Environmental Impact 

Statement for the Proposed 

Fluorine Extraction Process 

and Depleted Uranium 

Deconversion Plant in Lea 

County, New Mexico

Final Report

Office of Federal and State Materials and 

Environmental Management Programs

NUREG-2113
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Environmental Impact 

Statement for the Proposed 

Fluorine Extraction Process 

and Depleted Uranium 

Deconversion Plant in Lea 

County, New Mexico

Final Report

Manuscript Completed: July 2012

Date Published: August 2012

Asimios Malliakos, NRC Project Manager

Office of Federal and State Materials and

 Environmental Management Programs

NUREG-2113
 

 
iii 

ABSTRACT 

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

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

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

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

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

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

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

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

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

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

1954. 

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

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

(10 CFR 51). This EIS evaluates the potential environmental impacts of the proposed action, 

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

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

monitoring program and proposed mitigation measures. 

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 collection 

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

3150-0014; 3150-0020; 3150-0021; 3150-0135; 3150-0009; 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. 

NUREG-2113 has been reproduced from the best available copy

 v 

TABLE OF CONTENTS 

Section Page

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

1.5.2 Lea County and Local Laws and Regulations .......................................... 1-12 

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

1.5.3.1 Permits, Licenses, Authorizations, Approvals, and 

Consultations Required for Preconstruction and Construction . 1-12 

1.5.3.2 Permits, Authorizations, Approvals and Consultations 

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

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

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

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

1.7.1 National Historic Preservation Act of 1966 Section 106 Consultation ...... 1-19 

1.7.2 Endangered Species Act of 1973 Section 7 Consultation ........................ 1-19 

1.8 References .............................................................................................................. 1-20 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

TABLE OF CONTENTS (CONTINUED) 

Section Page

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

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

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

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

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

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

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

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

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

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

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

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

2.2.2.2 Alternative Technologies .......................................................... 2-34 

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

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

2.2.2.5 Commercial Enrichment Plant Deconversion of DUF6 at 

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

2.3 Comparison of Predicted Environmental Impacts ................................................... 2-37 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

3.5.2.3 Projected Impacts from Construction and Operation of the 

Proposed IIFP Facility on Carbon Dioxide and Other 

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

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

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

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

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

 
 vii 

TABLE OF CONTENTS (CONTINUED) 

Section Page

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

3.8.6 Wildlife Sanctuaries, Wildlife Management Areas, Refuges, 

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

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

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

3.8.6.3 Lesser Prairie-Chicken Habitat Preservation Area of Critical 

Environmental Concern and Proposed Lesser 

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

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

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

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

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

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

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

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

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

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

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

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

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

3.9.2.2 Income ...................................................................................... 3-73 

 
 viii 

TABLE OF CONTENTS (CONTINUED) 

Section Page

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

4.1.1.12 Waste Management ................................................................. 4-22 

 
 ix 

TABLE OF CONTENTS (CONTINUED) 

Section Page

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 
 x 

TABLE OF CONTENTS (CONTINUED) 

Section Page

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

7.5 References .............................................................................................................. 7-10 

 
 xi 

TABLE OF CONTENTS (CONTINUED) 

Section Page

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

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

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

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

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

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

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

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

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

9.3 Center for Nuclear Waste Regulatory Analysis Contributors .................................. 9-5 

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

APPENDICES 

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

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

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

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

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

 APPENDIX F PUBLIC PARTICIPATION AND NRC RESPONSE TO 

 COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT 

 STATEMENT ................................................................................ F-1 
 xii 

LIST OF TABLES 

Table Page

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

3-20 Population Estimates of ROI Counties and Incorporated 

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

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

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

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

Significant Minority or Low-Income Populations (Meeting 50 Percent 

Criteria or Exceeding Respective County or State Percentages by 

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

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

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

LIST OF TABLES (CONTINUED) 

Table Page

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

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

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

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

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

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

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

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

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

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

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

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

4-2 Emissions from Workforce Commuting and Delivery Activities During 

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

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

4-4 Estimated Maximum Annual Emissions from Construction of the 

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

4-5 Comparison of Maximum Annual Emissions from Construction of 

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

4-6 Comparison of Predicted Maximum Downwind Concentrations Due 

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

4-7 Assumptions for Workforce Characterization during Peak 

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

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

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

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

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

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

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

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

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

4-14 Estimated Maximum Annual Criteria Pollutant Emissions from 

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

4-15 Estimated Maximum Annual Criteria Pollutant Emissions from 

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

4-16 Comparison of Maximum Annual Emissions from Phase 1 

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

4-17 Predicted Property Boundary Concentrations Due to Phase 1 

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

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

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

4-19 Assumptions for Workforce Characterization During Phase 1 

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

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

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

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

LIST OF TABLES (CONTINUED) 

Table Page

4-22 Annual Collective Doses to Various Receptors from Radiological 

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

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

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

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

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

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

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

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

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

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

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

4-29 Annual Nonfatal and Fatal Occupational Injuries Projected for 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

6-6 Required Minimum Detectable Concentrations for Environmental 

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

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

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

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

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

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

LIST OF TABLES (CONTINUED) 

Table Page

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

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

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

LIST OF FIGURES 

Figure Page

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

EXECUTIVE SUMMARY 

Background 

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

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

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

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

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

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

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

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

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

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

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

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

National Environmental Policy Act require the preparation of an Environmental Impact 

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

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

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

decommissioning of the proposed IIFP facility. 

The Proposed Action 

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

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

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

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

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

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

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

roadways and other infrastructure improvements. 

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

2013. The proposed facility is designed to be capable of deconverting up to 3.4 million 

kilograms (kg) (7.5 million pounds, or 3,750 tons) per year of DUF6. The annual capacity of 

approximately 3.4 million kg (3,750 tons) per year equates to about 9,300 kg/day (10.3 

tons/day) on average. Following operations the facility is expected to be decommissioned 

following termination of the license. 

Preconstruction Activities 

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

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

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

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

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

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

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

Purpose and Need for the Proposed Action 

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

The proposed action is intended to satisfy the need for a facility that would deconvert DUF6 into 

DUO2 for disposal. An added goal of IIFP would be to produce fluoride products for commercial 

resale. Without a facility such as the proposed IIFP facility, DUF6 would continue to be stored, 

typically in 12.7-metric ton (14-ton) cylinders, at commercial uranium enrichment facilities in the 

United States. Although DUF6 could be transferred to the U.S. Department of Energy (DOE) for 

a fee, DOE’s existing inventory of DUF6 is not projected to be deconverted for approximately 

25 years. Further, long-term storage of DUF6 represents a potential chemical hazard if the 

material is not properly managed, and deconversion to DUO2 is preferable. The fluoride 

products are potentially valuable for applications in the electronic, solar panel, and semiconductor markets, among others. In addition, anhydrous hydrogen fluoride (AHF) is a 

by-product of the deconversion process and is an important chemical in various industrial 

applications. 

