of mobile nonroad diesel emissions from 

well drilling activities and construction equipment. The air quality impact analysis discussion in 

SEIS Section 4.7 was also updated to reflect the updated emissions information. 
Appendix B 

B–102 

Comment: MR015-037 

A commenter suggested NRC expand the discussion of greenhouse gas emissions and climate 

change in the draft SEIS. Specifically, they requested NRC staff consider the projected regional 

climate changes and the project contribution to these changes. They also requested NRC staff 

quantify the annual and cumulative greenhouse gas emissions and discuss the link between 

greenhouse gas emissions and climate change. A discussion of mitigation measures for 

greenhouse gas emissions was also requested. 

Response: To address these and other comments regarding the need for NRC staff to 

consider and evaluate the potential impact of greenhouse gas emissions on the global climate, 

NRC staff have calculated annual and cumulative CO2 emissions from applicant use of diesel 

construction equipment during construction and decommission of the production wellfields and 

facilities. Because operating ISR facilities are not major sources of CO2 or other greenhouse 

gas emissions, the construction equipment emissions (including well drilling rigs) produced 

during both construction and decommissioning phases are expected by the NRC staff to 

represent the majority of greenhouse gas emissions from the proposal. The emissions 

estimates are documented in a new Appendix D and summarized in Section 2.1.1.1.6. The staff 

also added an evaluation of potential impacts to climate from the calculated construction 

equipment emissions from the proposed facility in Section 4.7. The cumulative air impact 

analysis was also updated to evaluate the impact of the emissions in the context of other past, 

present, and reasonably foreseeable future actions. The revised impact analyses included 

discussion of the current understanding of the link between greenhouse gas emissions and 

global climate change. Based on the nature of the emissions (e.g., construction equipment) and 

the lack of available CO2 mitigations for such equipment, Section 5.7.1.5 was added to the 

SEIS. These general mitigation measures discussed in Section 5.7.1.5 would be implemented 

to minimize the overall GHG emissions at the proposed Moore Ranch Project. 

 

Comments: MR020-034; MR020-035 

Referring to page 4-43 of the draft SEIS (Section 4.7, Meteorology, Climatology, and Air Quality 

Impacts), a commenter noted that no project-specific emissions estimates were provided in the 

draft SEIS. The commenter noticed that the draft SEIS references GEIS Section 2.7.1, which 

includes emissions estimates for the Crownpoint ISR facility from a 1997 NRC Final 

Environmental Impact Statement (NRC, 1997). The commenter indicated the draft SEIS did not 

discuss how that facility, and therefore its emissions estimates, relate to the proposed facility. 

The commenter also suggested that the referenced emissions estimates from 1997 were not 

current and should be updated. 

Response: In response to this and other comments about the potential impacts of air 

emissions, NRC staff updated the discussion of proposed air emissions in Section 2.1.1.1.6.1 of 

the draft SEIS and provided, in a new Appendix D, supporting calculations of mobile nonroad 

diesel emissions from well drilling activities and construction equipment. NRC staff also 

updated the air quality impact analysis discussion in SEIS Section 4.7 to reflect the updated 

emissions information. Text was also added to SEIS Section 4.7 to compare attributes of the 

Crownpoint facility and the proposed action to establish a more transparent basis for adopting 

the GEIS air impact analyses in the SEIS. 

Comment: MR020-036 

Referring to page 4-45 of the draft SEIS (Section 4.7, Air Quality Impacts), a commenter 

expressed that while there is a discussion of air quality impacts, neither the draft SEIS nor GEIS 

have an air impact analysis. 
Appendix B 

B–103 

Response: While the commenter was not specific about the type of impact analysis that was 

expected, some additional clarification regarding some of the limitations that affect the content 

of Section 4.7 may be informative. First, Section 4.7 of the draft SEIS describes the potential 

impacts to nonradiological air quality based on the NRC staff review of the proposed action that 

was summarized in draft SEIS, Chapter 2, and the accessible environment that was 

summarized in SEIS, Chapter 3. The NRC staff approach to documenting the impact analyses 

in the Chapter 4 impact sections is to avoid repetitive discussions of information that was 

previously discussed in prior chapters by referencing and summarizing discussed information. 

This approach may have contributed to an appearance of incompleteness. In response to the 

comment, the NRC staff have reviewed the section, incorporated additional references and 

discussion of referenced information to add transparency to the support for the analysis and the 

bases for conclusions. Another factor that limits the scope of the air impact analysis is that the 

analysis in Section 4.7 is intentionally limited to consideration of nonradiological air quality 

impacts. This is because, as noted in the draft SEIS, radiological air emissions are regulated by 

NRC and are addressed in Section 4.13 as a public and occupational health and safety topic, 

whereas nonradiological emissions are regulated by the State and the EPA and are best 

evaluated separately in Section 4.7. The NRC staff evaluation of potentially nonradiological 

impacts in Section 4.7 of the draft SEIS is further limited because as stated in that section 

and in the GEIS, ISR facilities are not major emitters of nonradiological air pollutants and, 

consistent with NRC NEPA implementing regulations at 10 CFR Part 51, Appendix A (Item 7), 

the level of information considered in detail reflects the depth of analysis required for 

sound decisionmaking. 

In response to this and other comments, the NRC staff reviewed the applicable sections of the 

draft SEIS and added more detailed information on emissions to Section 2.1.1.1.6.1 and 

Appendix D; added information on nearby Class I and Class II areas to Section 3.7.2 that could 

potentially be impacted by emissions generated by the proposed action; and added text to 

Section 4.7 to clarify the NRC staff approach to evaluating impacts and improve the 

transparency of the NRC staff bases for impact conclusions. The additional emissions 

information confirms the proposed Moore Ranch ISR project would be a minor source of 

nonradiological emissions that the NRC staff conclude would be unlikely to change the current 

attainment status of the region surrounding the site nor would the emissions be likely to 

destabilize the local air quality. Short-term and intermittent, visible air emissions are possible to 

the local area surrounding the site (for example when vehicles travel on unpaved roads). 

Comments: MR020-037; MR020-038; MR020-047 

One commenter, referring to Section 4.7, Meteorology, Climatology, and Air Quality Impacts, 

expressed that the draft SEIS discusses potential local impacts of carbon monoxide and 

particulate emissions, as well as impacts to particulate matter NAAQS without providing bases 

for the impact conclusions. The commenter highlighted another statement in the SEIS section 

that describes the insignificance of pollutant emissions that present a potential for cumulative 

impacts as unsupported by any emission inventory or modeling. 

Response: In response to this and other comments, the NRC staff reviewed draft SEIS 

Section 4.7 and added text to clarify the NRC staff approach to evaluating impacts and to clarify 

the NRC staff bases for impact conclusions. The revisions included consideration in Section 4.7 

of the detailed information on emissions from drilling rigs, construction equipment, and unpaved 

roads (i.e., fugitive road dust) that was added to Section 2.1.1.1.6.1 and Appendix D in 

response to other comments. The specific statement about particulate matter and compliance 
Appendix B 

B–104 

with NAAQS emphasized by the commenter was paraphrasing impact conclusions from the 

GEIS, and the text was clarified to more explicitly associate the statement with the GEIS. The 

statement in draft SEIS Section 4.7 about cumulative impacts was deleted because cumulative 

impacts are addressed in SEIS, Chapter 5. 

B5.24.4 References

CEQ (Council on Environmental Quality), 2010. “Draft NEPA Guidance on Consideration of the 

Effects of Climate Change and Greenhouse Gas Emissions.” Letter (February 18) from Nancy 

Sutley to the Heads of Federal Departments and Agencies. Washington DC: CEQ. 

EMC (Energy Metal Corporation US), 2007. “Application for USNRC Source Material License, 

Moore Ranch Uranium Project, Campbell County, Wyoming, Environmental Report.” Casper, 

Wyoming: Uranium 1 Americas Corporation. ADAMS Accession Nos. ML072851222, 

ML072851229, ML072851239, ML07285249, ML07285253, ML07285255. October 2. 

Mackin, P.C., D. Daruwalla, J. Winterle, M. Smith, and D.A. Pickett, 2001. NUREG/CR–6733, 

“A Baseline Risk-Informed Performance-Based Approach for In-Situ Leach Uranium Extraction 

Licensees.” Washington, DC: NRC. September. 

NRC (U.S. Nuclear Regulatory Commission), 1997. NUREG–1508, “Final Environmental 

Impact Statement To Construct and Operate the Crownpoint Uranium Solution Mining Project, 

Crownpoint, New Mexico.” Washington, DC: NRC. February. 

NRC, 2009. “Uranium Recovery Policy Regarding: (1) The Process for Scheduling Licensing 

Reviews of Applications for New uranium Recovery Facilities and (2) The Restoration of 

Groundwater at Licensed Uranium In-Situ Recovery Facilities.” Regulatory Information 

Summary 2009-05. ADAMS Accession No. ML083510622. April 29. 

Karl, T.R., J.M. Melillo, and T.C. Peterson,eds., 2009. “Global Climate Change Impacts in the 

United States”. New York City, New York: Cambridge University Press. 

Uranium One (Uranium One Americas), 2009. “Response to Request for Additional Information 

for the Moore Ranch In-Situ Uranium Recovery Project License Application (TAC JU011).” 

ADAMS Accession Number ML092450317. August 31. 

WDEQ (Wyoming Department of Environmental Quality), 2010. “Re: Permit No. CT-7896.” 

Letter (January 4) from D.A. Finley to J. Cash, Lost Creek ISR, LLC. Cheyenne, Wyoming: 

WDEQ, Air Quality Division. 

WDEQ, 2009. “Re: Permit No. CT-8644.” Letter (October 2) from D.A. Finley to M. P. Thomas, 

Uranerz Energy Corporation. Cheyenne, Wyoming: WDEQ, Air Quality Division. 
Appendix B 

B–105 

B5.25 Historical and Cultural Resources 

B5.25.1 Potential Impacts to Cultural, Historical, and Sacred Places 

Comment: MR007-005 

One commenter requested a text change to indicate that, under conditions in its license, the 

applicant would likely be required to stop work upon discovery of previously undocumented 

historical or cultural resources. 

Response: NRC acknowledges this comment and has revised text in SEIS Section 4.9.1.1 to 

address inadvertent discovery. 

Comment: MR007-006 

One commenter noted that contrary to the Moore Ranch SEIS text the Wyoming SHPO does 

not possess the legal authority to require that work stop upon discovery of previously 

undocumented historic or cultural resources, etc. 

Response: NRC acknowledges the comment. SEIS Section 4.9.1.2 has been revised in 

response to this comment. 

Comment: MR007-007 

One commenter stated that the Moore Ranch SEIS is a federal undertaking. As such, the 

requirements of Section 106 of the NHPA apply regardless of land ownership, and 

minimization/mitigation of adverse effects is required. 

Response: Any Federal undertaking defined in 36 CFR 800.16(y) is subject to Section 106 of 

the NHPA regardless of land ownership. Text in SEIS Section 5.9 has been revised to clarify the 

status of the Moore Ranch as a Federal undertaking. 

Comment: MR009-035

One commenter noted that the Executive Summary states, “The identified eligible sites would 

be avoided and; therefore, there would be no impact.” The commenter further states that while 

technically correct, the nearest eligible site is located over 1 mile away from the current 

proposed areas of surface disturbance. 

Response: NRC acknowledges this comment. Because of the general nature of the comment, 

no revisions were made to the SEIS. 

B5.25.2 License Conditions to Address Potential Impacts to Historical and 

Cultural Resources 

Comments: MR009-036; MR009-037; MR009-038; MR009-292 

One commenter stated the applicant did not propose the preparation of an Unidentified 

Discovery Plan and is not aware of any NRC guidance that discusses the contents or 

requirements of such a plan. The Executive Summary states, “If any identified historic or 

cultural resources were encountered during the construction phase of the proposed Moore 

Ranch Project, they would be evaluated following procedures in an Unidentified Discovery Plan 

developed prior to initiation of construction.” This text is incorrect. 
Appendix B 

B–106 

Response: The development of an Unidentified Discovery Plan is an NRC proposed mitigation 

measure. This proposed mitigation measure was not mentioned within SEIS Section 4.9. Since 

the issuance of this SEIS, the Wyoming SHPO has concurred with the NRC finding that no 

historic properties would be affected by the proposed action. The SHPO noted in its November 

3, 2009, letter that, “If any cultural materials are discovered during construction, work in the area 

shall halt immediately, the federal agency and SHPO staff be contacted, and the materials be 

evaluated by an archaeologist or historian meeting the Secretary of the Interior’s Professional 

Qualification Standards (48 FR 22716, Sept 1983).” The staff concur with this 

recommendation. Additionally, the applicant has agreed to condition its license (if issued) to 

include a stop-work provision in case historic and cultural resources are encountered. The 

SEIS Executive Summary and Chapter 4 were revised in response to this comment. 

Comment: MR013-017

One commenter stated that NRC should be more specific in each final SEIS as to when license 

conditions are imposed on its licensees with respect to control (e.g., elimination or mitigation of 

a potential impact) so that members of the public and interested stakeholders are aware that 

NRC is regulating that activity. 

Response: NRC acknowledges this comment. With respect to cultural resources, a license 

condition can address ISR operators regarding an ongoing responsibility to monitor for 

unidentified historic and cultural resources during site construction and operation and, if and 

when such resources are identified, to cease operations and seek appropriate consultations 

with State and Federal agencies. Because of the general nature of this comment, no specific 

changes were made to the SEIS in response to this comment. 

B5.25.3 Historical and Cultural General 

Comment: MR007-002 

One commenter noted that while the 50-year cut-off date for possible inclusion on the NRHP is 

a good rule of thumb, it is not a hard and fast rule, which fully excludes sites younger than that 

for inclusion. 

Response: NRC acknowledges this comment. There is a general stipulation that a resource is 

50 or more years old, however, there are exceptions to this criteria if the property displays 

unique, outstanding, or ethnographic characteristics that would deem it eligible for listing on the 

NRHP. SEIS Section 3.9.1 has been revised in response to this comment. 

Comment: MR007-003 

One commenter stated the Moore Ranch SEIS incorrectly titled Section 3.9.3 Historic Properties 

Listed in the National and State Registers. The commenter noted that that the State of 

Wyoming does not maintain a Register of Historic Places. 

Response: NRC agrees with this comment. The title and text in Section 3.9.3 has been 

revised in response to this comment. 

Comment: MR007-004 

One commenter requested clarification in Moore Ranch Section 4.9.1.1.1. The text, in part, 

discusses eligibility for the NRHP under criteria in 36 CFR 60.4(a)-(d) or Traditional Cultural 

Properties, or both. Per National Register Bulletin 38, “Guidelines for Evaluating and 

Documenting Traditional Cultural Properties,” in order for a property to be eligible as a 
Appendix B 

B–107 

Traditional Cultural Properties, it must be eligible under one of the four criteria of eligibility set 

forth in 36 CFR 60.4. This should be clearly stated in the document. 

Response: NRC acknowledges this comment. The Moore Ranch SEIS Sections 4.91.1 and 

1.7.2 have been revised in response to this comment. 

Comments: MR009-107; MR009-151 

The applicant notes that in Section 2.2.3, Alternate Site Location, the discussion states that the 

alternate plant site locations would have resulted in potential impacts to cultural resources. The 

applicant further notes the response to environmental report RAI 2.5 Number 1, which 

discusses the plant site alternatives and does not discuss cultural resources because surveys 

have already been conducted in both areas, and potential sites are avoided. The applicant 

suggests revisions to Section 2.2.3. 

Response: NRC acknowledges this comment. SEIS Section 2.2.3 has been revised in 

response to this comment. 

Comment: MR009-220 

One commenter noted the current SHPO eligibility of the site was not accurate in the Moore 

Ranch SEIS. 

Response: NRC acknowledges this comment. Section 4.9.1.1 has been revised to reflect the 

November 2009, Wyoming SHPO decision that states the sites are ineligible. 

Comment: MR009-286 

The applicant requested that NRC reference the fact that ongoing monitoring and protection of 

historic and cultural resources will be required under a license condition. 

Response: NRC acknowledges this comment. SEIS Section 5 or 6 has been added to 

address this comment. 

Comments: MR020-048; MR020-049 

One commenter stated that the shift from recapping the GEIS to describing the additional 

findings of the SEIS is abrupt and confusing. Additionally, the commenter requests clarification 

on the status of eligibility of the sites on the Moore Ranch Project area. 

Response: NRC acknowledges this comment. The SEIS has been revised to clarify the 

language and to incorporate a November 3, 2009, letter from the Wyoming SHPO. This letter 

concurs with the NRC finding that the sites located in the project area are ineligible for listing on 

the NHRP. Appendix A of the final SEIS contains a copy of this letter. 

Comments: MR020-053; MR020-54 

One commenter noted a lack of discussion of Tribal impact, specifically stating that the CEQ 

guidance recommends considerations in the EJ analysis of impacts on Tribal cultural and 

subsistence resources. Although NRC does consider itself bound by CEQ guidance, the GEIS 

specifically requires consideration of those resources for sites in the Nebraska-South DakotaWyoming Uranium Milling Region. It notes the importance of hunting, gathering, and cultural 

resources to Tribal populations in the region. The Moore Ranch site is located within this 

region. Although the SEIS considers cultural resources outside the environmental justice 

context (and finds them to be small), it does not discuss them in the environmental justice 
Appendix B 

B–108 

analysis. An impacts on cultural resources discussion should be added to the environmental 

justice section. Furthermore, there is no indication that Tribal subsistence resources were 

considered at all. (The SEIS notes that there are large herds of antelope and deer in the project 

area, and at least some of the project surface area is not privately owned.) Regardless of 

whether the SEIS correctly identified the impact area, it is possible that Tribal members from 

outside the area use cultural and subsistence resources within the area. Therefore, that 

possibility should either be eliminated by a specific analysis of Tribal use, or impacts on cultural 

and subsistence resources should be addressed. 

Response: NRC acknowledges this comment. As the GEIS notes the importance of hunting, 

plant gathering, and cultural resources to Tribal populations in the area, the text has been 

revised to provide justification for the conclusions that there would be no impacts on EJ issues 

in regards to Tribal land use within the specific project area. 

B5.25.4 References 

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

Part 800. “Protection of Historic Properties.” 

36 CFR Part 60. Code of Federal Regulations, Title 36, Parks, Forests and Public Property. 

Part 60, “Natural Register of Historic Places.” 

B5.26 Socioeconomics 

Comment: MR018-008 

One commenter expressed concerns over the two mining districts in Wyoming being split. 

Response: The two mining districts were developed for analysis in the GEIS. Although the 

SEIS is tiered from the GEIS, the SEIS includes site-specific analysis of socioeconomic factors 

for the Moore Ranch project site. The SEIS uses a Region of Influence limited to the project site 

area (Campbell County). 

Comment: MR018-009 

One commenter expressed concerns that political subdivisions would cause socioeconomic 

data to be collected incongruently. 

Response: The SEIS uses a Region of Influence limited to the project site area (Campbell 

County). Socioeconomic information pertaining to these counties was derived from US Census 

Bureau information, in addition to different State agency data. Therefore, socioeconomic 

information in the SEIS is limited to the project area and is taken from resources that typically 

standardize their collection methods. 

Comment: MR018-010 

A commenter expressed concerns about using 10 year old US Census Bureau data in the 

socioeconomic analyses. 

Response: The GEIS relies on 2000 Census data, which is based on the actual count. The 

SEIS uses the latest U.S. Census Bureau American Community Survey estimates, which are 

based on the 2000 Census. The SEIS also uses current State and county estimates. 
Appendix B 

B–109 

Comments: MR009-015; MR009-230 

The commenter requested that socioeconomic impacts be divided up front in a positive or 

negative category. 

Response: Although positive and negative descriptions can be used in describing 

socioeconomic impacts, they are subjective and are not typically used in NRC licensing reviews. 

As a regulatory agency, the NRC must remain impartial to the socioeconomic negative and 

beneficial effects associated with the proposed action. This comment does not present any 

significant new information or arguments that would warrant a change to the final SEIS. 

Comment: MR009-231 

One commenter requests that the SEIS provide specific examples of industrial activities that are 

larger in scale than an ISR project. 

Response: The commenter refers to Chapter 4, Section 4.11.1.1 that describes the small size 

of the construction workforce in relation to other construction projects. NRC has revised the 

final SEIS in response to this comment. 

Comments: MR009-232; MR009-235 

One commenter stated that the SEIS mentions two different numbers of workers expected for 

staff operations and during the construction phase (40–60 workers vs. 50 workers). 

Response: The comment refers to Chapter 4, Section 4.11.1.1 that describes the number of 

operations workers for the proposed action (Alternative 1). NRC has revised the final SEIS in 

response to this comment. 

B5.26.1 Reference 

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

B5.27 Public and Occupational Health 

B5.27.1 Impacts to Members of the General Public 

Comment: MR015-027 

One commenter who requested the SEIS include an analysis of the potential use of evaporation 

ponds, further requested that this analysis include radon emission estimates and comparison to 

applicable Clean Air Act requirements, which could be significant. 

Response: The draft SEIS did not evaluate the use of evaporation ponds because evaporation 

ponds were not included in the applicant proposal, and that proposal was the focus of the NRC 

staff environmental review. However, in response to this and other comments, additional 

information was provided in SEIS Sections 2.1.1.2 and 4.14.1.2 to discuss and evaluate 

potential environmental impacts of options for liquid waste water disposal that were not 

proposed by the applicant. That evaluation of wastewater disposal options includes 

consideration of the use of evaporation ponds and how the potential environmental impacts 

compare with the applicant proposal and other liquid waste management options. The waste 
Appendix B 

B–110 

management options are discussed at a general level of detail with regard to radon emissions 

because there are various implementation options that an applicant could present that would 

affect the amount of radon emitted from a specific proposal. Additional information is discussed 

in the following paragraphs to address the commenter concern that radon emissions from 

evaporation ponds, if used in a modified proposed action, could lead to significant 

environmental impacts. 

The amount of radon that might be emitted if an evaporation pond or ponds were added to the 

current Moore Ranch ISR proposal can be approximated from radon emissions information 

provided in the applicant proposal (EMC, 2007). To calculate the emission estimates, the 

applicant used NRC accepted methods (NRC, 1987) to estimate the annual activity of radon 

that would be transferred to production fluids from the decay of radium in the ore body. This 

approach considered variables such as the average production flow rate (i.e., the amount of 

lixiviant that would be circulated annually through the ore body and pumped to the surface) and 

the radium content of the ore body. Assuming the radon is in secular equilibrium with the 

radium in the ore body, the applicant estimated 94.83 TBq/yr [2,563 Ci/yr] of radon would be 

emitted if all radon in the pumped lixiviant were allowed to escape to the open air. 

The amount of this potential total annual radon emission that could be released from an 

evaporation pond would be proportional to the amount of lixiviant (and, therefore, dissolved 

radium) that is diverted from the processing circuit as process bleed (1.0 percent of the 

production flow rate from the applicant proposal) or approximately 0.95 TBq/yr [26 Ci/yr]. This 

level of emission is well below the applicant annual estimate of 22.37 TBq [604.7 Ci] from all 

proposed releases. 

The applicant evaluated the potential offsite dose impacts of emitting 22.37 TBq/yr [604.7 Ci/yr] 

of radon using the MILDOSE code (Argonne National Laboratory, 1989). This resulted in a 

0.008 mSv/yr [0.8 mrem/yr] dose at the property boundary. Because the calculated dose is 

proportional to the emission, the dose from the calculated evaporation pond radon emission 

would be approximately 0.0003 mSv/yr [0.03 mrem/yr] (i.e., 26/604.7 × 0.8), and the combined 

dose from all proposed radon emissions with the evaporation pond emission dose added would 

be approximately 0.0083 mSv/yr [0.83 mrem/yr]. This calculated dose is a small fraction of the 

NRC 10 CFR Part 20 public dose limit of 1 mSv/yr [100 mrem/yr]. The NRC staff consider this 

calculation sufficient to demonstrate that potential public health impacts from radon releases 

would be small, and additional analyses or comparisons with other regulatory requirements are 

not necessary to support this conclusion. A licensed facility would also be required to have an 

NRC approved environmental monitoring program for radon emissions in place that would 

report measured radon values to NRC for review on a semi-annual basis. Annual NRC 

inspections would also verify that applicant safety programs are compliant with NRC regulations 

in 10 CFR Part 20 and any conditions of their license, thereby providing additional confidence 

that the facility would be operated safely and within the bounds described in the 

applicant proposal. 

Radon emissions associated with the applicant’s proposal are evaluated in SEIS 

Section 4.13.1.2.1. The use of evaporation ponds is presently not part of the applicant proposal 

for Moore Ranch. Should the applicant decide in the future to change their proposed approach 

to wastewater management, they would be required by NRC to amend their proposal, and that 

amendment would be reviewed for potential environmental impacts as well as for compliance 

with NRC safety requirements. 
Appendix B 

B–111 

B5.27.2 Impacts From Off-Normal Operations or Accidents 

Comment: MR009-249 

One commenter suggests the SEIS discussion of dose on page 4-73, line 29, should be 

considered in relation to the 40 CFR Part 190 annual limit of 25 mrem from airborne particulate 

radioactivity. 

Response: This section of the SEIS is addressing potential impacts from possible accident 

scenarios, in particular a thickener failure and spill of yellowcake slurry. As indicated in 

40 CFR Part 190, the EPA standard of 25 mrem applies to any member of the public as the 

result of exposures to planned discharges of radioactive materials to the general environment 

from uranium fuel cycle operations. The dose limit regulations discussed in the SEIS apply for 

the accident analyses and are not planned discharges; therefore, no change to the SEIS has 

been made in response to this comment. 

B5.27.3 General 

Comment: MR009-014 

One commenter suggested adding the statement that the SEIS evaluates potential public health 

and safety impacts in addition to the potential environmental impacts mentioned on page xv, 

line 8. 

Response: The NRC acknowledges the comment, and has amended the SEIS text 

appropriately to include that this draft SEIS evaluates the potential environmental and public 

health and safety impacts of the proposed action and the No-Action alternative. 

Comments: MR009-078; MR009-094; MR009-148; MR009-239; and MR013-020 

Two commenters suggested that the SEIS should be more specific about the technologies and 

processes that are employed at ISL facilities that provide additional protection of public and 

occupational health and safety. A specific example cited in the comments is downflow IX 

columns, which provide additional protections by limiting or eliminating potential public and 

worker exposure to radon gas. 

Response: This type of equipment is discussed in the SEIS, as well as the GEIS, and is part of 

the analysis in which the radiological impacts to the public and workers are evaluated as 

SMALL. Because these topics are already addressed and the impacts are classified as SMALL, 

no changes were made to the SEIS in response to this comment. 

Comment: MR009-248 

One commenter suggested additional descriptions of the systems in place to mitigate accidents 

such as spills at ISR facilities. 

Response: The primary references used in the SEIS, such as the GEIS and Mackin, et al, 

2001, go into detail on the accident analysis that is summarized in the SEIS. Therefore, no 

changes were made to the SEIS in response to this comment. 
Appendix B 

B–112 

Comments: MR009-240; MR009-241; MR013-022 

One commenter suggested the NRC staff discussion of radiation protection issues should 

reference comparisons of potential radiation dose to natural background and should not be 

limited to comparison to NRC dose limits. 

Response: Since NRC dose limits are well below natural background levels of radiation, a 

comparison of public dose from an ISL facility that is generally well below dose limits would be 

even further below natural background levels of radiation. The public generally perceives a 

marked difference from radiation exposure from man-made sources than that from natural 

background radiation levels. NRC requires that worker and public radiation doses be quantified 

as effective dose equivalent in millirem per year, which is intended to normalize doses by the 

expected health risk. This is achieved for different types of radiation and different body tissues 

by using weighting factors for radiation (alpha, beta, gamma, neutrons) and for body tissues 

(bone marrow, reproductive organs, lens of the eyes) to convert the radiation absorbed by a 

person to a common scale (in units of millirem) for determining compliance with NRC radiation 

protection requirements and for assessing the potential for harm or detriment. When this is 

accomplished, if a person is exposed to the same dose from background radiation or from 

releases from ISL facilities, there is no difference in the expected health effects. NRC staff 

understand that members of the public can perceive involuntary man-made risks as more 

hazardous than voluntary natural risks. Because the SEIS discussion is considered 

appropriate, no changes were made to the SEIS beyond the information provided in 

this response. 

Comment: MR009-251 

One commenter suggested that hydrochloric acid be added to the list of hazardous chemicals 

proposed for use at this site. 

Response: Based on information provided by the applicant in an RAI response (Uranium One, 

2009), hydrochloric acid and the associated protective provisions have been added to the SEIS. 

Comment: MR009-258 

One commenter suggested the SEIS discussion on page 4-81, line 21, should address 

occupational exposure at such a well site per NRC recent policies and statements on 

Part 40.32(e) prelicensing site construction authorizations and Part 20.2002 dose assessments. 

Response: Occupational exposure from all operations at the Moore Ranch facility is addressed 

in detail in previous sections of the SEIS and by reference to the GEIS; therefore, no additions 

have been made to the SEIS beyond this comment response. 

Comment: MR009-259

One commenter noted that data from Section 4.14.1.2 regarding calculations of radiation 

exposure resulting from deep well injections was incorrect and needed to be updated. 

Response: The sentence noted by the commenter has been removed from the SEIS (new 

Section 4.14.1.1.2) because the calculations were irrelevant to the conclusion. By definition, the 

WDEQ could not issue a permit for Class I injection if a complete exposure pathway existed that 

could result in public consumption. If deep well disposal is conducted in accordance with 

applicable UIC regulations, this type of disposal of liquid effluent would be protective of human 

health and the environment. Radiation doses to the public would be expected to be near 
Appendix B 

B–113 

zero (due to an incomplete exposure pathway) and well below the public limit of 1 mSv 

[100 mrem] per year. 

Comment: MR020-055 

One commenter recommended the statement on SEIS, page 5-18, that states, “Because 

hazardous and radioactive wastes are closely monitored throughout the United States, the 

potential impact from these activities would be expected to be SMALL” should be deleted. This 

is suggested because the commenter says not all hazardous and radioactive wastes are closely 

monitored and that monitoring does not necessarily completely guard against the occurrence 

of accidents. 

Response: The NRC acknowledges the comment, and the SEIS has been modified 

for clarification. 

B5.27.4 References 

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment. Part 190, 

“Environmental Radiation Standards.” 

Argonne National Laboratory, 1989. “MILDOS-AREA (Computer Code)-Calculation of Radiation 

Dose from Uranium Recovery Operations for Large-Area Sources.” Argonne, Illinois: Argonne 

National Laboratory. 

EMC (Energy Metal Corporation US), 2007 “Application for USNRC Source Material License, 

Moore Ranch Uranium Project, Campbell County, Wyoming, Technical Report.” Casper, 

Wyoming: Uranium 1 Americas Corporation. ADAMS Accession Nos. ML072851222, 

ML072851258, ML072851259, ML072851260, ML072851268, ML072851350, ML072900446. 

October 12, 2007. 

Mackin, P.C., D. Daruwalla, J. Winterle, M. Smith, and D.A. Pickett, 2001. NUREG/CR–6733, 

“A Baseline Risk-Informed Performance-Based Approach for In-Situ Leach Uranium Extraction 

Licensees.” Washington, DC: NRC. September.

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

NRC, 1987. “Regulatory Guide 3.59, Methods for Estimating Radioactive and Toxic Airborne 

Source Terms for Uranium Milling Operations.” Washington, DC: NRC. 

Uranium One (Uranium One Americas), 2009. “Responses to Request for Additional 

Information for the Moore Ranch In-Situ Uranium Recovery Project License Application (TAC 

JU011).” ADAMS Accession No. ML092450317. August 31. 

 
Appendix B 

B–114 

B5.28 Waste Management 

B5.28.1 General Waste Management Comments 

Comment: MR009-091 

One commenter pointed out that injection and production feed lines are discussed in the SEIS 

as surface equipment, but feed lines are actually buried. 

Response: The NRC acknowledges the comment, and the SEIS has been modified to address 

this inconsistency. 

Comment: MR009-261 

One commenter suggested that the applicant has committed to having an agreement for 

disposal of byproduct material in place before operations, not before construction, as stated in 

the SEIS. 

Response: The NRC staff acknowledge that the suggested change is consistent with NRC 

requirements with respect to byproduct material disposal, as stated in SEIS Section 4.14, and 

the SEIS has been modified. 

Comments: MR015-003; MR015-013 

One commenter was concerned with the narrow range of waste disposal alternatives and limited 

discussion regarding waste management impacts in the SEIS. 

Response: NRC staff have reviewed the discussions of waste disposal alternatives and waste 

management impacts in the SEIS. The discussions in SEIS Chapters 2, 3, and 4 have been 

modified to include additional discussion of wastewater disposal options and provide more 

detailed discussion regarding waste management impacts. 

Comments: MR018-049; MR018-050; MR018-053; MR018-054; MR018-067; MR018-074; 

MR018-076; MR018-078; MR018-081 

One commenter indicated that only estimates of solid wastes for the operations phase are 

provided and that estimates for all phases are needed to determine if adequate landfill 

capacity exists. 

Response: NRC staff has reviewed the discussions of waste management in the SEIS. As 

discussed in revised SEIS section 3.13.2, proposed activities during operations would annually 

generate approximately 1,530 m3

 (2,000 yd3), and decommissioning activities would generate 

about 45,500 m3 (59,500 yd3

) of solid waste (i.e., non-radioactive solid waste [general trash], 

construction and demolition debris, or byproduct material that complies with NRC unrestricted 

release limits). This estimated range applies to the life of the project. The discussion in SEIS 

section 3.13.2 has been modified, based on information from the applicant, to address the 

capacity and projected life of the City of Casper landfill, located in Casper, Wyoming. This 

landfill has a permitted capacity of 317,000,000 m3 (414,000,000 yd3

). 

Comments: MR018-056; MR018-097 

A commenter noted that the Wyoming Solid Waste Program encourages applicants to consider 

developing on-site recycling plans during the construction, operation, restoration, and 

decommissioning phases of facilities. The commenter also noted that a solid waste permit may 
Appendix B 

B–115 

be required, depending on the volume and location of solid waste accumulated on-site before 

transportation to a disposal facility. 

Response: The NRC staff acknowledge and appreciates the commenter encouragement of 

applicants to use recycling to reduce waste management impacts and notes that the applicant is 

required to coordinate waste management activities in accordance with applicable State and 

Federal laws. No modifications have been made to the SEIS beyond this comment response. 

Comment: MR018-068 

One commenter requested that Table 1-2, showing the waste management impact as SMALL, 

be updated because waste volumes were unknown. 

Response: Based on the NRC evaluation of the waste management issue, there is sufficient 

information about the capacity and projected life of landfills in the area to determine that the 

impact is accurately stated as SMALL. No changes were made to the SEIS in response to 

this comment. 