Alternatives 

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

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

would not grant a license to IIFP to construct, operate, and decommission the proposed facility 

near Hobbs, New Mexico, to receive and process source material, and to ship products and lowlevel radioactive waste (LLW). However, impacts from preconstruction activities could occur 

under the no-action alternative. The proposed site would remain in its current or 

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

negatively, except by preconstruction. LLW would not be shipped to licensed disposal facilities 

for disposal. Fluoride products would not be manufactured and sold to end users. Planned or 

existing commercial enrichment facilities would not be able to send their DUF6 to the IIFP facility 

for deconversion. 

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

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

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

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

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

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

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

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

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

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

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

chemical in various industrial applications. 

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

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

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

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

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

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

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

Determining the Significance of 

Potential Environmental Impacts 

NRC has established a standard of 

significance for assessing environmental 

impacts. Each impact is assigned one of 

the following three significance levels: 

• SMALL: The environmental effects are 

not detectable or are so minor that they 

would neither destabilize nor noticeably 

alter any important attribute of the 

resource. 

• MODERATE: The environmental 

effects are sufficient to noticeably alter 

but not destabilize important attributes of 

the resource. 

• LARGE: The environmental effects 

are clearly noticeable and are sufficient 

to destabilize important attributes of the 

 resource. 

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

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

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

by-products. 

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

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

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

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

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

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

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

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

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

should be eliminated from consideration in this EIS. 

Potential Environmental Impacts of the Proposed Action 

In this EIS, NRC staff evaluates the existing 

conditions (Chapter 3) and potential environmental 

impacts of the proposed action (Chapter 4). A 

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

established for assessing environmental impacts. 

The NRC staff has assigned each impact one of 

the three significance levels described in the 

textbox. The environmental impacts from the 

proposed action are SMALL or MODERATE and 

could be mitigated by the methods described in 

Chapter 5. Environmental monitoring methods are 

described in Chapter 6. 

Summarized below are the potential environmental 

impacts of the proposed action on each of the 

resource areas considered in this EIS. Each 

summary is preceded by the impact significance 

level for the respective resource areas. 

Land Use 

SMALL. Construction activities would occur on 

about 16 ha (40 ac) within the 259-ha (640-ac) site. Construction of the proposed facility would 

alter the current land use of the entire IIFP site, a tract known as Section 27 of Township 18 

South, Range 36 East, which is primarily used for cattle grazing. The transfer and conversion of 

the land for the facility would not conflict with any existing Federal, State, local, or Tribal Nation 

land use plans, or restrict current or planned mineral resource exploitation. The operation of the 

proposed facility would be consistent with the existing land use of the neighboring tracts, which 

support industrial facilities, natural gas and oil extraction and transmission infrastructure, and 

agriculture and open land. 
 xx 

Historical and Cultural Resources 

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

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

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

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

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

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

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

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

Visual and Scenic Resources 

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

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

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

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

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

resource inventory process. 

Climatology, Meteorology, and Air Quality 

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

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

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

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

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

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

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

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

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

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

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

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

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

Geology, Minerals, and Soils 

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

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

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

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

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

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

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

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

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

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

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

Water Resources 

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

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

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

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

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

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

groundwater use for potable water and process water needs is estimated to be less than 

38,000 liters (10,000 gallons [gal]) per day peak, averaging an estimated 13,000 liters 

(3,000 gal) per day. The proposed facility would use approximately 0.5 percent of the estimated 

additional annual 40-year planning period groundwater demand for Lea County and only 

0.15 percent of the unappropriated water rights that have been assigned to Lea County. 

Ecological Resources 

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

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

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

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

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

would be considered to lessen impacts. 

Socioeconomics 

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

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

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

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

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

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

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

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

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

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

and construction. 

Environmental Justice 

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

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

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

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

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

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

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

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

including minority or low-income populations. 
 xxii 

Noise 

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

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

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

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

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

Traffic and Transportation 

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

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

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

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

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

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

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

construction workforce is unlikely. 

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

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

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

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

year) for the operations traffic is unlikely. 

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

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

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

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

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

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

Public and Occupational Health and Safety 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Waste Management 

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

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

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

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

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

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

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

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

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

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

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

proposed facility. 

Summary of the Costs and Benefits of the Proposed Action 

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

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

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

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

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

College during the construction period. 

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

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

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

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

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

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

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

Comparison of Alternatives 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

ACRONYMS AND ABBREVIATIONS 

0 C degrees Celsius 

0 F degrees Fahrenheit 

AADT annual average daily traffic 

ac acre(s) 

ACEC area of critical environmental concern 

ACHP Advisory Council on Historic Preservation 

AEGL acute exposure guideline levels 

AHF anhydrous hydrogen fluoride 

ALARA as low as reasonably achievable 

APE area of potential effect 

API American Petroleum Institute 

AQCR Air Quality Control Region 

B2O3 boron oxide 

BEA Bureau of Economic Analysis 

BF3 boron trifluoride 

bgs below ground surface 

BLM Bureau of Land Management 

BMP best management practice 

Bq/L becquerel per liter 

CaCO3 calcium carbonate 

CaF2 calcium fluoride 

Ca(OH2) calcium hydroxide 

CCS Center for Climatic Strategies 

CEDE committed effective dose equivalent 

CEQ Council on Environmental Quality 

CERCLA Comprehensive Environmental Response Compensation and 

Liability Act 

CFR Code of Federal Regulations 

CH4 methane 

Ci curie 

cm centimeter 

CMA critical management areas 
xxvi 

ACRONYMS AND ABBREVIATIONS 

(continued) 

CO carbon monoxide 

CO2 carbon dioxide 

CWA Clean Water Act 

dB decibel (sound pressure level) 

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

DNFSB Defense Nuclear Facilities Safety Board 

DOE U.S. Department of Energy 

DOT U.S. Department of Transportation 

DU depleted uranium 

DUF4 depleted uranium tetrafluoride 

DUF6 depleted uranium hexafluoride 

DUO2 depleted uranium dioxide 

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

DUO2F2 depleted uranyl dioxyfluoride 

DWB Drinking Water Bureau 

EDE effective dose equivalent 

EPP environmental protection process 

EIS environmental impact statement 

EPA U.S. Environmental Protection Agency 

Eq equivalents 

ER environmental report 

ERPG Emergency Response Planning Guideline 

ESA Endangered Species Act 

FD&C Federal Food, Drug and Cosmetic Act 

FEMA Federal Emergency Management Agency 

FEP/DUP Fluorine Extraction Process/Depleted Uranium Deconversion Plant 

ft foot or feet 

FR Federal Register 

g gravity 

gal gallon(s) 

GHG greenhouse gases 

gpd gallons per day 
xxvii 

ACRONYMS AND ABBREVIATIONS 

(continued) 

gpm gallons per minute 

GPS global positioning system 

GWP global warming potential 

H2 hydrogen 

ha hectare(s) 

HAP hazardous air pollutant 

HF hydrofluoric acid or hydrogen fluoride 

HFC hydrofluorcarbon 

HPD [New Mexico] Historic Preservation Division 

HS&E health, safety and environmental 

HUD U.S. Department of Housing and Urban Development 

IIFP International Isotopes Fluorine Products, Inc 

in inch 

IPCC Intergovernmental Panel on Climate Change 

IRB industrial revenue bond 

ISA integrated safety analysis 

kBq kilobecquerel 

KF potassium fluoride 

kg kilogram 

KOH potassium hydroxide 

km kilometer(s) 

km/hr kilometers per hour 

km2

 square kilometer 

kV kilovolt 

L liter 

lb pound 

LCF latent cancer fatality 

LLD lower limit of detection 

LES Louisiana Energy Services 

LLRW low-level radioactive waste 

LLW low-level (radioactive) waste 

L/min liters per minute 
xxviii 

ACRONYMS AND ABBREVIATIONS 

(continued) 

m meter(s) 

MCL maximum contaminant levels 

MDC minimum detection concentrations 

MEI maximally exposed individual 

mg milligram 

MGD million gallons per day 

mg/kg micrograms per kilogram 

mg/L milligrams per liter 

mg/m3 milligrams per cubic meter 

mi mile(s) 

mi2

 square mile 

MM modified Mercalli 

mpg miles per gallon 

mph miles per hour 

mrem millirem 

mSv millisievert 

MW megawatt 

N2O nitrous oxides 

NAAQS National Ambient Air Quality Standards 

NAGPRA Native American Graves Protection and Repatriation Act 

NCRP National Council on Radiation Protection 

NEPA National Environmental Policy Act 

NESHAP National Emissions Standards for Hazardous Air Pollutants 

NHPA National Historic Preservation Act 

NH3 ammonia 

NM New Mexico 

NMAAQS New Mexico Ambient Air Quality Standards 

NMAC New Mexico Administrative Code 

NMDOT New Mexico Department of Transportation 

NMED New Mexico Environment Department 

NMEDAQB New Mexico Environmental Department Air Quality Bureau 

NMEDHWB New Mexico Environmental Department Hazardous Waste Bureau 
xxix 

ACRONYMS AND ABBREVIATIONS 

(continued) 

NMEDRCB New Mexico Environmental Department Radiation Control Board 

NMEDWQB New Mexico Environmental Department Water Quality Bureau 

NMGF New Mexico Department of Game and Fish 

NMOSE New Mexico Office of the State Engineer 

NMRL/CID New Mexico Regulations and Licensing/Construction Industries 

Division 

NMRPR New Mexico Radiation Protection Regulations 

NMRPTC New Mexico Rare Plant Technical Council 

NMSA New Mexico Statutes Annotated 

NM SHPO New Mexico State Historic Preservation Office 

NMSLO New Mexico State Land Office 

NMSS Nuclear Materials Safety and Safeguards 

NMVOC non-methane volatile organic compound 

NO2 nitrogen dioxide 

NOx oxides of nitrogen 

NRC U.S. Nuclear Regulatory Commission 

NRHP National Register of Historic Places 

O&M operating and maintenance 

OSHA Occupational Safety and Health Administration 

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

PFC perfluorocarbon 

PGA peak [horizontal] ground acceleration 

PILT payment in lieu of taxes 

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

PM10 particulate matter with a diameter less than 10 microns 

PPE personal protective equipment 

ppm parts per million 

PSD prevention of significant deterioration 

psig pounds per square inch gauge 

PSTB Petroleum Storage Tank Bureau 

QA quality assurance 

RAI Requests for Additional Information 
xxx 

ACRONYMS AND ABBREVIATIONS 

(continued) 

RCRA Resource Conservation and Recovery Act 

REMP Radiological Environmental Monitoring Program 

ROD record of decision 

ROI region of influence 

RMP resource management plan 

RMPA resource management plan amendment 

SARA Superfund Amendment and Reauthorization Act 

SF6 sulfur hexafluoride 

SiF4 silicon tetrafluoride 

SiO2 silicon dioxide 

SPCC Spill Prevention Control and Countermeasures 

SO2 sulfur dioxide 

SRP site redress plan 

s.u. standard units 

SVOC semivolatile organic compound 

SWPP Stormwater Pollution Prevention Plan 

SWU separative work unit 

TDS total dissolved solids 

TEDE total effective dose equivalent 

Tg teragram [1 x 1012 gram] 

TLD thermo luminescent dosimeters 

TSD treatment, storage, disposal 

TSP total suspended particulate 

U-234 a uranium isotope 

U-235 a uranium isotope 

U-236 a uranium isotope 

U3O8 variously known as uranium oxide, triuranium octoxide, or 

“yellowcake” 

UF4 uranium tetrafluoride 

UF6 uranium hexafluoride 

μCi/g microcuries per gram 

μg/L micrograms per liter 
xxxi 

ACRONYMS AND ABBREVIATIONS 

(continued) 

μg/m3 microgram per cubic meter 

UNFCCC United Nations Framework Convention on Climate Change 

UO2 uranium oxide or uranium dioxide 

UO2F2 uranyl oxyfluoride 

USACE U. S. Army Corps of Engineers 

USCB U.S. Census Bureau 

USEC U.S. Enrichment Corporation 

USFWS U.S. Fish and Wildlife Service 

USGS U.S. Geological Survey 

UWB underground water basin 

VA volt-ampere 

VOC volatile organic compound 

WCS Waste Control Specialists 

WIPP Waste Isolation Pilot Plant 

 1-1 

1.0 INTRODUCTION 

1.1 Background 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

October, 2010 and the Paducah, Kentucky facility began operating in December, 2010. With 

both fully operational, these plants will deconvert more than 700,000 metric tons (771,000 tons) 

of DUF6 currently stored by DOE. This inventory is projected to require 25 years to deconvert, 

once the facilities become operational. DOE plans to dispose of the 551,000 metric tons 

(607,200 tons) of deconverted DU as LLW (DOE, 2004). 