B5.28.2 Scope of the Assessment of Waste Management Impacts 

Comments: MR009-041; MR020-013 

Two commenters noted that during decommissioning, the potential exists for some equipment, 

materials, and buildings to require disposal as byproduct material or hazardous waste. 

Response: The NRC acknowledges the comments, and the SEIS has been modified to reflect 

these potential waste management options. 

Comment: MR015-011 

One commenter was concerned with the lack of estimates of the amount of wastewater that 

would be generated by the project. 

Response: SEIS, fig. 2-5, shows a water balance for the proposed project. Figure 2-5 contains 

estimates of 114L/min [30 gal/min] for the maximum flow rate of production bleed and 38 L/min 

[10 gal/min] of miscellaneous plant waste water that includes plant wash-down water and bleed 

stream from the elution and precipitation circuits during operations. During groundwater 

restoration, discharge from IX or reverse osmosis processes, or both, would increase by an 

estimated 380 L/min [100 gal/min]. SEIS Section 2.1.1.1.6.2 has been revised to include these 

liquid waste estimates. 

Comment: MR020-003 

One commenter wanted to know how waste management impacts were quantified or what 

thresholds were designated for the impacts classifications. 

Response: SEIS Section 4.14 discusses waste management impacts. NRC did not designate 

quantitative thresholds for the various impact classifications. In the SEIS, waste management 

impacts were often assessed in terms of the capacity or availability of treatment or disposal 

facilities. SEIS Sections 2.1.1.1.6 and 3.12 discuss the expected amounts of various wastes 

generated by the proposed action. Because the SEIS discussion is considered appropriate, no 

changes were made to the SEIS beyond the information provided in this response. 
Appendix B 

B–116 

B5.28.3 Characteristics of Wastes Generated by ISL 

Comment: MR009-095 

One commenter expressed concern that the liquid wastes section of the SEIS does not contain 

any discussion of brine from the reverse osmosis system, which is one of the most significant 

sources of liquid waste. 

Response: The NRC staff acknowledge this concern. The SEIS has been modified to include 

a discussion of liquid wastes generated during groundwater restoration. 

Comments: MR009-260; MR013-014

One commenter asserts that the discussion of waste classification within the SEIS is unclear. 

The NRC should adopt the format espoused in the Generic Environmental Report (GER) 

submitted by the National Mining Association. The GER used a format with radiological and 

non-radiological byproduct material and liquid and solid byproduct material. Another commenter 

suggested that the final SEIS be reformatted so that members of the public and interested 

stakeholders clearly understand the difference between wastes at ISL facilities that are 

classified as byproduct material and nonradiological wastes. The second commenter 

also noted that the staff should follow the format presented in the GER issued by National 

Mining Association. 

Response: The NRC staff have revised the text in Chapters 2, 3, and 4 of this SEIS in a 

manner similar to that proposed by one of the commenters to clarify the description of wastes 

generated by the proposed action. As indicated in the revised Sections 2.1.1.1.6, 3.13, and 

4.14.1, the proposed action would generate liquid and solid byproduct material, as well as other 

hazardous and nonhazardous liquid and solid wastes. As stated in these sections and in 

Section 4.2.1 of the NRC SER, all liquid byproduct material, whether radiological or not, is 

proposed for disposal via state-permitted well injection. Remaining liquid wastes consist of 

standard sanitary wastewater and uncontaminated well development and well test water. Also, 

as stated in these sections, solid byproduct material would be disposed of either at a site 

licensed to receive such waste or at a municipal waste disposal site, if the waste meets NRC 

unrestricted release criteria. Since liquid byproduct material would not be segregated according 

to its radiologic content, the NRC staff do not believe it is necessary to further distinguish 

between radiological and nonradiological byproduct material.

Comment: MR018-019 

One commenter indicated that groundwater sweep could generate more liquid waste than 

production bleed. 

Response: The NRC acknowledges that this may be true. The SEIS was modified in response 

to this comment. 

Comments: MR009-098; MR018-055; MR018-057; MR018-058; MR018-070 

One commenter was concerned that the SEIS description of handling and disposal of 

hazardous wastes was not consistent with pertinent local, State, and Federal 

regulations. Another commenter noted that the SEIS should be more specific about waste 

disposal locations. 

Response: The NRC staff has reviewed the discussions of solid waste management in the 

SEIS. Sections 2.1.1.1.6, 3.13.2, and 4.14.1 of the SEIS have been modified with more explicit 
Appendix B 

B–117 

statements with respect to types of wastes generated, proposed disposal locations, and 

compliance with pertinent State and Federal regulations governing hazardous waste handling 

and disposal. 

Comments: MR018-060; MR018-061; MR018-062; MR018-064; MR018-065; MR018-069; 

MR018-072; MR018-077; MR018-080 

One commenter indicated that the volume of solid byproduct material generated and the 

capacity of the solid byproduct material disposal sites being considered were needed to 

determine waste management impacts. 

Response: The NRC staff have reviewed the discussion regarding solid byproduct material 

management in the SEIS. The discussion in SEIS Section 3.13.2 identifies the Pathfinder 

Mines Corporation Shirley Basin site as a potential facility for the disposal of byproduct material. 

In addition, the discussion of waste management impacts in the SEIS indicates that NRC 

requires that an applicant have a byproduct material disposal agreement in place prior to 

operations. This agreement would include byproduct material generated throughout the life of 

the project, including decommissioning. The applicant is currently negotiating an agreement with 

Pathfinder Mines Corporation. The applicant has also identified the Energy Solutions disposal 

site in Clive, Utah as an alternate disposal location and is negotiating a draft disposal 

agreement with Energy Solutions . The environmental impacts of disposing a specified amount 

of byproduct material at any potential byproduct material disposal facility would be covered in 

the environmental impact statement or environmental assessment as part of the licensing of that 

disposal facility. The evaluation of the environmental impacts on the disposal facility is beyond 

the scope of this document, but is evaluated as part of the licensing process for the disposal 

facility. As stated throughout the SEIS, the local environmental impacts that result from the 

disposal of solid byproduct material would be small. Consequently, no modifications have been 

made to the SEIS beyond this comment response. 

Comment: MR018-071 

A commenter indicated that uncontaminated solid waste was not clearly defined and 

required clarification. 

Response: The NRC staff have reviewed the discussion of uncontaminated solid waste in the 

SEIS. The final SEIS revised the discussion in Section 2.1.1.1.6.3 to clarify the different types 

of solid wastes that would be generated by the proposed action. 

Comments: MR018-073; MR020-016 

Multiple commenters indicated that used oil storage and spent battery generation and disposal 

are regulated as both hazardous and solid waste by the State of Wyoming and may require 

a permit. 

Response: NRC staff have reviewed the discussion regarding used oil and spent batteries in 

the SEIS. The SEIS states that the applicant would develop management plans to meet the 

WDEQ regulatory requirements. Wyoming has primacy in the management of solid and 

hazardous wastes at the site, and Wyoming regulations would be the compliance standard. The 

applicant has proposed to dispose of both its hazardous and nonhazardous waste at the 

Casper, Wyoming landfill and special waste and diversion facility. The SEIS text in 

Sections 2.1.1.1.6.3, 3.13.1, and 4.14.1 has been modified to include additional information 

concerning waste disposal. 
Appendix B 

B–118 

Comment: MR020-004 

A commenter requested clarification of the term “other solid wastes” and noted that some 

construction materials, such as organic solvents, paints, used oil, and paint thinners, may be 

classified as hazardous wastes subject to regulation under Resource Conservation and 

Recovery Act. 

Response: The Executive Summary and Sections 2.1.1.1.6 and 3.13 of the final SEIS have 

been modified to more clearly describe waste generation and disposal during the construction 

phase of the proposed Moore Ranch Project. 

B5.28.4 Waste Treatment and Disposal Methods 

Comments: MR015-007; MR015-008; MR015-009; MR015-012 

One commenter was concerned with the deep well disposal of liquid wastes because of the 

waste water composition (radioactive and nonradioactive components) and potential impacts to 

the receiving strata and other USDW. 

Response: Uranium One has identified deep well disposal as its preferred liquid waste 

disposal option. Under the SDWA, EPA was granted primary authority to regulate underground 

injection and protect current and future sources of drinking water. EPA implements this 

responsibility through its UIC program. EPA has authorized the State of Wyoming to administer 

the UIC programs in accordance with EPA regulations. NRC expects the applicant's 

compliance with these and any other applicable regulatory requirements. The applicant is 

responsible for obtaining authorization from the State for a Class I UIC Permit. Unless 

authorized by rule or by permit, any underground injection is unlawful and violates the SDWA 

and UIC regulations. Before an NRC-licensed uranium ISL facility can begin operations at any 

project site, the applicant must obtain the necessary UIC authorizations. The terms of the UIC 

permit would dictate the concentrations of components (radioactive and nonradioactive), and 

injection rates allowable for the proposed well. In the event that the applicant is unable to obtain 

the proposed Class I UIC permit, an amendment to its NRC license application would be 

required. Any license amendment request would be subject to a safety and environmental 

review by the NRC and subject to public comment. No modifications have been made to the 

SEIS beyond this response. 

Comment: MR020-017 

One applicant pointed out that evaporation ponds used for storage of byproduct material (not 

currently considered for waste management) are considered a source of radon and subject to 

requirements of 40 CFR Part 61, Subpart W, and approval of construction is required under 40 

CFR Part 61, Subpart A. These requirements should be included in the SEIS if evaporation 

ponds are included. 

Response: The NRC staff acknowledges these requirements associated with the use of ponds 

used for storage of byproduct material. The applicant is not proposing to use evaporation 

ponds. However, the staff has included a discussion of evaporation ponds and associated 

requirements as an option under the proposed action in Section 2.1.1.2.1 of the SEIS. 
Appendix B 

B–119 

B5.28.5 Regulation of Wastes and Disposal Methods 

Comment: MR018-037 

One commenter noted that the discharge of water from wells or pipelines (from hydrostatic 

testing or from well testing and purging) onto the land surface or into surface water channels 

requires a permit. 

Response: The NRC staff acknowledge this comment. As stated in SEIS Section 4.5.2, well 

water would be discharged to the surface in accordance with approved permits from the State of 

Wyoming, which the applicant would obtain prior to any release. No further changes have been 

made to the SEIS beyond this response. 

Comment: MR018-059 

One commenter expressed concern that the SEIS contains no references to the role the State 

of Wyoming plays in authorizing additional byproduct material disposal facilities , if needed, and 

that the byproduct material is defined as solid waste by Wyoming statute and subject to state 

regulatory requirements. 

Response: The NRC acknowledges the commenter’s concern. Section 3.13.3 has been 

modified to include the permitted and current capacity of the applicant's proposed disposal site 

for this material (Pathfinder Mines Corporation Shirley Basin site). However, a discussion of 

construction and authorization of additional byproduct material disposal facilities goes beyond 

the scope of this document. Concerning the definition of byproduct as “solid waste” and the 

State of Wyoming regulatory authority thereof, the NRC agrees that such waste would be 

subject to Wyoming solid waste regulations if it meets NRC criteria for unrestricted release. 

However, byproduct material is regulated by NRC under 10 CFR Part 40 and is not “solid waste” 

according to 40 CFR 261.4(a)4. Because Wyoming is a non-agreement state, NRC retains 

jurisdiction over byproduct materials. 

Comment: MR020-012 

One commenter stated that the ISR facility may be subject to Emergency Planning and 

Community Right-to-Know Act and Toxic Substance Control Act and requested that the SEIS 

discuss the extent to which the ISR facility would comply with these regulations. 

Response: SEIS Section 4.13.1.2.3 identifies the primary regulations applicable to the use and 

storage of chemicals and includes the topics mentioned by the commenter. NRC, though not 

the regulatory authority for either of these Acts, expects its licensees to comply with these and 

all other applicable regulations. SEIS Sections 1.5 and 1.6 discuss the role of other Federal, 

Tribal, State, and local agencies in regulating and permitting an ISR facility. Because the SEIS 

discussion is considered appropriate, no changes were made to the SEIS beyond the 

information provided in this response. 

Comment: MR020-015 

One commenter was concerned that the definition in the SEIS of conditionally exempt small 

quantity generator did not fully explain the requirement for this exemption, or the consequences 

if the site fails to meet the requirements. 

Response: Section 2.1.1.1.6.4 of the SEIS has been modified to include the requirements for a 

conditionally exempt small quantity generator, as well as the consequences if the site fails to 

meet the requirements.
Appendix B 

B–120 

B5.28.6 References 

10 CFR Part 40. Code of Federal Regulations, Title 10, Energy, Part 40, “Domestic Licensing of 

Source Material.” 

40 CFR Part 61. Code of Federal Regulations, Title 40, Protection of Environment. Part 61, 

“National Emission Standards for Hazardous Air Pollutants (NESHAPS).” 

B5.29 Decommissioning 

Comment: MR009-088 

One commenter noted that the Moore Ranch SEIS discussion of the decommissioning process 

did not clearly indicate that a detailed decommissioning plan would need to be approved and 

the NRC license amended before decommissioning could begin. 

Response: NRC agrees with the comment and has revised SEIS Section 2.1.1.1.5 to state that 

NRC approval of the decommissioning plan is required prior to the start of site 

decommissioning. 

Comment: MR009-165 

A commenter stated that NRC should note that the Moore Ranch license application included a 

detailed discussion of decommissioning and decontamination planning for review. 

Response: The comment is noted. Details regarding the planning activities for 

decommissioning and decontamination are addressed in Chapter 6 of the Moore Ranch SER. 

No new information was added to the final Moore Ranch SEIS beyond the information provided 

in this response. 

Comment: MR009-211 

A commenter noted that the SEIS stated that the applicant should submit a reclamation plan for 

approval by the appropriate State and Federal agencies, but that the requirement was for the 

applicant to submit a decommissioning plan for NRC review and approval at least 12 months 

before final decommissioning commences. 

Response: The comment is noted. Section 4.6.1.4 of the final SEIS was revised in response 

to the comment. 

Comments: MR009-227; MR009-228 

A commenter noted that the Moore Ranch draft SEIS stated, “Once project operations cease, 

the central plant and support structures would be decommissioned and removed.” The 

commenter noted that the Moore Ranch license application had indicated the possibility that 

some structures could be decontaminated and released, if desired by the landowner and 

approved by the NRC. The commenter also noted that the SEIS stated, “Uranium One would 

submit a site reclamation plan to NRC in accordance with 10 CFR Part 40 before the license 

was terminated.” The commenter noted, per 10 CFR Part 40, that Uranium One would submit a 

decommissioning plan to the NRC 12 months before final site decommissioning commences. 

Response: The comments are noted. Section 4.10.1.4 of the final SEIS was revised in 

response to these comments. 
Appendix B 

B–121 

B5.33.1 Reference 

10 CFR Part 40. Code of Federal Regulations, Title 10, Energy, Part 40, “Domestic Licensing of 

Source Material.” 

B5.30 Cumulative Effects 

B5.30.1 General Comment: SEIS Does Not Adequately Address 

Cumulative Effects 

Comments: MR001-003; MR005-003; MR012-065; MR012-066; MR012-072; MR014-002; 

MR016-017; MR016-018; MR017-032 

Multiple commenters expressed concern that the SEIS does not adequately address cumulative 

effects. For example, several commenters noted that the SEIS provides a list of other EISs 

prepared by different agencies, but with no associated meaningful analysis. Other commenters 

expressed concern that cumulative impacts were presented as conclusory statements with an 

inadequate basis. Another commenter expressed concern that the SEIS only considered 

Federal actions in the cumulative effects analysis. One comment noted that the SEIS does not 

provide an adequate discussion of potential cumulative impacts from nearby uranium and oil 

and gas activity. Also, another commenter noted that the cumulative effects analysis in the 

SEIS was not transparent and was not developed with sufficient public input. 

Response: The NRC staff believe that the information presented in Chapter 5 of the SEIS is 

valid and relevant to the assessment of potential cumulative effects. Mitigation measures are 

described throughout Chapters 4 and 5 of the SEIS, and additional monitoring measures are 

described in Chapter 6. The cumulative effects analysis presented in Chapter 5 of the SEIS has 

been revised to improve the transparency and clarity of the analysis and provide a more 

detailed discussion of potential cumulative effects for critical resource areas, such as Land Use 

(SEIS Section 5.2), Groundwater (SEIS Section 5.5.2), Ecological Resources (SEIS 

Section 5.6), Air Quality (SEIS Section 5.7), and Socioeconomics (SEIS Section 5.11). 

Comments: MR012-056; MR012-058; MR012-062; MR012-063; MR012-064; 

MR016-019; MR016-020

Commenters expressed concern that the cumulative effects analysis presented in the GEIS 

(NRC, 2009) was inadequate and was used to constrain the scope of the cumulative effects 

analysis in the SEIS. For example, one commenter noted that the SEIS does not consider the 

cumulative impacts of past uranium mining and milling combined with the current project. One 

commenter noted that the GEIS deferred conclusions on the potential cumulative impacts to the 

site-specific SEIS. Because the site-specific cumulative effects analysis presented in the SEIS 

is based heavily on information presented in the GEIS, the commenter concluded that the SEIS 

does not address the NEPA requirements with respect to cumulative impacts. 