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

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

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

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

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

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

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

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

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

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

applications (IIFP, 2009a). 

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

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

the construction, operation, and decommissioning of a commercial facility for deconversion of 

DUF6 in Lea County, New Mexico. 

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

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

Domestic Licensing and Related Regulatory Functions.” The NRC’s regulations under 10 CFR 

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

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

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

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

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

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

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

to evaluate the potential environmental impacts of 

the proposed IIFP facility and reasonable 

alternatives to the proposed action. 

1.2 Proposed Action 

The proposed action is for the NRC to grant IIFP a 

license (under 10 CFR 40, “Domestic Licensing of 

Source Material”) to construct, operate, and 

decommission a facility to deconvert commercially 

generated DUF6 to depleted uranium dioxide 

(DUO2) and other deconversion products. IIFP 

would own the facility and be responsible for its 

operation and performance. If the NRC issues a 

license to IIFP under the provisions of the Atomic 

Energy Act of 1954, as amended, the license would 

authorize IIFP to possess and use special nuclear 

material, source material, and byproduct material at 

the proposed IIFP facility for a period of 40 years in 

accordance with the NRC’s regulations in 

10 CFR 40. The scope of activities to be conducted 

under the license would include the construction, 

operation, and decommissioning of the proposed 

IIFP facility. 

If issued a license by NRC, IIFP has proposed that 

the IIFP facility, comprising 16 hectares (ha) 

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

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

Mexico. This parcel of land which was previously 

publicly-owned and comprises open range land 

Potential Beneficial Uses of DU 

• Further enrichment – DU can be used 

as feedstock for uranium enrichment. 

The low cost of uranium ore and 

postponed deployment of advanced 

enrichment technology have indefinitely 

delayed this application. 

• Nuclear reactor fuel – DU can be mixed 

with plutonium oxide from 

decommissioned nuclear weapons to 

make mixed oxide fuel (typically about 

6 percent plutonium oxide and 

94 percent depleted uranium oxide) for 

commercial power reactors. 

• Down-blending highly-enriched uranium 

– Nuclear disarmament treaties allow 

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

to make commercial reactor fuel. 

• Munitions – DU metal can be used for 

tank armor and armor-piercing 

projectiles. 

• Biological shielding – DU metal has a 

high density, which makes it suitable for 

shielding from x-rays or gamma rays for 

radiation protection. 

• Counterweights – Because of its high 

density, DU has been used to make 

small but heavy counterweights. 

Source: NRC, 2005 
 1-3 

used for grazing as well as overhead transmission lines and underground petroleum pipelines, 

has been conveyed from the State of New Mexico to Lea County and, ultimately, to IIFP for 

construction and operation of the proposed facility. 

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

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

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

deconversion capability. 

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

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

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

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

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

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

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

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

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

1.3 Purpose and Need for the Proposed Action 

The proposed action under consideration by the 

NRC is a license application to construct, operate, 

and decommission a facility to deconvert DUF6 into 

depleted uranium oxides for disposal. Additionally 

the process will recover fluoride products for 

commercial sale. With the existing inventory of 

stockpiled depleted uranium and four new 

commercial enrichment plants in the United States 

expected to be operating within the next few years, 

there is a need to deconvert the quantity of DUF6

that exists and would be produced at these 

enrichment facilities. Without a deconversion facility, 

DUF6 would continue to be stored, primarily at 

commercial uranium enrichment facilities in the 

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

cylinders. Although DUF6 could be transferred to 

DOE for deconversion for a fee, DOE’s existing 

inventory of DUF6 is not projected to be deconverted 

for 25 years. The proposed IIFP facility should be 

capable of deconverting up to 3.4 million kilograms 

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

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

one-tenth of the DUF6 that is projected to be 

produced annually in the United States by 

commercial enrichment facilities. The annual 

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

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

average. 

The NRC Environmental and Safety 

Reviews 

The focus of an EIS is a presentation of 

the potential environmental impacts of the 

proposed action and reasonable 

alternatives. In addition to meeting its 

responsibilities under NEPA, the NRC 

prepares a Safety Evaluation Report 

(SER) to analyze the safety of the 

proposed action and assess its 

compliance with applicable NRC 

regulations. 

The safety and environmental reviews are 

conducted in parallel. Although there is 

some overlap between the content of an 

SER and that of an EIS, the intent of the 

documents is different. To aid in the 

decision process, the EIS provides a 

summary of the more detailed analyses 

included in the SER. For example, the 

EIS does not address how accidents are 

prevented; rather, it addresses the 

environmental impacts that could result 

should an accident occur. Much of the 

information describing the affected 

environment in the EIS also is applicable 

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

and meteorology). 

Source: NRC, 2005 
 1-4 

IIFP is proposing to perform the following activities: 

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

• Receive full and return empty DUF6 cylinders from various commercial enrichment 

facilities. 

• Transport marketable deconversion byproducts to end users. 

• Transport depleted UO2 for LLW disposal or other potential disposition. 

IIFP is planning, but has not formally submitted an application for, an expansion of the facility. 

Expansion and operation of the expanded facility (Phase 2) would be a reasonably foreseeable 

action and is evaluated as a cumulative impact in this EIS. 

Activities that do not constitute construction under 10 CFR 40 and 51 are those that do not have 

a reasonable nexus to radiological health and safety or the common defense and security, and 

could include clearing of the facility area, grading, installation of drainage and erosion control 

and other environmental mitigation measures, and construction of access roads. These 

“preconstruction” activities are evaluated in this EIS as cumulative impacts because they are 

expected to occur independently of the proposed licensing action by NRC. 

1.4 Scope of this Environmental Analysis 

On December 30, 2009, IIFP submitted an application to the NRC (IIFP, 2009b), seeking a 

license to construct, operate, and decommission a facility for deconversion of DUF6. As part of 

that license application, IIFP submitted an Environmental Report (ER) (IIFP, 2009a) for the 

proposed facility. 

On February 24, 2010, the NRC accepted the IIFP 

application for formal review (NRC, 2010b). A safety 

review team and an environmental review team are 

conducting both safety and environmental reviews of 

the license application. To fulfill its responsibilities 

under NEPA, the NRC staff has prepared this EIS to 

analyze the potential environmental impacts of the 

proposed IIFP facility, and of reasonable alternatives 

to the proposed action. The scope of this EIS 

includes consideration of both radiological and 

nonradiological (including chemical) impacts 

associated with the proposed action and the 

reasonable alternatives. The EIS also addresses the 

potential environmental impacts of transportation. It 

addresses cumulative impacts to physical, biological, 

and socioeconomic resources. In addition, it identifies monitoring and mitigation activities. This 

EIS is the result of the NRC staff’s review of the IIFP facility license application, the ER, 

information obtained from the NRC staff’s independent research, and IIFP’s responses to 

Requests for Additional Information (RAIs). This review has been closely coordinated with the 

NRC staff’s development of the Safety Evaluation Report (SER). 

 

Scoping 

Scoping is an early and open part of the 

NEPA process designed to help determine 

the range of actions, alternatives, and 

potential impacts to be considered in the 

EIS, and to identify significant issues 

related to the proposed action. In addition 

to the public scoping process, the NRC 

solicits input from State, local, and other 

Federal agencies, and potentially affected 

Native American Tribes in order to focus 

on issues of genuine concern. 
 1-5 

1.4.1 Scoping Process and Public Participation Activities 

The NRC regulations in 10 CFR 51 contain requirements for defining the scope of an EIS and 

identifying issues that should be addressed in depth. The scoping process was used to solicit 

public and agency input to identify those issues to be discussed in the EIS in detail, and to 

identify those issues that are either beyond the scope of this EIS or are not directly relevant to 

the assessment of potential impacts from the proposed action. 

As part of the NRC staff’s environmental review and in compliance with 10 CFR 51.26 and 

10 CFR 51.27, the scoping process was initiated on July 15, 2010, with the publication in the 

Federal Register (FR) of a Notice of Intent (NOI) to prepare an EIS (NRC, 2010a). The NOI 

summarized the NRC’s plans to prepare an EIS and presented background information on the 

proposed IIFP facility. The NOI also invited comments on the appropriate scope of issues to be 

considered and announced NRC’s plan to hold a public scoping meeting. The public scoping 

comment period ended on August 30, 2010. 

On July 29, 2010, the NRC staff held a public scoping meeting in Hobbs, New Mexico, to 

receive oral and written comments from interested parties. The public scoping meeting began 

with the NRC staff providing a description of the NRC’s roles, responsibilities, and mission. A 

brief overview of the licensing process was followed by a description of the environmental 

review process and a discussion of how the public can effectively participate. Most of the 

meeting was reserved for attendees to ask questions and make comments on the scope of the 

environmental review. Prior to the public scoping meeting, the NRC staff hosted an informal 

“open house” for those who wished to attend. The open house provided members of the public 

with an opportunity to speak informally with individual NRC staffers. 

Scoping meeting attendees submitted oral and written comments. Additional comments were 

received during the scoping period via electronic and postal mail. As a result of the scoping 

process, the following public comments were received: 

• Expressions of general support for the IIFP facility. 

• Opposition to locating the IIFP facility, or any facility that deals with nuclear byproducts, 

over an aquifer and in an area with a history of earthquakes. 

• Expressions of support for the project, specifically for the jobs that would be created by 

construction and operation of the facility and the positive economic impact it would have 

on the region. 

• Support for the project as a way to use depleted uranium that will be generated at the 

nearby URENCO USA uranium enrichment plant, which would otherwise have to be 

stored or disposed of as DUF6 waste. 

• Concern that a disposal path for waste from the IIFP facility to the Andrews County, 

Texas, nuclear waste disposal facility is an unsafe disposal path. 

• A statement that the EIS should include the aquifer map that has been prepared by 

Mesa Water Company. 

• A statement that the EIS should address the seismic hazards that have been indicated 

for Lea County by the U.S. Geological Survey. 
 1-6 

Appendix A (Scoping Summary) of this EIS includes the scoping summary report that 

summarizes the comments received during the scoping process as required in 

10 CFR 51.29(b). 

The NRC staff has requested information regarding the scope of its environmental review from 

the New Mexico State Historic Preservation Officer (NM SHPO) and Native American Tribes 

identified by the NM SHPO. The NRC staff has also asked for comment from the U.S. Fish and 

Wildlife Service (USFWS) and the New Mexico Department of Game and Fish (NMGF) 

regarding threatened and endangered species. The NRC staff also sought information from the 

New Mexico Energy, Minerals, and Natural Resources Department. The NRC staff has not 

identified any cooperating agencies for the preparation of this EIS. 

Information received from these agencies and potentially affected Native American Tribes was 

important in assessing impacts to cultural and ecological resources and determining if there 

were environmental justice concerns. Correspondence with the NM SHPO and potentially 

affected Native American Tribes (Apache Tribe of Oklahoma, Comanche Tribe of Oklahoma, 

Kiowa Tribe of Oklahoma, Mescalero Apache Tribe, Ysleta del Sur Pueblo, and Shawnee Tribe) 

is included in Appendix B (Consultation/Correspondence) of this EIS. Correspondence with the 

USFWS and the NMGF is also included in Appendix B of this EIS. 

1.4.2 Issues Studied in Detail 

In the (July 15, 2010) NOI, the NRC staff tentatively identified issues to be studied in detail as 

they relate to implementation of the proposed action. These issues were: 

• Land Use: plans, policies, and controls. 

• Historic and Cultural Resources: archaeological sites (historic and prehistoric 

archaeological artifacts/features and information), architectural historic resources 

(structures and districts), and historic properties of traditional religious significance to the 

Native American Tribes. 

• Visual Resources: the visual setting on and near the proposed site. 

• Transportation: transportation modes, routes, quantities, and risk estimates. 

• Geology and Soils: physical geography, topography, geology, and soil characteristics. 

• Water Resources: surface water and groundwater hydrology, water use and quality, and 

the potential for degradation. 

• Ecology: wetlands; aquatic, and terrestrial economically or recreationally important 

species; and threatened and endangered species. 

• Air Quality: meteorological conditions, ambient air quality, pollutant sources, and the 

potential for degradation. 

• Socioeconomics: demography, economic base, labor pool, housing, transportation, 

utilities, public services and facilities, and education. 

• Environmental Justice: potential disproportionately high and adverse impacts to minority 

or low-income populations. 

• Noise: noise receptors and potential noise impacts in the vicinity of the proposed facility. 
 1-7 

• Public and Occupational Health: potential public and occupational consequences from 

construction, routine operation, transportation, and credible accident scenarios (including 

natural events). 

• Waste Management: types of wastes expected to be generated, handled, and stored. 

• Cumulative Effects: impacts from past, present and reasonably foreseeable future 

actions at and near the site. 