Response: The relationship between the GEIS and the site-specific SEIS is described in SEIS 

Section 1.4.1. Revisions to the GEIS are beyond the intended scope of the public comment 

process associated with the SEIS. The NRC staff believe that the cumulative impacts from past 

uranium mining and milling projects have been adequately considered. All known uranium 

recovery sites in the vicinity of Moore Ranch have been listed in Table 5.1. Locations of nearby 

uranium recovery projects are illustrated in Figures 5.1 and 5.2, while Figure 5.3 shows other 

energy development projects within a 50 mile radius of the proposed project site. The NRC staff 
Appendix B 

B–122 

believe that the information presented in SEIS Section 5 is valid and relevant to the assessment 

of potential cumulative effects. The cumulative effects analysis presented in SEIS Section 5 

has been revised to improve the transparency and clarity of the analysis and provide a more 

detailed discussion of potential cumulative effects for critical resource areas, such as Land Use 

(SEIS Section 5.2), groundwater (SEIS Section 5.5.2), Ecological Resources (SEIS Section 

5.6), Air Quality (SEIS Section 5.7), and Socioeconomics (SEIS Section 5.11). The NRC staff 

believe that NEPA requirements have been adequately addressed. 

B5.30.2 Past, Present, and Reasonably Foreseeable Future Actions 

Comments: MR010-007; MR011-006 

Two commenters stated that no studies have been conducted to identify the cumulative effects 

of locating multiple ISR facilities closely together. 

Response: The cumulative impacts analysis presented in Chapter 5 of the SEIS includes a 

discussion of past, present, and reasonably foreseeable future uranium recovery operations, 

both for conventional mining and milling and ISR technologies. All known uranium recovery 

sites in the vicinity of Moore Ranch have been listed in Table 5.1, which also includes the 

distance and direction from the proposed project site. These facilities are regulated by NRC, 

and the potential environmental impacts from these facilities are (or will be) evaluated in 

accordance with NRC NEPA requirements in 10 CFR Part 51. In addition, the cumulative 

effects analysis has been revised to improve the clarity and transparency of how past, present, 

and reasonably foreseeable future actions relating to uranium recovery were considered.

Comments: MR012-067; MR012-068; MR012-069; MR012-070; MR012-071; MR017-031 

Multiple commenters expressed concern over the possible cumulative effects that could result 

from past, present, and reasonably foreseeable future actions associated with other resource 

extraction operations in the Powder River Basin, such as CBM production, oil and gas 

production, and coal mining. For example, several commenters noted that the SEIS should 

include a disclosure of the types and amounts of contaminants released from CBM operations 

into aquifers and surface waters, and provide a detailed analysis of the incremental impacts 

from the Moore Ranch ISR. Other commenters stated that the SEIS should include an analysis 

of the potential for cross-contamination from wells associated with CBM, oil and gas, and coal 

mining operations. 

Response: Potential impacts to groundwater resources and the effects of waste management 

practices at the site are described in Sections 4.5.2 and 4.14 of the SEIS. Chapter 5 of the 

SEIS includes a discussion of other past, present, and reasonably foreseeable future actions 

associated with resource extraction in the Powder River Basin. In addition, as described in 

Section 1.7 of the SEIS, NRC has entered into an MOU with BLM to keep current on issues 

that develop with respect to these operations on public lands. The analysis presented in 

Section 5.5.2 of the SEIS has been revised to clarify the technical basis for potential cumulative 

impacts to groundwater resources in the vicinity of Moore Ranch. 

Comments: MR012-074; MR012-077; MR017-029 

Several commenters expressed concern that the cumulative impacts analysis presented in 

Chapter 5 of the SEIS did not consider impacts from past uranium mining or milling. 

Response: The cumulative impacts analysis presented in Chapter 5 of the SEIS includes a 

discussion of past, present, and reasonably foreseeable uranium recovery operations, both for 

conventional mining and milling and ISR technologies. All known past and present uranium 
Appendix B 

B–123 

recovery sites in the vicinity of Moore Ranch have been documented and listed in Table 5.1, 

which also includes the distance and direction from the proposed project site. NRC has 

regulatory authority for the radiological aspects of these facilities, and the potential 

environmental impacts from these facilities are (or will be) evaluated in accordance with NRC 

NEPA requirements in 10 CFR Part 51. In addition, the cumulative effects analysis has been 

revised to improve the clarity and transparency of how past, present, and reasonably 

foreseeable future actions relating to uranium recovery were considered.

Comments: MR015-020; MR015-021; MR015-022 

Several commenters noted specific cumulative impacts from multiple ISR facilities with respect 

to the ambient air quality, including effects on NAAQS pollutants such as nitrogen oxides, 

particulate matter, and ozone. In addition, one commenter noted that the development of 

multiple ISR facilities could result in air emission levels that could adversely affect the Air 

Quality Related Values such as visibility in Class I and sensitive Class II areas. 

Response: Ambient air quality is discussed in Section 3.7 of the SEIS, and potential impacts to 

air quality are discussed in Section 4.7. Visual resources are discussed separately in 

Sections 3.10 and 4.10 of the SEIS. These sections have been revised to address recent 

changes in the air quality requirements, and Section 5.7 incorporates these analyses 

by reference. 

B5.30.3 Specific Document Changes or Action Requests 

Comment: MR012-078

One commenter stated that the GEIS is the more appropriate document for conducting a 

cumulative impacts analysis. The commenter also suggested that NRC reissue the GEIS for 

public review and comment on its cumulative impacts analysis. 

Response: As described in Section 1.4.1 of the SEIS, the NRC staff believe that the SEIS is 

the appropriate way to update and supplement the environmental report in the GEIS. Specific 

revisions to the GEIS are beyond the intended scope of this environmental report. Because the 

relationship between the SEIS and GEIS and the tiering approach used are described in 

Section 1.4.1, no changes were made to the SEIS in response to this comment.

B5.30.4 Significance 

Comment: MR012-076

One commenter noted that the cumulative effects analysis presented in the GEIS (NRC, 2009) 

was inadequate, assuming that most site-specific cumulative impact analyses would require 

only a Level 1 or Level 2 analyses. The commenter expressed concern that this assumption 

was used to constrain the scope of the cumulative effects analysis in the SEIS. 

Response: Section 5.4 of the GEIS describes approaches to address cumulative impacts in a 

site-specific environmental impact statement. These approaches are based on cumulative 

impacts assessment guidance developed by CEQ, providing examples and assumptions that 

the NRC staff might use to determine the appropriate level of detail to analyze the potential 

cumulative effects for a given resource area. The purpose of the information in the GEIS is to 

outline one methodology that may be used in conducting cumulative effects analysis. It does 

not to prescribe a particular approach, nor does it presume a particular outcome (e.g., an impact 
Appendix B 

B–124 

significance level) in the site-specific environmental impact statement. In the examples given in 

the GEIS, a relatively lower level of detail (Level 1) might be, but not necessarily would be, 

applied to analyze cumulative impacts for a resource area. The relationship between the GEIS 

and the site-specific SEIS is described in Section 1.4.1 of the SEIS. Revisions to the GEIS are 

beyond the intended scope of the public comment process associated with the SEIS. The NRC 

staff believe that the information presented in Chapter 5 of the SEIS is valid and relevant to the 

assessment of potential cumulative effects. The cumulative effects analysis presented in 

Chapter 5 of the SEIS has been revised to improve the transparency and clarity of the analysis 

and provide a more detailed discussion of potential cumulative effects for critical resource areas 

such as groundwater and land use. 

Comments: MR017-010; MR017-011 

Two commenters addressed the potential significance of cumulative impacts associated with 

spills, noting that even small spills might be cumulatively significant for soil and groundwater 

resources. In addition, the commenter noted that the GEIS identified spills as occurring at ISR 

facilities but does not assert that these spills are necessarily cleaned up promptly. 

Response: These comments address the discussion of spills contained in the GEIS rather than 

in the SEIS. GEIS Sections 2.11.2, 4.2.3 and 4.2.4 correctly characterize the NRC approach to 

regulate and inspect ISR facilities and implement corrective actions to minimize both the 

likelihood of and the impacts from unplanned spills. Licensees are required to develop and 

implement a spill control plan prior to beginning uranium recovery operations. NRC ensures 

these procedures are correctly implemented through its inspection and enforcement process. 

GEIS Section 2.11.2 also discusses historical information with respect to spills at NRCregulated ISR facilities. No changes were made to the SEIS in response to the comments. 

Comment: MR017-030 

One commenter requested greater detail about how NRC determined the magnitude of 

cumulative impacts. Specific issues raised include whether cumulative impacts were evaluated 

on both a geographic and temporal scale, and whether groundwater impacts could be classified 

as large because the groundwater in the mining areas would never be the same. 

Response: The NRC staff believe that the information presented in SEIS Section 5 is valid and 

relevant to the assessment of potential cumulative effects. Section 5.1.2 identifies the temporal 

scale as being from 2007 to 2020. This period represents the time that NRC initially received 

the license application from the applicant (2007) through expected license termination (2020). 

The geographic scale varies by resource category and is clearly identified for each resource 

throughout SEIS Section 5. The cumulative effects analysis presented in SEIS Section 5 has 

been revised to improve the transparency and clarity of the analysis, including a more detailed 

discussion of how impact significance was determined for potential cumulative effects for critical 

resource areas, such as Land Use (SEIS Section 5.2), Groundwater (SEIS Section 5.5.2), 

Ecological Resources (SEIS Section 5.6), Air Quality (SEIS Section 5.7), and Socioeconomics 

(SEIS Section 5.11). 

Comments: MR018-063; MR018-084

The commenter (WDEQ) reviewed the draft SEIS and two other pending ISR NRC draft SEISs 

(i.e., Nichols Ranch, Lost Creek) and estimated the volume of byproduct material that would be 

generated from the three proposed facilities. The commenter estimate was based on the 

reported waste volumes for operations and aquifer restoration from the draft SEIS and the 

decommissioning waste volume reported in the GEIS (6008 yd3

, based on adding information in 
Appendix B 

B–125 

Table 2.6-1). NRC would require any solid byproduct material generated from the proposed 

facilities to be disposed at a licensed facility. The commenter estimate of the cumulative solid 

byproduct material from the three proposed ISR facilities was 16,067 m3 [21,000 yd3]. The 

commenter expressed a concern that if this volume of material were disposed in Wyoming, 

there could be a large impact. 

Response: An important aspect of the NRC staff evaluation of potential waste management 

impacts is the availability of disposal capacity. As discussed in the GEIS, NRC requires an ISR 

facility to have an agreement in place with a licensed disposal facility to accept byproduct 

material that would be associated with facility operations, aquifer restoration, and 

decommissioning. Such agreements ensure that sufficient disposal capacity for byproduct 

material would be available throughout the life of the facility. 

As discussed in draft SEIS Section 2.1.1.1.6.3, the applicant does not presently have an 

agreement in place with a licensed site to accept their solid byproduct material for disposal. The 

applicant preferred destination for disposal of byproduct material is at the Pathfinder-Shirley 

Basin site in Mills, Wyoming. If that facility does not have sufficient capacity at the time the 

request for an agreement is made, then the applicant could engage other low-level radioactive 

waste disposal facilities that are licensed to accept byproduct material. Another existing facility 

that is licensed by NRC to accept byproduct material for disposal is the Rio Algom Ambrosia 

Lake uranium mill tailings impoundments near Grants, New Mexico. Additionally, three sites are 

licensed by NRC Agreement States to accept byproduct material for disposal (i.e., the 

EnergySolutions site in Clive, Utah; the White Mesa uranium mill site in Blanding, Utah; and the 

Waste Controls Specialists site in Andrews, Texas). 

At the time of this writing, NRC has received no proposals to expand byproduct material 

disposal capacity in Wyoming. As discussed in the GEIS (Section G5.32.2), proposals for 

onsite disposal of byproduct materials at locations without available disposal capacity are 

uncommon, but if such proposals were received by NRC, they would be evaluated on a caseby-case basis against criteria in 10 CFR Part 40, Appendix A. NRC would evaluate the potential 

environmental impacts of any such proposals if and when they are received. Based on the 

disposal options currently available and the disposal agreement that NRC requires prior to 

operations, the NRC staff continue to conclude that the potential waste management impacts 

associated with the generation of byproduct material would be SMALL. 

In response to this and other comments, the NRC staff reviewed the draft SEIS and, as the 

commenter has also noted, found the reported facility waste volumes did not include estimates 

of decommissioning byproduct material. The NRC staff then calculated the amount of solid 

byproduct material that could be generated from decommissioning activities based primarily on 

information provided in the applicant surety estimate (EMC, 2007). The calculation results for 

the Moore Ranch proposal were added to the SEIS Section 2.1.1.1.6.3 discussion of) byproduct 

material expected to be generated by the proposed action. The estimates were also added to 

the revised waste management cumulative effects analysis and discussion in Section 5.14. 

 
Appendix B 

B–126 

B5.34.5 Other 

Comment: MR012-020 

A commenter noted that the cumulative impacts analysis in the SEIS should include 

consideration of the ISR facility on climate change, and also related effects that climate change 

might have on the groundwater supply for the region. 

Response: EPA issued regulations for inventorying greenhouse gas emissions on 

October 20, 2009, and on February 18, 2010. After the draft SEIS was published for comment, 

CEQ issued draft guidance to agencies on the consideration of the effects of climate change 

and greenhouse gas emissions in the context of NEPA environmental reports. NRC is currently 

evaluating the best approaches for how it will address these recent developments with respect 

to climate change and greenhouse gas emissions while meeting its responsibilities under 

NEPA. The SEIS has been updated to reflect these recent developments. 

Comment: MR012-075

One commenter expressed concern that the cumulative effects analysis presented in the GEIS 

(NRC, 2009) effectively pre-determined to what extent cumulative impacts would be analyzed in 

the SEIS. 

Response: Section 5.4 of the GEIS describes approaches to addressing cumulative impacts in 

a site-specific environmental impact statement. These approaches are based on cumulative 

impacts assessment guidance developed by CEQ, providing examples and assumptions that 

the NRC staff might use to determine the appropriate level of detail to analyze the potential 

cumulative effects for a given resource area. The purpose of the information in the GEIS is to 

outline one methodology that may be used to conduct cumulative effects analyses. It does not 

to prescribe a particular approach, nor does it presume a particular outcome (e.g., an impact 

significance level) in the site-specific environmental impact statement. The relationship 

between the GEIS and the site-specific SEIS is described in Section 1.4.1 of the SEIS. 

Revisions to the GEIS are beyond the intended scope of the public comment process 

associated with the SEIS. The NRC staff believe that the information presented in Chapter 5 of 

the SEIS is valid and relevant to the assessment of potential cumulative effects. The cumulative 

effects analysis presented in Chapter 5 of the SEIS has been revised to improve the 

transparency and clarity of the analysis and provide a more detailed discussion of potential 

cumulative effects for critical resource areas such as groundwater and land use. 

Comment: MR014-003

One commenter noted that the SEIS does not provide a discussion of mitigation measures 

that might reduce potential cumulative impacts associated with nearby uranium and oil and 

gas production.

Response: Mitigation measures are described throughout Chapters 4 and 5 of the SEIS, and 

additional monitoring measures are described in Chapter 6. SEIS Chapter 5 has been revised 

to provide a more clear and transparent evaluation of the potential cumulative impacts from 

nearby production of coal, oil and gas, CBM, and uranium. 
Appendix B 

B–127 

B5.30.6 References 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

EMC (Energy Metals Corporation US), 2007. “Application for USNRC Source Material License 

Moore Ranch Uranium Project Campbell County, Wyoming.” Technical Report, Volume 3, 

Appendix D. Casper, Wyoming: EMC. September. 

NRC (U.S. Nuclear Regulatory Commission ), 2009. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

B5.31 Environmental Justice 

Comment: MR020-052 

One commenter stated that NRC policy recommends that the minority and low-income 

proportions in the impact area be the county and state proportions. The commenter further 

states the SEIS claims that the state was selected as the area for comparison, but that the SEIS 

later correctly notes the comparison with both the state and counties. The commenter requests 

that the second paragraph should be modified to reflect this. 

Response: The commenter refers to text in Chapter 4, Section 4.12.1 that describes the 

methodology used to conduct the EJ impact assessment. NRC has revised the final SEIS in 

response to this comment. 

Comment: MR020-050 

One commenter expressed concern that the SEIS gave an insufficient justification for varying 

from NRC policy in defining the impact area of the project. The commenter states that the 

impact area of the project is too broad for the environmental justice analysis and that the data is 

misleading. The commenter further states that low-income and minority individuals may reside 

in a community very near a project site and that the analysis would skew this by analyzing a 

broad impact area. 

Response: The commenter refers to text in Chapter 4, Section 4.12 that describes the 

deviation from the NRC Policy Statement on Environmental Justice (69 FR 5240). NRC has 

revised the final SEIS in response to this comment. 

Comment: MR020-051 

One commenter states that the SEIS briefly discusses the distribution of minority individuals in 

the area but insufficiently to conclude that minority communities are not disproportionately 

impacted by the project. 

Response: The comment refers to text in Chapter 4, Section 4.12.1 that describes the 

methodology used to conduct the environmental justice impact assessment. NRC has revised 

the final SEIS in response to this comment. 

Comments: MR020-053; MR020-054 

A commenter expressed concern that Tribal cultural resources are not discussed in the 

environmental justice analysis. The commenter requested that a reference to the cultural 
Appendix B 

B–128 

resource analysis be added to the environmental justice analysis. The commenter also stated 

that there is no indication that Tribal subsistence resources were considered in the cultural 

resources section, and those resources need to be analyzed in the SEIS. 

Response: Subsistence (consumption) hunting or gathering practices were not discussed in 

the Draft SEIS. NRC has assessed the potential impact to subsistence consumption behavior 

receptors and has revised the final SEIS in response to these comments. 

B5.32 Best Management Practices 

B5.32.1 Enforcement of Mitigation 

Comment: MR012-038 

One commenter stated that the classifying groundwater impacts from leaks and spills as SMALL 

is unjustified because this relies on the assumption that mitigation measures would be effective. 

Response: As noted in SEIS Section 4.5.2., implementation of the required leak detection 

program and well MITs should mitigate the potential impacts from leaks and spills to shallow 

(near surface) aquifers and result in SMALL potential impacts. This impact conclusion is based 

on facility-specific process descriptions for the Moore Ranch Project and site-specific 

characteristics at the proposed site. In determining impact conclusions, the NRC staff reviewed 

information provided by the applicant in its license application as amended (including the 

technical and environmental reports), information and data independently collected by the staff, 

and information and data provided in the GEIS. Section 2.11 of the GEIS presents an historical 

discussion of ISL operations, and Section 2.14 provides reference to specific facilities in 

Wyoming, Nebraska, and New Mexico. The intent of the information in these sections of the 

GEIS was to inform the reader regarding which issues have historically resulted in potential 

impacts at ISL facilities and to provide a range of conditions that may be expected for each of 

the four ISL phases. No changes were made to the SEIS in response to this comment. 

Comment: MR017-018 

One commenter requested that NRC ensure mitigation measures be implemented by the 

applicant regarding protection for sage-grouse. 

Response: NRC has made a reasonable effort to provide a discussion of potential mitigation 

measures that would limit impacts to wildlife and sage-grouse; however, NRC does not have the 

statutory authority to enforce mitigation measures. NRC recognizes that the proposed project 

may not meet all of the development recommendations established by the Wyoming Governor, 

BLM, and WGFD. NRC is not bound by the WGFD recommendations or BLM guidelines that 

the proposed action may not meet the published recommendations. The applicant may be 

required to consult with appropriate agencies in order to obtain permits or be required to 

develop a mitigation plan. Mitigation measures may be stipulations of other permitting agencies 

with statutory authority. NRC believes that the wildlife analyses are supported by sufficient 

technical bases whether tiered from the GEIS or based on supplemental staff analyses. 

Because the SEIS discussion is considered appropriate, no changes were made to the SEIS 

beyond the information provided in this response. 
Appendix B 

B–129 

Comment: MR014-001 

One commenter questioned why NRC would consider licensing a project in an unconfined 

[aquifer] location, unless it can demonstrate that the [potential] impacts to water resources can 

be prevented through “enforceable and effective mitigation measures.” 

Response: The commenter is correct that the production zone “70 sand” aquifer at Moore 

Ranch is an “unconfined aquifer.” An “unconfined” aquifer is one where the water level is below 

the overlying aquitard as described in SEIS Section 4.5.2.1.2.2 and shown in Figure 4-1. The 

term “unconfined aquifer” does not mean that the overlying aquitard, which acts as the top 

confining layer to the production ore zone is missing. At the proposed Moore Ranch Project, the 

overlying aquitard that confines the top of the “70 sand” production zone is continuous across 

the entire site; however, the groundwater flow behavior of an “unconfined aquifer” is different 

than that of a “confined aquifer,” which can impact the ability to prevent and control excursions. 

The applicant provided field test data and groundwater modeling to demonstrate it could 

monitor, prevent and capture excursions from the “unconfined aquifer” in the “70 sand” 

production zone. 

Furthermore, the NRC SER will evaluate the potential for excursions and discuss the 

operational monitoring program that would consist of establishing monitoring well rings around 

each wellfield to monitor for both horizontal and vertical excursions, as discussed in 

Section 6.3.1.2 of the final SEIS. In addition, NRC will establish site-specific license conditions 

for the Moore Ranch ISR facility to address required applicant actions that would further 

demonstrate the ability to operate an ISR facility in the 70 sand “unconfined aquifer” with either 

no or minimal impacts to the environment. License conditions are enforceable, therefore, 

comparable to the “enforceable and effective mitigation measures” to which the commenter 

refers. No revisions were made to the SEIS beyond the information provided in this response. 

Comment: MR018-018 

A commenter stated that some of the measurements [depths below ground surface (bgs)] and 

quantities contradict information provided to the WDEQ in the permit application for the Class I 

injection well. 

Response: NRC acknowledges that reported formation depths to the proposed injection zones 

may have been revised after NRC received the initial license application from the applicant. 

Sections have changed from the time the applicant first submitted license application 

(i.e., environmental and technical reports) to the NRC to the time the Class I disposal 

application was submitted. Sections 3.5.2.4 and 4.5.2.1.2.3 of the Moore Ranch SEIS have 

been revised to reflect the depth to potential aquifers based on current information. 

B5.32.2 Completeness of the Mitigation Measures and Best 

Management Practices 

Comment: MR009-203 

A commenter stated that the mitigation measures presented in the applicant environmental 

report would be effective in minimizing the potential impacts of the proposed Moore Ranch ISR 

Project, and that if the NRC determined that additional mitigation measures would be required, 

then the specific requirements should be disclosed in the SEIS. 
Appendix B 

B–130 

Response: Chapter 7 of the GEIS provided a general overview of the types of best 

management practices, mitigation measures, and management actions that have been used, 

historically, at ISR facilities to avoid or reduce potential environmental impacts. The NRC staff 

have been evaluating the adequacy of the proposed safety and environmental monitoring 

programs at the proposed Moore Ranch Project as part of both the environmental and safety 

reviews. For example, the seasonal noise guidelines developed by WGFD (WGFD, 2010) were 

identified as a means to mitigate the potential impact to avian species, as discussed in Section 

4.6.1.1.2.3 of the final SEIS. NRC can only establish license conditions within the limits of 

authority granted by Congress and if a best management practice or mitigation measure 

became a license condition, they would become subject to NRC inspection and oversight at the 

Moore Ranch facility. No changes were made to the final SEIS beyond the information provided 

in this response. 

B5.32.3 General Comments Related to Mitigation Measures and Best 

Management Practices 

Comment: MR009-177 

A commenter stated that the discussion of excursions and groundwater quality in Section 4.5.2 

of the SEIS should have discussed MIT of injection wells for potential well casing failures. 

Response: NRC agrees with the commenter and revised the referenced discussion in 

Section 4.5.2 to acknowledge the performance of MITs. Additionally, operators are required to 

demonstrate that no significant leaks exist prior to operation of a Class I injection well through 

an MIT and every 5 years after for the operational life of the well. 

Comment: MR009-191 

A commenter noted that different fencing methods could be used depending on the purpose of 

the fence. 

Response: NRC agrees with the commenter and clarified the discussion in Section 4.6.1.1.2.1 

of the final SEIS in response to the comment. 

Comment: MR009-205 

A commenter noted that there is no BLM surface ownership at the proposed Moore Ranch 

Project; therefore, there would not need to be BLM concurrence on seed mixtures used for 

reseeding. 

Response: NRC agrees with the commenter and has revised the discussion in 

Section 4.6.1.2.1 of the final SEIS in response to the comment. 

Comment: MR020-044 

A commenter was concerned about air quality impacts from fugitive dust emissions during 

construction and operation of the proposed Moore Ranch Project and questioned who would 

develop and enforce a site-specific monitoring plan. 

Response: NRC does not have the statutory authority to require compliance with a site-specific 

monitoring plan regarding fugitive dust emissions. The WDEQ permitting process would be the 

mechanism used to address air quality. Best management practices, such as the application of 

water to suppress fugitive dust emissions, have been proposed by the applicant. 
Appendix B 

B–131 

Comment: MR009-039 

A commenter noted that the applicant would use dust suppression techniques, when necessary, 

to mitigate air quality impacts but did not propose to use dust suppression as a mitigation 

technique for visual resource impacts. 

Response: In the environmental report, the applicant identified that visual impacts would be 

mitigated by using harmonizing paint colors for wellfield structures, using existing topographic 

features, where possible, to screen visual impacts due to constructed features; aligning roads to 

follow existing topographic contours, where feasible; and removing construction debris from the 

area as soon as possible (environmental report, Section 5.9). The applicant stated that the 

fugitive dust arising from construction activities and vehicle traffic on the site access roads 

would have a negligible effect on air quality, and that dust suppression techniques, such as the 

application of water on unpaved roads, would further reduce the amount of dust produced. The 

SEIS was revised to clarify that mitigation measures for visual resource impacts did not 

specifically include dust suppression techniques. 

Comments: MR009-169; MR009-170 

A commenter clarified that the mitigation of soil erosion and revegetation of disturbed land areas 

would follow WDEQ-LQD rules and regulations and associated guidelines, not separate 

reclamation plans. 

Response: The NRC acknowledges that the applicant committed to perform soil erosion 

mitigation practices in accordance with WDEQ-LDQ rules and regulations, and the applicant 

committed to conduct revegetation practices in accordance with WDEQ-LDQ regulations and 

guidelines. The SEIS was revised to clarify applicant commitments. 

Comment: MR009-209 

One commenter stated that mitigation measures discussed in Section 4.6.1.2.4 of the SEIS for 

threatened and endangered species do not correlate to those discussed in Section 5.5.5 of the 

applicant environmental report. 

Response: NRC states in Section 4.6.1.2.4 that “Examples of mitigation are ...” related to spill 

procedures and fencing. NRC references two documents, the applicant environmental report 

and the NRC summary of consultations with stakeholders. Spill procedures and fencing may 

have been discussed during the NRC consultations; however, they are not included in the 

summary document. Therefore, NRC removed the reference to the NRC consultation summary 

memo from the SEIS. The reference to the environmental report does not specify a particular 

section of the environmental report where examples of mitigation are located. The applicant 

discusses mitigation measures in Chapter 5 of the environmental report, and specifically for 

ecological resources in Section 5.5 of the environmental report. The applicant specifically 

identifies timing restrictions as a mitigation measure for reducing potential impacts to threatened 

and endangered species. 

As clearly stated in the SEIS, examples of mitigation measures are discussed in 

Section 4.6.1.2.4, which does not preclude other mitigation measures that may indirectly benefit 

a resource area. Because spill response procedures and fencing are mitigation measures 

discussed in the reference environmental report that could benefit threatened and endangered 

species, NRC has retained the discussion in Section 4.6.1.2.4. Because the environmental 

report specifies timing restrictions, NRC has included timing restrictions in the SEIS as part of 
Appendix B 

B–132 

the discussion. These changes clarify that NRC provides examples of mitigation measures to 

reduce potential impacts to threatened and endangered species; however, other mitigation 

measures may be used. 

B5.32.4 References 

NRC (U.S. Nuclear Regulatory Commission), 2009. NUREG–1910, “Generic Environmental 

Impact Statement for In-Situ Leach Uranium Milling Facilities.” Washington, DC: NRC. May. 

WGFD (Wyoming Game and Fish Department), 2010. “Recommendations for Development of 

Oil and Gas Resources within Important Wildlife Habitats.” Version 6.0. Cheyenne, Wyoming: 

WGFD. April. 

B5.33 Monitoring 

Comment: MR009-034 

A commenter stated that no long-term monitoring activities have been proposed for the Moore 

Ranch Project, and that the site would be released with no restrictions following license 

termination by the NRC. 

Response: NRC agrees with the commenter. Following completion of license termination 

activities at ISR facilities, there are no restrictions on site use and there are no long-term 

monitoring activities. Page xxii of the Moore Ranch final SEIS was revised in response to 

this comment. 

Comment: MR009-075 

A commenter stated that the purpose of the ore zone restoration wells is to establish baseline 

water quality information and to determine whether restoration standards have been met after 

restoration. The commenter noted that the ore zone restoration wells are not used to 

detect excursions. 

Response: NRC agrees with the commenter. The only monitoring wells used to detect 

horizontal excursions are the perimeter monitoring wells. The monitoring wells drilled within the 

ore zone are used to collect baseline water quality information and to verify restoration 

progress, not to detect excursions. Section 2.1.1.1.3.1.3 of the final SEIS has been revised in 

response to this comment. 

Comments: MR009-267; MR009-268 

A commenter stated that the proposed air monitoring and soil monitoring program at the 

proposed Moore Ranch Project included analysis of U-nat in accordance with Regulatory 

Guide 4.14, rather than isotopic analysis of U-234, U-235, and U-238; furthermore, the 

commenter noted there would be no reason to perform isotopic analysis of uranium at an 

ISR facility. 

Response: The commenter is correct. The applicant has not proposed identifying the different 

isotopes of uranium. The proposed monitoring includes natural uranium, consistent with 

Regulatory Guide 4.14. Sections 6.2.1, 6.2.2, and 6.2.4 of the final SEIS has been revised in 

response to this comment. 
Appendix B 

B–133 

Comment: MR009-269 

A commenter stated that the phrase “outside of the license area” is imprecise and that the 

applicant has committed to monitoring all private wells within 1 km (0.6 mi) of an 

operating wellfield. 

Response: NRC agrees with the commenter. Section 6.2.5 of the final SEIS has been revised 

to clarify the location of private wells that would be monitored. 

Comment: MR009-270 

A commenter stated that the groundwater monitoring of all private wells within 1 km [0.6 mi] of 

an operating wellfield would be performed to provide an early warning of potential impacts from 

ISR operations. 

Response: Section 6.2.5 of the final SEIS includes a statement about the purpose of 

monitoring within 1 km [0.6 mi] of an operating wellfield to identify potential impacts from ISR 

operations. No changes were made to the final SEIS in response to this comment. 

Comment: MR009-272 

A commenter stated that the discussion of physiochemical monitoring in Section 6.3 of the final 

SEIS should be revised to clarify that ISR processes affect groundwater quality in the production 

zone during operations, which is exempted under an aquifer exemption, meaning that it cannot 

now nor ever in the future serve as a source of public drinking water. Restoration is designed to 

reduce such impacts, and monitoring allows protection of production zone versus adjacent, nonexempt aquifers or portions thereof. 

Response: NRC modified the text in Section 6.3 of the SEIS to discuss that the purpose of 

monitoring is to protect groundwater outside the exempt aquifer from potential contamination. 

Comment: MR009-279 

A commenter stated that monitoring wells are not placed within the wellfields to detect 

an excursion. 

Response: NRC agrees with the commenter. Perimeter monitoring wells are used to detect 

potential horizontal excursions. Section 6.3.1.2 of the final SEIS was revised for clarification. 

Comment: MR009-281 

A commenter objected to a phrase in the SEIS that stated that typical pump tests used for a 

confined aquifer are ineffective. 

Response: In response to the comment, the discussion in Section 6.3.1.2 of the Moore Ranch 

final SEIS was revised to clarify that more intensive pumping tests are required. 
Appendix B 

B–134 

B5.34 Editorial 

B5.34.1 Grammatical Editorial 

Comment: MR009-040 

A commenter noted that the following sentence in the summary appears to be in the wrong 

section. “The local economy would experience a MODERATE impact from the purchasing of 

local goods and services and taxes derived from construction equipment and other constructionrelated activities.” The commenter noted that this sentence appears in the section describing 

impacts from facility operations, not construction. 

Response: The comment is noted, and the SEIS has been revised in response to 

this comment. 

Comment: MR009-130 

One commenter noted a typographical error regarding discussion of a wildlife survey. 

Response: NRC recognizes that the sentence should reference wildlife surveys instead of 

vegetation surveys and has corrected the sentence accordingly. 

Comments: MR009-082; MR009-108; MR009-115; MR009-119; MR009-120; MR009-128; 

MR009-129; MR009-145; MR009-155; MR009-156; MR009-175; MR009-266; MR009-278; 

MR009-070; MR009-118; MR009-154; MR009-157; MR009-162; MR009-163; MR009-210; 

MR009-234; MR009-238; MR009-245; MR009-252; MR009-277 

One commenter noted that in several occurrences throughout the SEIS, references were not 

properly noted or cited. 

Response: The NRC acknowledges the need for accuracy of references. Each occurrence 

noted by the commenter was checked for accuracy and updated or modified, as appropriate. 

Comments: MR009-001; MR009-008; MR009-009; MR009-010; MR009-024; MR009-027; 

MR009-030; MR009-043; MR009-046; MR009-058; MR009-060; MR009-071; MR009-080; 

MR009-097; MR009-101; MR009-102; MR009-103; MR009-104; MR009-105; MR009-111; 

MR009-117; MR009-122; MR009-123; MR009-124; MR009-125; MR009-126; MR009-131; 

MR009-134; MR009-135; MR009-141; MR009-142; MR009-143; MR009-146; MR009-147; 

MR009-164; MR009-183; MR009-186; MR009-188; MR009-189; MR009-192; MR009-204; 

MR009-214; MR009-221; MR009-222; MR009-225; MR009-233; MR009-237; MR009-246; 

MR009-263; MR009-265; MR009-290 

Commenters suggested corrections for typographical, format, or grammatical errors in the SEIS. 

Response: Proposed changes were checked for accuracy, determined to be appropriate, and 

incorporated into the SEIS.

Comment: MR009-153 

One commenter requested that the order of two paragraphs in Section 4.2.1.4 be changed for 

consistency with other sections. 

Response: The NRC acknowledges the comment and has changed the order of the two 

paragraphs in 4.2.1.4 for clarity. 
Appendix B 

B–135 

Comment: MR009-284 

One commenter suggested a specific wording change to clarify leak detection monitoring of 

injection and production wells. 

Response: The NRC staff have reviewed the discussion of surface water monitoring in the 

SEIS. The text regarding leak detection monitoring has been modified to clarify the system 

proposed for the Moore Ranch project. 

Comment: MR013-002 

One commenter stated that as a general observation, the SEIS should be clear and consistent. 

Response: NRC acknowledges the importance of providing clear and consistent information. 

Because the comment was general in nature, no changes were made to the SEIS in direct 

response to this comment. Specific or detailed comments concerning clarity and consistency 

are addressed in Section B34.2, B34.3, and other sections of this appendix. 

Comments: MR009-051; MR009-113; MR018-085 

Two commenters noted that tables in the SEIS text needed to be updated to reflect the most 

recent information available. 