After completion of the scoping process, the NRC staff determined that these issues are still 

appropriate for detailed study in the EIS, for the following reasons: (1) the fact that the 

resources identified for study are present and have the potential to be impacted by the action 

and (2) the fact that participants in the scoping process raised many of the same issues, 

including perceived beneficial impacts, that were identified in the NOI. Therefore, the initial 

issues identified in the July 5, 2010, NOI for consideration were carried forward for further 

analysis. In addition, the NRC staff identified no new issues that require detailed study in the 

EIS. 

1.4.3 Issues Beyond the Scope of the EIS 

The purpose of an EIS is to assess the potential environmental impacts of a proposed federal 

action in order to assist in an agency’s decision-making process. In this case, the NRC’s 

decision is whether to grant the license. Some issues and concerns raised during the scoping 

process are not relevant to the EIS because they are not directly related to the environmental 

impact analysis or to the NRC’s decision. The lack of an in-depth discussion in the EIS, 

however, does not mean that an issue or concern lacks value. Issues beyond the scope of the 

EIS either may not yet be at the point where they can be resolved, or are more appropriately 

discussed and decided in other venues. Appendix A includes a discussion of issues identified 

during scoping that are beyond the scope of the EIS. 

Some of the issues raised during the public scoping process for the proposed facility are outside 

the scope of the EIS, but are analyzed in the SER. For example, health and safety issues are 

considered in detail in the SER prepared by the NRC staff for the proposed action and are 

summarized in the EIS. The EIS and the SER may cover some of the same topics and may 

contain similar information, but the analysis in the EIS is focused on the assessment of potential 

environmental impacts. In contrast, the SER deals primarily with safety evaluations and 

procedural requirements or license conditions to ensure the health and safety of workers and 

the general public. 

1.5 Applicable Statutory and Regulatory Requirements 

This section summarizes compliance with legal/regulatory requirements, including permits, 

licenses, and other authorizations, and approvals at the Federal, State, and local level, which 

would be necessary for the proposed IIFP facility’s construction, operation, and 

decommissioning, should NRC grant the license. 

1.5.1 State of New Mexico Laws and Regulations 

Certain Federal environmental requirements, including some discussed earlier, have been 

delegated by the Federal agencies to State authorities for implementation, enforcement, or 

oversight. In addition, the State of New Mexico has its own state laws, and Lea County has its 
 1-8 

own local laws. Table 1-1 provides a list of applicable New Mexico laws, regulations, and 

agreements, whereas Table 1-2, includes anticipated requirements of those agency laws, 

regulations, and policies where federal agencies have delegated authority to the state, and 

those laws, regulations and policies administered under autonomous state legal authority. New 

Mexico Statutes Annotated (NMSA) and implementing regulations in New Mexico Administrative 

Code (NMAC) are listed numerically by citation (primarily by NMSA statutory Chapter, Article, 

and Section; or secondarily by NMAC regulation Title, Chapter, and Part). 

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

Law, Regulation, or 

Agreement Citation Requirements 

New Mexico Wildlife 

Conservation Act 

NMSA, Chapter 17, Game and 

Fish and Outdoor Recreation, 

Article 2, Hunting and Fishing 

Regulations, and Part 3, 

Wildlife Conservation Act 

Requires a permit and coordination if 

a project may disturb habitat or 

otherwise affect threatened or 

endangered species. There are no 

known, or anticipated (other than 

transient), threatened or endangered 

species on the proposed site. 

New Mexico Raptor 

Protection Act 

NMSA, Chapter 17, Game and 

Fish and Outdoor Recreation, 

Article 2 Part 14, Hawks, 

Vultures, and Owls; taking, 

possessing, trapping, 

destroying, maiming, or selling 

prohibited except by permit; 

penalties 

The act makes it unlawful to take, 

attempt to take, possess, trap, 

ensnare, injure, maim, or destroy 

individuals of any species of hawk, 

owl, or vulture.

New Mexico Cultural 

Properties Act 

NMSA, Chapter 18, Libraries 

and Museums, Article 6, 

Cultural Properties 

The act defines the NM SHPO role 

and responsibilities, and establishes 

requirements to prepare an 

archaeological and historic survey 

and consult with NM SHPO. A 

cultural resources inventory was 

completed for the project. The survey 

for cultural resources consisted of a 

file search, field inventory, and 

inventory report. A negative 

declaration was prepared by the 

applicant and the NM SHPO 

concurred. NRC staff has not yet 

completed its consultation with the 

NM SHPO.

New Mexico Occupational 

Safety and Health 

NMSA, Chapter 50, 

Employment Law 

NMAC Title 11, Labor Workers 

Compensation, Chapter 5, 

Occupational Safety and 

Health 

The act and implementing regulations 

establish State requirements for 

assuring safe and healthful working 

conditions for every employee. 

These State regulations are being 

followed to ensure any additional 

requirements beyond the Federal 

Occupational Safety and Health 

Administration (OSHA) regulations 

are adequately addressed.
 1-9 

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

 (Continued) 

Law, Regulation, or 

Agreement Citation Requirements 

New Mexico Air Quality 

Control Act 

NMSA, Chapter 74, 

Environmental Improvement, 

Article 2, Air Pollution 

NMAC Title 20, Environmental 

Protection, Chapter 2, Air 

Quality 

The act and implementing regulations 

establish air quality standards and 

permit requirements that must be met 

prior to construction or modification of 

an emissions source. These 

regulations also define requirements 

for an operating permit for major 

producers of air pollutants and 

impose emission standards for 

hazardous air pollutants.

New Mexico Radiation 

Protection Act 

NMSA, Chapter 74, 

Environmental Improvement, 

Article 3, Radiation Control 

NMAC, Title 20, 

Environmental Protection, 

Chapter 3, Radiation 

Protection 

The act and implementing regulations 

establish State requirements for 

worker protection from radiation 

sources. Because the facilities would 

be privately owned, the State will 

require registration of security X-ray 

machines.

New Mexico Hazardous 

Waste Act (see note 

below) 

NMSA, Chapter 74, 

Environmental Improvement, 

Article 4, Hazardous Waste 

NMAC Title 20, Environmental 

Protection, Chapter 4, 

Hazardous Waste 

The act and implementing regulations 

establish State standards for the 

management of hazardous wastes. 

The New Mexico Environmental 

Development (NMED) regulations 

imposed on a generator or on a 

treatment, storage, or disposal (TSD) 

facility, vary according to the type and 

quality of material or waste 

generated, treated, stored, or 

disposed. The method of treatment, 

storage, or disposal also impacts the 

extent and complexity of the 

requirements. 

The IIFP plant may generate 

hazardous waste during construction 

and operation. These hazardous 

wastes will be temporarily stored and 

shipped off site for treatment and 

disposal in accordance with 

applicable NMAC and Resource 

Conservation and Recovery Act 

(RCRA) requirements. 