Response: The NRC agrees with the responder, and tables in the SEIS were 

updated appropriately. 

B5.34.2 Technical Editorial 

Comments: MR009-002; MR013-003 

A commenter noted that the NRC SEIS states that the application is for a new “source material 

license.” The applicant notes that the license would also need to authorize possession of 

byproduct material as defined in section 11e.(2) of the AEA. Another commenter requested the 

license not be referred to as a “source material license” but rather a “uranium recovery license” 

or a “combined source and 11e.(2) byproduct material license.”

Response: Per NRC regulations in 10 CFR Part 40, the applicant is issued a “source material 

license.” No changes were made to the SEIS in response to this comment. 

Comments: MR009-007; MR018-017

Two commenters noted that the draft SEIS referred specifically to the applicant including “two 

deep disposal wells,” and that the applicant may drill two or four deep disposal wells, depending 

on which formation is used. 

Response: NRC acknowledges the comment and has revised the language in the Executive 

Summary appropriately that two or four wells would be drilled. 

Comments: MR009-066, MR009-250 

One commenter notes that the applicant no longer plans to utilize anhydrous ammonia at the 

site, and requests that reference to it in the SEIS be removed. 

Response: NRC acknowledges the comment, and references to anhydrous ammonia have 

been removed from the SEIS. 
Appendix B 

B–136 

Comment: MR009-085 

One commenter requested that reference to “water being pumped from a different aquifer” be 

removed from the SEIS text, as the applicant would remove this option in the revised 

license application. 

Response: NRC acknowledges the comment; the reference has been removed from the SEIS, 

as requested. 

Comment: MR009-106 

One commenter pointed out that heap leach mining does not necessarily require removal of the 

ore from the ground, but it may take place in situ. 

Response: The NRC staff acknowledge this comment. The conventional use of the term “heap 

leaching” is usually in reference to ores that have been extracted from the ground. ISL is the 

term that is conventionally used to describe leaching in place. The purpose of the discussion of 

heap leaching in the SEIS is for comparison with ISR proposed at the Moore Ranch site. 

Consequently, no modifications have been made to the SEIS beyond this response. 

Comment: MR009-109 

One commenter was concerned with a reference to “hazardous or mixed waste,” with respect to 

11e.(2) byproduct material. 

Response: NRC acknowledges the comment, and the reference to “hazardous or mixed 

waste” has been removed from the SEIS. 

Comment: MR009-110 

A commenter noted that the capital cost for mechanical evaporation would be approximately 

four times greater than those for deep well disposal, not greater than that for an ISR facility. 

Response: The commenter is correct. Section 2.2.5 of the final SEIS has been revised in 

response to this comment. 

Comment: MR009-127 

One commenter noted that some minor differences in acreage were present between the 

Environmental Report and the SEIS. 

Response: NRC acknowledges that there are slight differences, but because these are simply 

due to rounding approximations, no changes were made to the SEIS or the tables therein in 

response to this comment. 

Comment: MR009-132 

One commenter stated that the latitude and longitude of the Moore Ranch project were 

stated incorrectly. 

Response: The applicant confirms a latitude and longitude for the Moore Ranch project of 

43°34'12.83" and 105o50'49.72". 

Comment: MR009-150 

A commenter noted that throughout Chapter 4, NRC concludes the analysis of impacts for each 

resource area and life cycle phase of the project by noting that site-specific conditions are 
Appendix B 

B–137 

comparable to those described in the GEIS. It would be helpful for the public if the NRC cited 

the specific section of the GEIS. 

Response: At the introduction to each life cycle phase, NRC refers the reader to the 

particular section of the GEIS that addresses each phase. The comment does not provide any 

new and significant information; therefore, no change was made to the SEIS in response to 

this comment. 

Comment: MR009-158 

One commenter noted that the annual production of yellowcake was listed incorrectly at 

40,000 pounds per year in the SEIS, rather than 4 million pounds per year. 

Response: NRC acknowledges the comment and has made the appropriate correction in 

the SEIS. 

Comment: MR009-161 

One commenter indicated that the chemical waste shipments were identified as a transportation 

impact during aquifer restoration, and there are no chemical waste shipments associated with 

the Moore Ranch Project. 

Response: The NRC staff have reviewed the discussion of transportation impacts during 

aquifer restoration in the SEIS. The SEIS has been modified to the more general term “waste 

shipments” instead of “chemical waste shipments.” 

Comment: MR009-179 

A commenter stated that the text in 4.5.2.1.2.2 regarding excursions and groundwater quality 

should be rewritten to reflect the restoration standards as specified in 10 CFR Part 40, 

Appendix A. The commenter further noted that the standard is actually baseline or MCLs, 

whichever is higher, or ACLs. 

Response: The comment is noted. Section 4.5.2.1.2.2 of the final SEIS has been revised in 

response to this comment. 

Comment: MR009-219

A commenter stated that NRC should note that the applicant “would be required,” rather than 

“would likely be required” to stop work and assess resources prior to continuing with 

construction, per a license condition. 

Response: The commenter is correct. Section 4.9.1.1 has been revised in response to 

this comment. 

Comment: MR009-255 

One commenter suggested replacing “radioactive waste” with the more specific term “11e.(2) 

byproduct material.” 

Response: The NRC agrees with the commenter. The term “radioactive waste” has been 

replaced with the more specific term “byproduct material” in the SEIS. 
Appendix B 

B–138 

Comment: MR009-256 

One commenter suggested that referring to reverse osmosis and IX waste stream as “highly 

contaminated” was inconsistent with the typical concentrations for deep well injection provided 

by the applicant. 

Response: SEIS Section 4.14.1.1.2 has been revised to clarify the discussion of the IX and 

reverse osmosis waste streams, in response to this comment. 

Comment: MR009-262 

One commenter noted that the discussion of cumulative impacts incorrectly stated the status of 

conventional uranium projects in the vicinity of the proposed Moore Ranch Project. 

Response: The NRC staff have reviewed discussion of cumulative impacts, and the SEIS has 

been modified to clarify the status of conventional uranium projects in the vicinity of the Moore 

Ranch Project. 

Comment: MR009-289 

A commenter stated that NRC cannot say that surface water “could” potentially be impacted by 

an increase in sediment yield within “Unavoidable Adverse Environmental Impacts” for 

Water Resources. 

Response: The comment is noted. The text within Table 8-1 has been revised, in response to 

this comment.

Comments: MR009-092; MR009-144; MR009-253 

Several commenters suggested revising the text in various locations to clarify meaning. 

Response: The NRC acknowledges the suggestions, and the SEIS has been modified 

accordingly to address these concerns. 

Comments: MR009-031; MR009-033; MR009-083; MR009-116; MR009-121; MR009-133; 

MR009-136; MR009-137; MR009-138; MR009-139; MR009-166; MR009-172; MR009-173; 

MR009-187; MR009-190; MR009-223; MR009-224; MR009-229; MR009-242; MR009-251; 

MR009-244; MR009-247; MR009-257; MR009-264; MR009-276; MR009-283; MR009-285 

One commenter pointed out several typographical or minor errors in technical data. 

Response: The NRC acknowledges the comment and has corrected any errors that were 

found in the technical data. 

Comment: MR009-226 

A commenter noted that the phrase “an approved site reclamation plan” should be replaced by 

the phrase “an NRC-approved decommissioning plan.” 

Response: The commenter is correct. The applicant will have a site-wide general 

decommissioning plan and initial cost estimate by the end of plant operations. Prior to any 

decommissioning activities taking place, the applicant would need to submit a detailed plan to 

the NRC 12 months prior to decommissioning, per 10 CFR 40.42. The suggested change has 

been made to SEIS Section 4.10.1.4. 
Appendix B 

B–139 

Comment: MR009-243 

A commenter pointed out a typographical error on page 4-72, lines 20 and 21 of the SEIS. 

Response: The commenter is correct. NUREG–1910, Table 4.2-2 shows Crow Butte offsite 

dose as 0.317 mSv [31.7 mrem] and Irigaray as 0.004 mSv [0.4 mrem] just as the SEIS does. 

The text in Section 4.13.1.2.1 of the final SEIS was revised in response to the comment. 

Comment: MR013-004 

One commenter stated that the final SEIS should indicate that the terms “ISL” and “ISR” can be 

used interchangeably. 

Response: SEIS Section 1.1 states that for purposes of the SEIS, “in-situ recovery” or ISR is 

synonymous with “in-situ leach” or ISL. Because the SEIS discussion already addresses this 

issue, no changes were made to the SEIS in response to this comment. 

Comments: MR018-021; MR018-022 

A commenter identified two pages in the draft SEIS where subsurface depth intervals for deep 

injection wells did not correspond stratigraphically to the geologic formations being discussed. 

Response: Sections 2.1.1.1.6.2 and 3.4.1 of the draft SEIS described that the Lance Formation 

and Fox Hills Sandstone were present at the Moore Ranch site at a subsurface depth of 1,128 

to 2,286 m [3,400 to 7,500 ft]. However, this depth interval would also include the Tullock 

Member of the overlying Fort Union Formation, which is not part of the proposed deep injection 

zone. The SEIS was corrected to indicate that the Lance Formation and the Fox Hills 

Sandstone occur at the Moore Ranch site at a subsurface depth interval of approximately 1,615 

to 2,286 m [5,300 to 7,500 ft]. 

Comment: MR018-025: 

One commenter suggested deleting “an average flow rate of 643 L [170 gal] over 9 years” from 

SEIS page 4-81, line 29 and replacing it with “500 gal/min for 10 years.” 

Response: The text in question is not a flow rate and based on the GEIS should be edited to 

be “an average flow rate of 1700 L/min [450 gal/min] over a 9 year operating period”. The SEIS 

text has been modified to reflect this correction. 

Comments: MR018-075; MR018-079 

The commenter noted that page 3-50, line 36 of the SEIS refers to the “Midwest Industrial 

Landfill” and that page 4-52, line 5 refers to a “county landfill.” The commenter points out that 

the landfill referenced is the Midwest-Edgerton Landfill that is a municipal landfill. 

Response: The reference to the landfill on pages 3-50 and 4-52 has been corrected to refer to 

the Midwestern Edgerton Municipal Landfill. 

Comments: MR001-004; MR009-064; MR009-068; MR017-015; MR018-086 

Several commenters discussed the quality of the figures in the SEIS. One commenter stated 

that the clarity of the visual figures and graphics in the draft SEIS was inadequate. This same 

commenter noted interactions with the NRC to obtain revised figures prior to the end of the 

comment period, and that only four revised figures were posted on the NRC website prior to the 

closure of the public comment period. Another commenter stated that the scale of the SEIS 

maps were inadequate for evaluation of surface resource impacts at the site-specific level. 
Appendix B 

B–140 

Another commenter noted that not all figures were up to date with the most recent 

applicant information. 

Response: The NRC staff reviewed all figures in the SEIS and determined that many 

warranted revision. The NRC staff opted to revise and improve the following figures: 2-1, 2-2, 

2-3, 2-5, 3-1, 3-2, 3-3, 3-5, 3-6, 3-7, 3-8, 3-9, 3-10, 3-11, 3-12, 4-1, and 6-1. Prior to the 

publication of the final SEIS, all revised figures were posted on the NRC website. Four of these 

revised figures were posted on the NRC website prior to the closure of the public comment 

period on March 3, 2010. In response to these comments, the figures identified in this response 

were revised to improve the quality. Figure 2-1 was updated to match the most recent applicant 

information submittal in response to these comments. 

Comment: MR002-008 

One commenter suggested that the readability of SEIS Section 3.6.3 would be improved if the 

section was reorganized using the protection status for the subcategories rather than 

the species. 

Response: NRC acknowledges that information can be organized in different manners. NRC 

opted to organize the information by species and provided Table 3-8 which provides information 

columns describing protection status by species. Because the organization in the SEIS is 

considered appropriate, no changes were made to the SEIS in response to this comment. 

Comment: MR009-026 

One commenter noted that in the Executive Summary, the discussion of ore production zone 

was out of place in a discussion about liquid waste disposal. 

Response: The NRC acknowledges the comment, and has removed the sentence from the 

Executive Summary for clarity. 

Comments: MR009-052; MR009-069; MR013-005 

Two commenters recommended that references to the proposed action as “mining” should be 

replaced with the term “milling.” 

Response: NRC agrees that the proposed action at Moore Ranch should be described as 

milling or rather than mining. NRC staff reviewed the discussions of the proposed action in the 

draft SEIS and corrected instances where the substitution of the term “milling” for “mining” 

was warranted. 

B5.34.3 Regulatory Editorial 

Comment: MR008-001 

One commenter felt that the language in the recommendations section seems full of negatives 

as opposed to more clearly written positive statements. 

Response: The NRC acknowledges the comment. 

Comment: MR008-002 

The commenter suggests that the NRC staff describe how the safety review is integrated with 

the environmental review. 
Appendix B 

B–141 

Response: As stated in Section 1.4.5, the NRC safety staff evaluate whether the applicant 

proposed action can be accomplished in accordance with the applicable provisions of 10 CFR 

Part 20 and 10 CFR Part 40, Appendix A. The SER evaluates the applicant proposed facility 

design, operational procedures, and radiation protection program to ensure that the applicable 

requirements in 10 CFR Part 20 and 10 CFR Part 40 would be met by the applicant. These 

facets of the safety review are integral to shaping the environmental review in the SEIS. The 

comment does not present any new or significant information; therefore, no change was made 

to the SEIS text in response to this comment.

Comments: MR009-004; MR013-006 

Two commenters noted that NRC should use the terms “proposed” and “potential” when 

referring to the proposed action and the impacts analyzed. 

Response: The NRC agrees with the comment, and has added the terms “proposed” and 

“potential” when referring to the site and proposed action throughout the SEIS, as appropriate. 

Comments: MR009-042; MR009-114 

A commenter noted that the NRC preliminary conclusion seems to be a negative endorsement 

of the analysis completed in the SEIS. NRC has concluded that virtually all of the impacts 

associated with the proposed Moore Ranch Project would be small and that there would be no 

long-term effects. Assuming there are no significant safety issues identified in the SER that 

would require denial of a license, then issuance of a license is a reasonable action by the NRC. 

The commenter also noted that the Preamble to 10 CFR Part 51 states that NEPA reviews do 

not rule out actions that have potentially significant impacts. So, where the NEPA review 

identified SMALL impacts and an SER with license conditions demonstrate adequate protection 

of public health and safety and the environment, NRC has to issue the license. 

Response: Per 10 CFR 51.71(f), the draft environmental impact statement will include a 

preliminary recommendation by the NRC staff in response to the proposed action. This 

recommendation is based on the NRC staff analysis of all relevant information and review of all 

other Federal permits, licenses, approvals, and other entitlements that must be obtained to 

implement the proposed action. This preliminary decision will be reached after considering the 

environmental effects of the proposed action and reasonable alternatives, and after weighing 

the costs and benefits of the proposed action. The NRC preliminary conclusion is based upon 

the regulatory requirements specified in 10 CFR Part 51 and §§ 51.75, 51.76, 51.80, 51.85, and 

51.95. The NRC staff preliminary conclusion states, “Should safety issues mandate otherwise, 

that the environmental impacts are not so great as to make issuance of a source material 

license an unreasonable licensing decision. If the proposed action presents certain safety 

issues that make licensing unreasonable, then the license will not be granted.” The comment 

provides no new and significant information; therefore, no change was made to the SEIS text. 

Comment: MR009-053 

One commenter noted that NRC should reference reports submitted by the applicant as an aid 

to consultations. 

Response: The NRC is not required to list every report completed by the applicant. The 

applicant did conduct surveys of the project area, and these reports have been reviewed by the 

NRC and SHPO. Section 1.7.2 has been revised to include additional consultation efforts to 

date and the SHPO determination that the project would have no effect on historic properties. 
Appendix B 

B–142 

Comment: MR009-065 

A commenter stated that NRC should specifically reference any secondary containment on all 

facilities, including berms or curbs, or both. This should be referenced throughout the SEIS. 

Response: The SEIS (specifically Section 2.1.1.1.2.1) provides the reader with a general 

description of the Central Plant facility, its dimensions, and a description of activities that would 

occur within that building and its immediate environs. Some clarifications were made in the 

SEIS to reference secondary containments. 

Comment: MR009-236 

One commenter requested that, for consistency, NRC add a statement to the end of 

Section 4.11.1.2 that no new or significant information was identified by the NRC staff. 

Response: The NRC acknowledges the comment and has added the requested statement to 

the final SEIS. 

Comment: MR009-254 

A commenter stated that the NRC should note that the requirement for a disposal agreement to 

be in place will be pursuant to a license condition. 

Response: The comment is noted. Section 4.14 has been revised, in response to this 

comment. 

Comment: MR009-271 

A commenter noted that the statement is not accurate. “The sampling would be conducted in 

accordance with a standard operating procedure reviewed by the NRC staff.” The commenter 

states that a full description of the sampling process was provided in an RAI response, dated 

July 11, 2008, [See section 5.12(f)]. The commenter states that since the NRC had no further 

questions or comments, this is not an open item. 

Response: Section 6.2.5 has been clarified. While the NRC does not approve standard 

operating procedures, NRC inspectors can review procedures during site inspections. 

Comment: MR009-274 

A commenter stated that the NRC should make it clear that analysis of the full Guideline 8 

parameters is only required for the first two sample events. 

Response: WDEQ does not identify the number of Guideline 8 samples that must be obtained. 

NRC would require that the number of samples of Guideline 8 parameters be adequate to 

determine the baseline conditions. No changes have been made to the text to address 

this comment.

Comment: MR009-280 

A commenter stated that NRC should add the text, “Under WDEQ requirements...” to the 

beginning of the sentence on page 6-6, line 14 to show interconnection between monitoring 

wells and the production patterns. 

Response: The commenter is correct. Furthermore, Section 5.7.8.3(4) of NUREG–1569 

states, “Once a wellfield is installed, it should be tested to establish that the production and 

injection wells are hydraulically connected to the perimeter horizontal excursion monitor wells 
Appendix B 

B–143 

and hydraulically isolated from the vertical excursion monitoring wells.” Section 6.3.1.2 has 

been revised in response to this comment. 

Comment: MR013-001 

One commenter stated that the existing SEIS language concerning the preliminary 

recommendation on issuing a license was inadequate and should be rephrased to provide a 

clear understanding that the environmental review has resulted in a finding that the license 

should be issued. 

Response: As described in SEIS Section 1.6.1, the NRC licensing process includes a detailed 

technical review of the Moore Ranch ISR Project license application, which is comprised of both 

a safety review and an environmental review. These two reviews are conducted in parallel (see 

GEIS Fig. 1.7-1). The environmental review is conducted in accordance with the regulations in 

10 CFR Part 51. The focus of the safety review is to assess compliance with the applicable 

regulatory requirements in 10 CFR Part 20 and 10 CFR Part 40, Appendix A. The NRC staff 

reviewed the SEIS language concerning the preliminary recommendation and determined that 

the text was consistent with the NRC licensing process. Because the SEIS is considered 

appropriate, no changes were made to the SEIS in response to this comment. 

Comment: MR018-042 

A commenter noted that Antelope Creek is protected through a rulemaking process. The 

commenter states that the term “suitable” gives the reader the impression that there have been 

onsite water quality assessments that have determined the suitability for all uses (recreation, 

other aquatic life, wildlife, agriculture, industry, and scenic value), which may or may not be the 

case. Please replace “suitable” with “protected.” 

Response: The comment is noted. Section 3.5.1.4 of the final SEIS has been modified in 

response to this comment. 

Comment: MR018-045 

A commenter suggested that the NRC add a sentence to Section 4.5.1.1: “Authorization from 

the Wyoming DEQ could be required when filling or crossing wetlands.” 

Response: The comment is noted. Section 4.5.1.1 of the final SEIS has been revised, in 

response to this comment. 

APPENDIX C 

ALTERNATE CONCENTRATION LIMITS 

 C–1

ALTERNATE CONCENTRATION LIMITS 

In-Situ recovery (ISR) facilities operate by first extracting uranium from specific areas called 

wellfields. After uranium recovery has ended, the groundwater in the wellfield contains 

constituents that were mobilized by the lixiviant. Licensees shall commence aquifer restoration 

in each wellfield soon after the uranium recovery operations end (NRC, 2008b). Aquifer 

restoration criteria for the site-specific baseline constituents are determined either for each 

individual well or as a wellfield average. 

NRC licensees are required to return water quality parameters to the standards in 

10 CFR Part 40, Appendix A, Criterion 5B(5). As stated in the regulations: “5B(5)─At the point 

of compliance, the concentration of a hazardous constituent must not exceed─(a) The 

Commission approved background concentration of that constituent in the groundwater; (b) The 

respective value given in the table in paragraph 5C if the constituent is listed in the table and if 

the background level of the constituent is below the value listed; or (c) An alternate 

concentration limit is established by the Commission.” 

For an alternate concentration limit (ACL) to be considered by the NRC, a licensee must submit 

a license amendment application to request an ACL. In this ACL license amendment request, 

the licensee must provide the basis for any proposed limits including consideration of 

practicable corrective actions, that limits are as low as reasonably achievable (ALARA), and 

information on the factors the Commission must consider. The NRC will establish a site-specific 

ACL for a hazardous constituent as provided in paragraph 5B(5) if the NRC finds the proposed 

limit as ALARA, after considering practicable corrective actions, and determining that the 

constituent will not pose a substantial present or potential hazard to human health or the 

environment as long as the ACL is not exceeded. 

To determine if the ACL does not pose a potential hazard to human health or the environment, 

NRC performs three risk assessments (NRC, 2003a). The first is a hazard assessment which 

evaluates the radiological dose and toxicity of the constituents in question and the risk to human 

health and environment. The second is an exposure assessment to examine the existing 

distribution of hazardous constituents, as well as potential sources for future releases and the 

potential consequences associated with the human and environmental exposure to the 

hazardous constituents. The last assessment is a corrective action assessment which evaluates 

(1) all applicant proposed corrective actions; (2) the technical feasibility of each proposed 

corrective actions; (3) the costs and benefits associated with each proposed corrective action; 

and (4) the preferred corrective action to achieve the hazardous constituent concentration which 

is protective of human health and the environment. 

To perform these assessments, the NRC staff uses a rigorous review process. Licensees must 

provide a comprehensive ACL amendment that addresses groundwater and surface water 

quality and expected impacts on human health and the environment. Such information required 

in an amendment request pursuant to 10 CFR Part 40, Appendix A, Criterion 5B(6) includes the 

following factors: 

• Potential adverse effects on groundwater quality, considering the following: 

o The physical and chemical characteristics of the waste in the licensed site 

including its potential for migration 

o The hydrogeologic characteristics of the facility and surrounding land 

o The quantity of groundwater and the direction of groundwater flow 
Appendix C 

 C–2

o The proximity and withdrawal rates of groundwater users 

o The current and future uses of groundwater in the area 

o The existing quality of groundwater, including other sources of contamination and 

their cumulative impact on the groundwater quality 

o The potential for health risks caused by human exposure to waste constituents 

o The potential damage to wildlife, crops, vegetation, and physical structures 

caused by exposure to waste constituents 

o The persistence and permanence of the potential adverse effects. 

• Potential adverse effects on hydraulically connected surface water quality, considering 

the following: 

o The volume and physical and chemical characteristics of the waste in the 

licensed site 

o The hydrogeologic characteristics of the facility and surrounding land 

o The quantity and quality of groundwater, and the direction of groundwater flow 

o The patterns of rainfall in the region 

o The proximity of the licensed site to surface waters 

o The current and future uses of surface waters in the area and any water quality 

standards established for those surface waters 

o The existing quality of surface water including other sources of contamination 

and the cumulative impact on surface water quality 

o The potential for health risks caused by human exposure to waste constituents 

o The potential damage to wildlife, crops, vegetation, and physical structures 

caused by exposure to waste constituents 

o The persistence and permanence of the potential adverse effects. 

Although state “class of use” standards are not recognized in NRC’s regulations as restoration 

standards, these standards may be considered as one factor in evaluating ACL requests for ISR 

facilities located in Wyoming. Furthermore, in considering ACL requests, particular importance 

is placed on protecting underground sources of drinking water (USDWs). The use of modeling 

and additional groundwater monitoring may be necessary to show that ACLs in ISR wellfields 

would not adversely impact USDWs. It must be demonstrated that the licensee has attempted 

to restore hazardous constituents in groundwater to background or a maximum contaminant 

level—whichever level is higher. 

Before an ISR licensee is allowed to extract uranium, the EPA under 40 CFR Part 146.4 and in 

accordance with the Safe Drinking Water Act must issue an aquifer exemption covering the 

portion of the aquifer in which the uranium-bearing rock is located. The EPA cannot exempt the 

portion of the aquifer unless it is found that “it does not currently serve as a source of drinking 

water” and “cannot now and will not in the future serve as a source of drinking water”. Due to 

these criteria, only impacts outside of the exempted aquifer are evaluated. In most cases, the 

water in aquifers adjacent to the uranium ore zones does not meet drinking water standards. 

The staff will not approve an ACL if it will impact any adjacent USDWs. Therefore, the impact of 

granting an ACL request is SMALL. 

Further guidance for the review of ACLs for ISR facilities is being developed in a revision of 

NUREG–1569 (NRC, 2003a). Existing guidance for the review of ACLs for conventional mills is 

in NUREG–1620, “Standard Review Plan for the Review of a Reclamation Plan for Mill Tailings 

Sites Under Title II of the Uranium Mill Tailings Radiation Control Act of 1978.” (NRC, 2003b). 
Appendix C 

 C–3

REFERENCES 

10 CFR Part 40. Appendix A. Code of Federal Regulations, Title 10, Energy, Part 40, Appendix 

A, “Criteria Relating to the Operations of Uranium Mills and to the Disposition of Tailings or 

Wastes Produced by the Extraction or Concentration of Source Material from Ores Processed 

Primarily from their Source Material Content.” 

40 CFR Part 146. Code of Federal Regulations, Title 40, Protection of Environment. Part 146, 

“Underground Injection Control Program: Criteria and Standards.” 

NRC (U.S. Nuclear Regulatory Commission), 2003a. NUREG–1620 “Standard Review Plan for 

the Review of a Reclamation Plan for Mill Tailings Sites under Title II of the Uranium Mill 

Tailings Radiation Control Act of 1978,” Final Report, Washington, D.C. NRC 2003 

NRC, 2003b. NUREG–1569, “Standard Review Plan for In-Situ Leach Uranium Extraction 

License Applications.” Final Report. Washington, DC: NRC. June. 

APPENDIX D 

NONROAD COMBUSTION ENGINE EMISSIONS ESTIMATES 

D–1 

NONROAD COMBUSTION ENGINE EMISSIONS ESTIMATES 

D1 INTRODUCTION 

The primary nonradiological emissions from in-situ recovery (ISR) facilities include diesel 

combustion engine emissions from construction equipment (including drilling rigs) and fugitive 

dust emissions from vehicular travel on unpaved roads (NRC, 2009, Section 2.7.1). This 

appendix provides estimates of the expected nonroad combustion engine emissions from the 

proposed action. Fugitive dust emissions are discussed in the supplemental environmental 

impact statement (SEIS) and, therefore, it is not discussed further in this appendix. 

NRC has previously evaluated combustion engine emissions associated with ISR facilities in 

prior licensing actions (NRC, 1997; 2004) and has characterized the potential impacts to air 

quality as minor. The drilling rigs that are used during construction of these facilities, in 

particular, are not presently subject to State of Wyoming new-source emissions permitting, and 

applicants that propose facilities in attainment areas (i.e., areas in compliance with ambient air 

quality standards) are not presently required by the state to document their emissions from 

these sources. Similarly, the U.S. Nuclear Regulatory Commission (NRC) has not routinely 

requested detailed nonradiological emissions information from applicants. As a result, existing 

information pertaining to ISR construction emission activities is limited. Nonetheless, to address 

recent concerns expressed in public comments on the draft SEIS about potential air quality 

impacts (EPA, 2010), representative emissions estimates are calculated in this appendix. 

Based on the similarities in design and construction of ISR facilities and the nature of associated 

nonradiological emissions, the nonroad combustion engine exhaust calculations in this section 

are based on a combination of proposal-specific and other representative information that the 

staff considers adequate to support a conservative emissions screening analysis. The current 

calculations incorporate the best available information provided by the applicant for the 

proposed action; representative information provided by other NRC applicants as applicable; 

and emissions factors provided by the U.S. Environmental Protection Agency (EPA). Mobile 

road (vehicle) combustion emissions were not calculated here because these engine emissions 

are controlled at the source by mandated emission control technology, and the magnitude of 

proposed road vehicle activity is small relative to existing road traffic (Section 4.3). 

The calculations in this appendix were conducted to support the NRC evaluation of potential 

environmental impacts to air quality from the proposed action.1

 These calculations are provided 

to meet NRC obligations, pursuant to the National Environmental Policy Act of 1969 as 

amended, to more completely disclose the potential environmental impacts from the proposed 

action. While NRC is responsible for assessing the potential environmental impacts from the 

proposed action, NRC does not have the authority to develop or enforce regulations to control 

nonradiological air emissions from equipment used by licensees. This authority rests with the 

State of Wyoming Department of Environmental Quality (WDEQ). To ensure the air quality of 

 

1

 The analysis in this appendix is based upon the applicant’s original schedule provided in its license application 

(EMC 2007, Figure 1.8-1) which included the development of three wellfields. The applicant subsequently revised its 

application in 2008 to combine wellfields 2 and 3 into one wellfield which is now wellfield 2. The analysis presented in 

this section is still applicable. 
Appendix D 

 D–2

Wyoming is adequately protected, in addition to addressing all NRC regulatory requirements 

that address radiological emissions, NRC applicants and licensees must also comply with all 

applicable State and Federal air quality regulatory compliance and permitting requirements. 

D2 NONROAD DIESEL COMBUSTION ENGINE EXHAUST EMISSIONS 

CALCULATION METHODS 

D2.1 Well Drilling Emissions Calculations 

ISR facilities are constructed using commonly available construction equipment, including truck 

mounted or mobile drilling rigs (NRC, 2009). Based on past estimates (NRC, 2004), the NRC 

staff expect well drilling activities will represent the majority of combustion engine emissions 

during the construction period. Emissions from diesel combustion engines, including drilling 

rigs, that the staff evaluated for potential impacts to air quality include nitrogen oxides (NOx), 

carbon monoxide (CO), sulfur oxides (SOx), particulate matter (PM10), formaldehyde, volatile 

organic compounds (VOC), and carbon dioxide (CO2) emissions were calculated to support the 

NRC staff evaluation of greenhouse gas emissions in the SEIS. 

Diesel emissions were estimated using emission factors provided by EPA. Emissions factors 

provide the ratio of the mass of a pollutant emitted to the atmosphere by a source engine to the 

level of activity of the emission source (Eastern Research Group, 1996). The level of activity of 

the emission source in an emission factor is represented by power output (in horsepower-hours) 

or fuel use represented by heat energy of combusted fuel in million British Thermal Units 

(MMBtu). Emission factors were developed by the EPA for different engine classes, based on 

their review of a variety of engine test data (EPA, 1996, 2004). Currently available EPA 

documentation of emissions factors for diesel combustion engines include AP-42 (EPA, 1996) 

and a more recent update of emissions factors for the EPA NONROAD model (EPA, 2004). 

The former reference (AP-42) is recognized by WDEQ as a source for emissions factors that 

may be used to estimate emissions from drilling rigs (WDEQ, 2010) while the NONROAD model 

factors represent a more current data source. For the following calculations, the emissions 

factors from AP-42 (EPA, 1996) were used. The updated emissions factors for the NONROAD 

model are considered for context in the discussion of the calculated emissions results. 

The WDEQ provided methods for calculating emissions from drilling rigs based on fuel use 

(WDEQ, 2010). The WDEQ calculation methods are from worksheets they have provided to 

minor oil and gas emitters in a proposed ozone non-attainment area in southwestern Wyoming 

(Finley, 2010). These methods were adapted to the current analysis and are summarized by 

the following equations 

 Etot,r,i = Ftot,r HCfuel EFi Uconv (D–1) 

where 

Etot,r,i ― annual total emissions for drilling rig type r and pollutant i [tons/yr] 

Ftot,r ― annual fuel use for drilling rig type r [gal/yr] 

HC fuel ― heat content of diesel fuel [Btu/gal] 

EFi,r ― emission factor for pollutant i from drilling rig type r [lb/MMBtu] 

Uconv ― unit conversion [MMBtu/1E+6 Btu][ton/2000lb] 
Appendix D 

 D–3

and 

 Ftot,r = ∑DTn,r FCr (D–2) 

where 

DTn ― duration of drilling for individual well n [hr] 

FCr ― hourly fuel consumption for drilling rig type r [gal/hr] 

Input parameters for well-drilling equipment diesel emission calculations are provided in 

Tables D2–1, D2–2, and D2–3. Proposed drilling activities include (i) drilling water wells for 

wellfield operations and associated monitoring and (ii) drilling deep disposal wells for disposal of 

operational liquid wastes. Water well drilling is expected to involve truck-mounted drilling 

equipment that requires, on average, 12 hours of drilling per well and consumes approximately 

2.5 gal of diesel fuel per hour (Cash, 2010). These operational water wells would be drilled to 

the depth of the ore body {approximately 76 to 91m [250 to 300 ft)} (EMC, 2007). Deep 

disposal well drilling would go to a greater depth (several thousand feet) relative to the water 

wells. Such drilling requires a more powerful drilling rig that consumes more fuel than a water 

well drilling rig. Completion of one deep well has been estimated by an NRC applicant to take 

approximately 528 hours of drilling and consume about 56 gal of diesel fuel per hour (Cash, 

2010). The applicant proposes to drill four deep wells, although the schedule for drilling has not 

Table D2–1. Well Drilling Input Parameters for Emissions Calculations 

Parameter Symbol Value Remarks 

Duration of drilling activities for 481 

water wells [hr] 

∑DTn,r 

n

5532 

Staff estimate for drilling 

one wellfield based on 

average per well drill time 

provided by an applicant* 

and the proposed number 

of wells for Wellfield #1 

Hourly fuel consumption for truckmounted drilling rig [gal/hr] FCr_water 2.5 Provided by an applicant* 

Annual fuel use for truck mounted 

water well drilling rigs [gal/yr] Ftot,r_water 13,830 

Staff calculated from 

drilling duration and 

hourly fuel consumption 

Duration of drilling activities for 2 deep 

waste disposal well [hr] ∑DTn.r 

n

1056 

Double the value provided 

by an applicant* for 

drilling 1 deep well 

Hourly fuel consumption for deep well 

rig [gal/hr] FCr_deep 56.25 Provided by an applicant* 

Annual fuel use for deep well drilling 

rig [gal/yr] Ftot,r_deep 59,400 

Staff calculated from 

drilling duration and 

hourly fuel consumption 

Heat content of diesel fuel [Btu/gal] HC fuel 137,000 Value from EPA AP-42† 

*Cash, 2010. 