Note: Source, special nuclear, or by-product, material as defined by the Atomic Energy Act of 1954

is specifically excluded from the definition of a solid waste and therefore is not a hazardous waste 

regulated under RCRA or NMSA, Chapter 74, Article 9, Solid Waste Act and implementing 

regulations at NMAC Title 20, Chapter 9, Solid Waste. The IIFP facilities would not store (other than 

temporarily) or dispose of hazardous waste on site. IIFP may need a permit for operation of its 

Environmental Protection Process under the authority of RCRA or the New Mexico Hazardous 

Waste Act. 
 1-10 

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

 (Continued) 

Law, Regulation, or 

Agreement Citation Requirements 

New Mexico Radioactive 

and Hazardous Materials 

Act

NMSA, Chapter 74 

Environmental Improvement,, 

Article 4, Article 4A, 

Radioactive and Hazardous 

Materials

The act establishes a system of 

assuring public health and safety with 

regard to safe treatment, disposal, and 

transportation of radioactive and 

hazardous materials and coordinates 

efficient and timely emergency 

response to accidents and natural 

disasters with a centralized and 

coordinated source of information. 

New Mexico Hazardous 

Chemicals Information 

Act 

NMSA, Chapter 74 

Environmental Improvement,, 

Article 4E-1, Hazardous 

Chemicals Information Act 

The act implements the hazardous 

chemicals information and toxic 

release reporting requirements of the 

Emergency Planning and Community 

Right-to-Know Act of 1986 (Superfund 

Amendment and Reauthorization Act

[SARA] Title III) for facilities such as 

the proposed IIFP plant. 

New Mexico Water 

Quality Act 

NMSA, Chapter 74, 

Environmental Improvement, 

Article 6, Water Quality 

NMAC Title 20, Environmental 

Protection, Chapter 6, Ground 

and Surface Water Protection 

The act and implementing regulations 

establish water quality standards and 

apply to permitting prior to 

construction, during operation, and 

decommissioning, if necessary. 

Generally, a permit is required for 

discharges that could affect surface or 

groundwater. Any impoundments for 

sewage treatment facilities, cooling 

water or other discharges that exceed 

the standards listed in 20.6.2.3103 

NMAC or contain toxic constituents 

require a permit. No site-specific 

issues have been identified which 

would preclude permitting of needed 

water control and treatment facilities at 

the IIFP Site. 

New Mexico Groundwater 

Protection Act 

NMSA, Chapter 

74,Environmental 

Improvement, Article 6B, 

Groundwater Protection 

NMAC Title 20, Environmental 

Protection, Chapter 5, 

Petroleum Storage Tanks 

The act and implementing regulations 

establish State standards for 

protection of groundwater from leaking 

underground and above-ground 

storage tanks. 
 1-11 

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

 (Continued) 

Law, Regulation, or 

Agreement Citation Requirements 

New Mexico Night Sky 

Protection Act 

NMSA Chapter 74, 

Environmental Improvement, 

Article 12, Night Sky 

Protection 

The act establishes requirements to 

preserve and enhance the State’s dark 

sky while promoting safety, conserving 

energy and preserving the 

environment for astronomy. These 

requirements will be addressed during 

detailed design of the IIFP facility. 

Exchanges of State Trust 

Lands 

NMAC Title 19, Natural 

Resources and Wildlife, 

Chapter 2 State Trust Lands, 

Part 21, Land Exchanges 

The act establishes State standards 

and procedures for exchanges of 

lands held in trust, including 

consideration of cultural resources, 

natural resources, and wildlife. 

New Mexico Endangered 

Plant Species Act 

NMAC Title 19, Natural 

Resources and Wildlife, 

Chapter 21, Endangered 

Plants 

The act establishes an endangered 

plant species list and rules for 

collection. There are no threatened or 

endangered plant species on the 

proposed IIFP site. 

Registration of Tanks NMAC, Title 20, 

Environmental Protection, 

Chapter 5, Petroleum Storage 

Tanks, Part 2, Registration of 

Tanks 

The regulations establish the State 

standards for the regulation of 

petroleum storage tanks. If needed at 

the IIFP facility, storage tanks would 

be designed in accordance with State 

requirements and registration 

application made. 

Drinking Water 

Regulations 

NMSA, Chapter 74, 

Environmental Improvement, 

Article 1, General Provisions, 

Sections 1-8 and 1-13.1, and 

Article 6 Water Quality 

NMAC Title 20, Environmental 

Protection, Chapter 7, 

Wastewater and Water Supply 

Facilities, Part 10 Drinking 

Water 

The acts require the establishment of 

drinking water standards for New 

Mexico. These standards are found at 

20.7.10 NMAC. The proposed facility 

would use an on-site groundwater 

supply for all domestic water needs. 

Under the New Mexico drinking water 

regulations, the facility would be 

classified as a non-transient, noncommunity water supply system 

because it would regularly serve more 

than 25 people. 

Transportation and 

Highway 

NMAC Title 18, Transportation 

and Highways, Chapter 31, 

Classification and Design 

Standards, Part 6, State 

Highway Access Management 

Requirements 

The regulations establish State 

highway access management 

requirements that will protect the 

functional integrity of and investment 

in, the State highway system. 

Threatened and 

Endangered Species of 

New Mexico 

NMAC, Title 19, Natural 

Resources and Wildlife, 

Chapter 33, Endangered and 

Protected Species 

The regulations establish the State of 

New Mexico’s list of threatened and 

endangered wildlife species. There 

are no threatened or endangered 

species on the proposed plant site. 

Source: IIFP, 2009a 
 1-12 

1.5.2 Lea County and Local Laws and Regulations 

Lea County requires county permits for most major construction activity, but these permits are 

issued in accordance with subdivision ordinances at the time when parcel subdivision is 

approved; thus most other parcels where subdivision is not requested are not restricted by local 

subdivision ordinances and do not require county permits for construction activity. In other 

words, building permits for foundations, structures, electrical/mechanical systems, roadways, or 

temporary construction-related structures are not required by local ordinance, except where 

subdivision regulations apply. Because subdivision is not necessary for the IIFP facility, Article 

8 of Lea County’s subdivision regulations (or other local regulations) do not apply. 

1.5.3 Permit and Approval Status 

IIFP would prepare and submit several construction and operating permit applications, and 

regulatory approval and/or permits would be received prior to preconstruction, construction, or 

facility operation. It is IIFP’s responsibility to adhere to necessary permit application schedules 

and permit requirements prior to preconstruction, construction, or operation, as applicable. 

Tables 1-2 and 1-3 list the required Federal and State construction and operation permits and 

their status. 