† EPA, 1996. 

been provided. Because the proposed wellfield development is phased over a period of years 

(EMC 2007, Figure 1.8-1), for the calculation of annual emissions, the drilling of one wellfield 

and two deep wells in the first year is assumed. To account for the differences in the two 
Appendix D 

 D–4

proposed drilling operations, emissions calculations were conducted for each type of drilling 

activity (i.e., water wells, deep disposal wells). Input parameters for each activity are provided 

in Table D2–1. 

Table D2–2. Emissions Factors (EFi,) for Uncontrolled Diesel Industrial 

Engines (lb/MMBtu) 

Pollutant Value 

Nitrogen Oxides (NOx) 4.41 

Carbon Monoxide (CO) 0.95 

Sulfur Oxides (SOx) 0.29 

Particulate Matter (PM10) 0.31 

Carbon Dioxide (CO2) 164 

Formaldehyde 0.00118 

Volatile Organic Compounds 0.35 

Source: EPA, 1996. 

Table D2–3. Emissions Factors (EFi,) for Large Stationary Diesel Engines (lb/MMBtu) 

Pollutant Value 

Nitrogen Oxides (NOx) 3.2 

Carbon Monoxide (CO) 0.85 

Sulfur Oxides (SOx) 1.01 

Particulate Matter (PM10) 0.10 

Carbon Dioxide (CO2) 0.85 

Formaldehyde 7.89E-5 

Volatile Organic Compounds 0.09 

Source: EPA, 1996. 

D2.2 Construction Equipment Emissions Calculations 

In addition to the use of drilling rigs, proposed wellfield construction involves the use of common 

diesel powered construction equipment that will also contribute to air emissions. Emissions from 

this equipment were calculated using emission factors based on power output and operating 

time using the following equation 

 Etot,r,i = HPr OTr EFi Uconv (D–3) 

where 

Etot,r,i ― annual total emissions for construction equipment type r and pollutant i [tons/yr] 

HPr ― engine horsepower rating for construction equipment type r [hp] 

OTr ― operating time for construction equipment type r [hr/yr] 

EFi, ― emission factor for pollutant i for diesel industrial engines [lb/hp-hr] 

Uconv ― unit conversion [ton/2,000lb] 

Input parameters used in the construction equipment emissions calculations, including the types 

of equipment the applicant could use during the construction period, operating times for this 

equipment, and applicable emission factors, are provided in Tables D2–4 and D2–5. The 

information in Table D2–4 summarizes detailed equipment emissions information an applicant 
Appendix D 

 D–5

(Cash, 2010) voluntarily submitted to the WDEQ to support a survey of small emitters. 

Table D2–5 lists the applicable power-output-based emissions factors for diesel 

industrial engines. 

Table D2–5. Emissions factors (EFi,) for Uncontrolled Diesel Industrial Engines 

(lb/hp-hr) 

Pollutant Value 

Nitrogen oxides (NOx) 0.031 

Carbon monoxide (CO) 0.00668 

Sulfur oxides (SOx) 0.00205 

Particulate matter (PM10) 0.00220 

Carbon dioxide (CO2) 1.15 

Formaldehyde 0.00000826 

Volatile organic compounds 0.00247 

Source: EPA, 1996. 

D2.3 Reclamation Equipment Emissions Calculations 

Emissions during the construction period are expected to bound annual emissions from 

operations and aquifer restoration phases because the use of diesel powered equipment during 

those phases is much less than during construction (NRC, 2004). Construction equipment use 

during decommissioning and reclamation (hereafter reclamation) is expected to be similar to the 

construction phase (NRC, 2004) because many aspects of reclamation, in effect, are the 

reverse of the activities conducted during construction. During construction, well-drilling and 

facility construction activities predominate, while during reclamation, diesel equipment is used 

for other activities, such as well plugging and abandonment, equipment removal, and land 

reclamation. The applicant has planned a two-year period for the reclamation of each wellfield 

(EMC, 2007, Figure 1.8-1). 

Emissions for diesel equipment used for reclamation activities were calculated using the same 

methods as in Section D2.2 for construction equipment (Eq. D–3), although input parameters 

were revised for equipment horsepower and operating times to reflect available information on 

the proposed reclamation activities. The NRC staff identified the most detailed and complete 

Table D2–4. Horsepower (hp) and Operating Times (hr/yr) for Diesel 

Construction Equipment 

Equipment 

Horsepower 

(HPr)

Operating Time 

(OTr)

Lull 944E Telehandler 110 450 

John Deere 710J Backhoe 126 360 

John Deere 410 Backhoe 66 240 

Truck 250 90 

John Deere Loader 200 50 

Scraper 600 50 

Blade 300 38 

Caterpillar D8 Dozer 321 12 

Source: Cash, 2010. 
Appendix D 

 D–6

information on proposed equipment and activities in the surety estimate for the proposed facility 

(EMC, 2007). Based on the types of equipment identified in the surety estimate, specific 

equipment models were selected by reviewing documentation of commonly used reclamation 

equipment provided by WDEQ (2009). 

Equipment horsepower information for specific models was obtained from manufacturer 

documentation. A few items of equipment were only generally described in the surety estimate 

as truck or tow vehicles for well-abandonment activities, and these were assumed to be rated at 

250 horsepower. Operating times for each item of equipment were derived from detailed 

information and assumptions on specific reclamation activities discussed in the surety estimate 

(EMC, 2007), including building demolition floor removal, pipeline removal, well abandonment, 

and reclamation of disturbed surface areas such as wellfields, facilities areas, and access 

roads. Equipment usage for backhoe and trackhoe equipment was explicit in the surety 

information, and operation times are expected to be the most reliable estimates of the 

equipment evaluated in this analysis. Other equipment was not explicitly called out for specific 

activities (e.g., dozer, dump truck, scaper, motor grader), so operating times were estimated 

based, in part, on assumptions about which reclamation activities would utilize the equipment 

(e.g., the motor grader was assumed for road grading and grading cleared foundation areas, the 

dozer was assumed to be involved in ripping packed land surface areas; the dump truck was 

assumed for transporting excavated contaminated soils; and the scraper was assigned the 

same hours as for the construction work discussed in Section D2.2). Information on equipment 

productivity, such as grading or ripping rates and payload amounts, were obtained from the 

aforementioned WDEQ documentation (WDEQ, 2009). The resulting equipment and operation 

times are provided in Table D2–6. The emissions factors used in the calculations are provided 

in Table D2–5. 

D3 RESULTS AND DISCUSSION 

The estimated annual emissions from well drilling and construction equipment are provided in 

Tables D3–1 and Table D3–2. The total estimated annual emissions from both calculations 

combined are provided in Table D3–3. The combined results for drilling and construction 

equipment show CO2 and NOx annual emissions are the highest of the pollutants evaluated. 

For well-drilling equipment, the rigs used for two deep disposal wells generated higher annual 

Table D2–6. Horsepower (hp) and Operating Times (hr) for Diesel 

Reclamation Equipment 

Equipment 

Horsepower 

(HPr)

Operating Time 

(OTr)

Heavy Truck 250 1280 

Caterpillar 430E Backhoe 101 950 

Caterpillar 320DL Track hoe 148 780 

Lull 944E Telehandler 110 450 

New Holland 545D Tractor 63 170 

Dump Truck 250 60 

Caterpillar 657G Scraper 600 50 

Caterpillar D9 Dozer 474 50 

Caterpillar 16H Motor Grader 265 5 

Source: Derived by staff from information in the following references: 

(1) EMC, 2007. (2) Cash, 2010. (3) WDEQ, 2009.
Appendix D 

 D–7

emissions estimates when compared to the emissions from drilling all of the water wells for a 

single wellfield (481 wells). This result is explained by the larger, more fuel-consuming, engine 

used by a deep well rig in comparison to the smaller water well rig and the long drilling time 

Table D3–1. Calculated Annual Emissions From Well Drilling Activities*

 (tons/yr) 

Drilling Activity NOx† CO† SO2† PM10† CO2† Formaldehyde VOC† 

Operational 

wellfield (water 

well) drilling 

4.2 0.9 0.27 0.27 160 0.0011 0.34 

Deep well drilling 13 3.5 0.20 0.41 670 0.00032 0.37 

Total 17 4.4 0.47 0.68 830 0.0014 0.71 

*Includes drilling and construction of the first proposed wellfield, and two deep disposal wells 

†NOx = nitrogen oxides; CO = carbon monoxide; SOx = sulfur oxides; PM10 – particulate matter; CO = carbon 

dioxide; VOC = volatile organic compounds 

Table D3–2. Calculated Annual Emissions From Construction Equipment (tons/yr)* 

 Equipment NOx† CO† SO2† PM10† CO2† Formaldehyde VOC† 

Lull 944E 

Telehandler 0.77 0.17 0.05 0.05 28 0.00020 0.06 

JD 710J 

Backhoe 0.70 0.15 0.05 0.05 26 0.00019 0.06 

JD 410 Backhoe 0.25 0.05 0.02 0.02 9.1 0.000065 0.02 

Truck 0.35 0.08 0.02 0.02 13 0.000093 0.03 

JD Loader 0.16 0.03 0.01 0.01 5.8 0.000041 0.01 

Scraper 0.47 0.10 0.03 0.03 17 0.00012 0.04 

Blade 0.18 0.04 0.01 0.01 6.6 0.000047 0.01 

CAT D8 Dozer 0.06 0.01 0.0039 0.0042 2.2 0.000016 0.0047

Total 2.9 0.63 0.19 0.19 110 0.00077 0.23 

*Includes equipment used to support drilling and wellfield development operations 

†NOx = nitrogen oxides; CO = carbon monoxide; SOx = sulfur oxides; PM10 – particulate matter; CO = carbon 

dioxide; VOC = volatile organic compounds

Table D3–3. Total Calculated Annual Emissions From Drilling and 

Construction (tons/yr)* 

Activities NOx† CO† SO2† PM10† CO2† Formaldehyde VOC† 

Well drilling 

and 

construction 

20 5.0 0.66 0.87 940 0.0022 0.94 

*Includes drilling and construction of the first proposed wellfield, and two deep disposal wells. Results are the sum 

of results from Tables D3–1 and D3–2 

†NOx = nitrogen oxides; CO = carbon monoxide; SOx = sulfur oxides; PM10 – particulate matter; CO = carbon 

dioxide; VOC = volatile organic compounds

per well required for deep drilling. For example, the two deep well-drilling activities combined 

are estimated to emit 76 percent of the annual NOx drilling emissions, compared water welldrilling of 481 wells that represents 24 percent of the annual drilling NOx emission total. The 

magnitude of the calculated construction equipment emissions is small relative to the results for 

drilling activities. The total construction equipment emissions of NOx are 14 percent of the total 

annual NOx from all activities included in the calculations while drilling activities constitute the 

remaining 86 percent of the total emissions. 
Appendix D 

 D–8

The emissions estimates are expected to be conservative because they are based on emissions 

factors applicable to engines that have no pollution controls. Table D3–4 provides a 

comparison of the EPA AP-42 factors (EPA, 1996) that were used for the calculations in this 

appendix with updated emission factor values (EPA, 2004) that are based on more recent data 

Table D3–4. Effect of Using Updated Emissions Factors That Account for 

Pollution Controls 

Pollutant 

1996 Uncontrolled 

Emission Factor for 

Diesel Industrial Engines

2004 Updated Value 

(Tier 1 Controlled 300-

600 HP Diesel Engines) 

Reduction Ratio 

(Updated/ 

Uncontrolled) 

Nitrogen oxides 

(NOx) 0.031 0.0132 0.42 

Carbon monoxide 

(CO) 0.00668 0.00288 0.43 

Particulate matter 

(PM10) 0.00220 0.00044 0.20 

Volatile organic 

compounds 0.00247 0.000446 0.18 

Source: EPA, 2004; EPA, 1996. 

that apply to engines with pollution controls (Tier 1 representing the first phase of standards that 

were mandated by the Federal government in four phases of increasing limits). Table D3–4 

shows that calculated emissions estimates for NOx and CO would be reduced, approximately, 

by a factor of 2 and PM10, and VOC emissions by a factor of 5 if the updated emission factors 

were used. Because the actual equipment that would be used is uncertain, the assumption of 

an applicant using older, uncontrolled engines bounds the emissions should older equipment be 

selected for this work and also provides margin in the estimates if newer equipment is selected. 

The results of emissions calculations for the reclamation activities are provided in Table D3–5. 

Because wellfield reclamation is planned to take two years per wellfield using a phased 

approach, the annual emissions for years that do not overlap with any of the other scheduled

wellfield reclamation activities would be approximately half of the values listed in Table D3–5. 

According to the applicant schedule, in two of the four years allocated for wellfield reclamation, 

two wellfield’s reclamation activities overlap (EMC, 2007, Figure 1.8-1) and, therefore, the 

annual emissions during these years would equal the values listed in Table D3–5. Because 

many of the total values in Table D3–5 are less than the emissions calculated for construction 

(by no more than a factor of 2.5), the magnitude of annual reclamation emissions are less than 

the annual emissions calculated for wellfield construction, by approximately a factor of about 

two to five for several of the pollutants evaluated, depending on the specific year evaluated. 

Cumulative emissions for the proposed action were also approximated using the calculated 

results and the number of wellfields proposed by the applicant. For the purpose of this analysis, 

cumulative emissions are the total lifecycle emissions from all phases of the proposed action. 

Because the principal diesel emissions from the proposed action are associated with equipment 

used for constructing and decommissioning the project, the analysis focuses on the emissions 

from those phases. The initial calculated annual emissions in Table D-3 apply to constructing a 

single wellfield with two deep disposal wells. Assuming these emissions are representative of 

the construction of the other wellfields to be developed, these results scale with the total number 

of wellfields and deep wells that are proposed. Because the applicant’s initial proposal includes 

phased construction of three wellfields (EMC, 2007, Figure 1.8-1) and each of these wellfields 
Appendix D 

 D–9

would require reclamation once operations and aquifer restoration are completed, the 

cumulative emissions were conservatively approximated by calculating a wellfield weighted-sum 

of emissions for the planned life of the facility. This was done by computing a weighted sum of 

the (pollutant-specific) total construction phase water well drilling emissions from Table D3–1, 

the total construction equipment emissions from Table D3–2, and the total reclamation 

emissions contributions from Table D3-5 where each contribution to this sum is weighted by a 

factor of 3 (the total number of planned wellfields for this proposed action). Because the total 

deep-well drilling emissions from Table D3-1 are independent of the water wellfields, the results 

for these emissions (for two deep wells) are doubled and added to the weighted sum result to 

complete the cumulative emissions totals that are provided in 

Table D3–5. Calculated Diesel Equipment Emissions (tons) From Reclamation of One 

Wellfield*

 and the Central Processing Facilities* 

 Equipment NOx† CO† SO2† PM10† CO2† Formaldehyde VOC† 

Heavy Truck 4.97 1.07 0.33 0.35 180 0.0013 0.40 

Caterpillar 430E 

Backhoe 1.49 0.32 0.098 0.10 55 0.00040 0.12 

Caterpillar 

320DL Track 

hoe 

1.79 0.39 0.12 0.13 66 0.00048 0.14 

Lull 944E 

Telehandler 0.77 0.16 0.05 0.054 28 0.00020 0.061 

New Holland 

545D Tractor 0.17 0.036 0.011 0.012 6.2 0.000044 0.013 

Dump Truck 0.24 0.052 0.016 0.017 9.0 0.000065 0.020 

Caterpillar 

657G Scraper 0.47 0.10 0.031 0.033 17 0.00012 0.037 

Caterpillar D9 

Dozer 0.37 0.079 0.024 0.026 14 0.000098 0.029 

Caterpillar 16H 

Motor Grader 0.021 0.0044 0.0014 0.0015 0.76 0.0000055 0.0016 

Total 10 2.2 0.68 0.72 380 0.0027 0.82 

*The applicant plans reclamation of a single wellfield over a 2-year period, so annual emissions would be 

approximately half the values listed in this table when only a single wellfield is planned to be reclaimed in 1 year. 

†NOx = nitrogen oxides; CO = carbon monoxide; SOx = sulfur oxides; PM10 – particulate matter; CO = carbon 

dioxide; VOC = volatile organic compounds 

Table D3–6. Estimated Cumulative Emissions of the Proposed Action* (tons) 

Activities NOx† CO† SO2† PM10† CO2† Formaldehyde VOC† 

Well drilling and 

construction of three 

wellfields and up to 

four deep wells and 

reclamation of all 

wellfields and facilities 

78 18 3.8 4.4 3300 0.014 4.9 

*The planned duration of the proposed action represents a phased construction, operation, aquifer restoration, and 

reclamation schedule for each wellfield and central plant over a period of 12 years. 

†NOx = nitrogen oxides; CO = carbon monoxide; SOx = sulfur oxides; PM10 – particulate matter; CO = carbon 

dioxide; VOC = volatile organic compounds 
Appendix D 

 D–10

Table D3–6. The cumulative results are conservative, in part, because the (factor of 3) 

multiplier overcounts the contribution from the plant facilities decommissioning that is included in 

each wellfield reclamation emissions estimate. 

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Eastern Research Group, 1996. “Report on Revisions to 5th Edition AP-42, Section 3.3 

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EMC (Energy Metals Corporation), 2007. “Application for USNRC Source Material License 

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WDEQ (Wyoming Department of Environmental Quality), 2010. “Emissions Inventory Forms: 

2009 Annual and 2010 Winter Upper Green River Basin Emissions Inventory, Winter Drill Rig 
Appendix D 

 D–11

Emission Inventory.” Cheyenne, Wyoming: WDEQ, Air Quality Division. 

<http://deq.state.wy.us/adq/ei.asp> (10 May 2010). 

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