1.5.3.1 Permits, Licenses, Authorizations, Approvals, and Consultations Required 

for Preconstruction and Construction 

Table 1-2 identifies the anticipated legal/regulatory requirements for site preparation and 

construction of the proposed IIFP facility. These include any permits, licenses, authorizations, 

approvals, or other regulatory entitlements required for constructing the proposed facility. 

Table 1-2 also identifies the status of these possible requirements. 

1.5.3.2 Permits, Authorizations, Approvals and Consultations Required 

for Operations 

Table 1-3 identifies the anticipated legal/regulatory requirements for operation of the proposed 

IIFP facility. Table 1-3 also identifies the status of these possible requirements. 

1.6 Cooperating Agencies 

No Federal, State, or local agencies or Native American Tribes have requested to be 

considered as cooperating agencies in the preparation of this EIS. 

1.7 National Historic Preservation Act of 1966 and the Endangered 

Species Act of 1973 Consultations 

The consultation requirements of the National Historic Preservation Act (NHPA) and 

Endangered Species Act (ESA) apply to the NRC with regard to the proposed IIFP facility 

licensing action. Consultation correspondence is provided in Appendix B 

(Consultation/Correspondence). 
 1-13 

Table 1-2. Legal/Regulatory Requirements and Authorizations for Site Preparation and Construction of the Proposed 

IIFP Facility 

Agency 

Legal/Regulatory 

Authority Activity Covered Status 

Permits, Licenses, 

Authorizations, 

Approvals, and 

Consultations 

Identification Permit Dates 

Federal – NRC 10 CFR 40 Domestic licensing of 

source material 

IIFP’s application accepted February 24, 2010; pending NRC review ongoing 

License Application (LA-IFP-001, IFP-002, & ER-IFP-001) 

Pending 

Federal – EPA Region 6 and State – NMED 

CWA 33 USC 1251 

Construction Stormwater General Permit and NOI 

3rd Qtr. 2012; 

Stormwater Pollution Prevention Plan and NOI (IIFP) 

Pending Pending 

Federal – USACE CWA 

33 USC 1251 

Fill of wetlands Applicability of 

depressions onsite determined by consultation (IIFP) 

Jurisdictional Determination complete (no wetlands present; no permit necessary) 

No permit needed; no jurisdictional wetlands or waters of the U.S. are present 

State – NMDOT District 2 

NMAC Title 18, Chapter 31, Part 6, State Highway Access Management Requirements 

Highway Access Management Permit for NM 483 and/or US 62/180 driveway entry and/or second (emergency) access point 

3rd Qtr. 2012 (IIFP or 

Lea County). The District 2 permit, if issued, would stipulate any required highway safety enhancements. 

Pending Pending 
 1-14 

Table 1-2. Legal/Regulatory Requirements and Authorizations for Site Preparation and Construction of the Proposed 

IIFP Facility (Continued) 

Agency Authority Activity Covered Status 

Permits, Licenses, 

Authorizations, 

Approvals, and 

Consultations 

Identification Permit Dates 

State – NMED/AQB 

Title 20 Chapter 2 Part 72, Clean Air Act Title V and NESHAP 

Preconstruction and New Source Review, NESHAP Permit (if needed; pending consultation with state AQB) 

Submitted 1st Qtr. 2012 (IIFP). A “Request for a No Permit Required Determination” for pre-licensing construction activities would be submitted. 

Pending Pending 

State – NMRL/CID NMAC Title 14 Building permits for 

foundations, structures, and electrical/mechanical systems, as well as temporary construction-related structures 

Projected for 3rd Qtr. 

2012 (IIFP) 

Pending Pending 

State – NMED/PSTB Above Ground 

Storage Tank Registration 

Petroleum storage tanks (size, design specifications, and fuel type) 

Projected for 2nd Qtr. 

2013 (IIFP) 

Pending Pending 

(IIFP, 2012) International Isotopes Fluorine Products, Inc. “Response to NC EIS Follow Up Questions on EIS Table 1-9.” E-mail communication to J. Miller and J. Thomas (IIFP) from M. Bartlett (NRC). Table 1-9, Federal and State Permits and Requirements. ADAMS Accession No. ML12089A470.. AQB—Air Quality Bureau, CWA—Clean Water Act, EPA—U.S. Environmental Protection Agency, ER—environmental report, IIFP—International Isotopes Fluorine Products, Inc., LA—license application, NESHAP—National Emissions Standards for Hazardous Air Pollutants, NMAC—New Mexico Administrative Code, NMDOT—New Mexico Department of Transportation, NMED/AQB—New Mexico Environment Department/Air Quality Bureau, NOI—Notice of Intent, NRC—U.S. Nuclear Regulatory Commission, USACE—U.S. Army Corps of Engineers, NMED/PSTB—Petroleum Storage Tank Bureau, NMRL/CID—New Mexico Regulations and Licensing/Construction Industries Division. 
 1-15 

Table 1-3. Legal/Regulatory Requirements and Authorizations for Operation of the Proposed IIFP Facility 

Agency Authority Activity Covered Status 

Permits, Licenses, 

Authorizations, 

Approvals, and 

Consultations 

Identification Permit Dates 

Federal – NRC 10 CFR 40 Domestic licensing of 

source material 

IIFP’s application 

Accepted February 24, 2010 (IIFP); pending review 

License Application (LA-IIFP-001, LA-IIFP-002, & ER-IFP-001) 

Pending 

Federal – NRC 10 CFR 73 and 74 Domestic licensing of 

physical protection and material control/accountability 

IIFP’s application accepted February 24, 2010; pending NRC review 

License Application (LA-IIFP-001, IIFP-002, & ER-IIFP-001) 

Pending 

Federal – NRC 10 CFR 20 Standards for 

Protection Against Radiation 

IIFP’s application accepted February 24, 2010; pending NRC review 

License Application (LA-IFP-001, IIFP-002, & ER-–IIFP-001) 

Pending 

Federal – EPA Region 6 and NMED 

CWA 33 USC 1251 

Multi-sector Industrial Stormwater General Permit 

Projected for 2nd Qtr. 

2013 (IIFP)

Pending Multi-sector Industrial General Permit (IIFP) 

Pending 

Federal – EPA Region 6 and state—NMED/HWB) 

RCRA Operations Permit 

EPA Operation If necessary, IIFP 

would submit 2nd Qtr. 

2013 (IIFP) 

Pending Pending 

Federal – EPA Region 6 and NMED/HWB 

RCRA EPA Waste Activity, 

EPA ID Number, for storage and use of hazardous chemicals 

2nd Qtr. 2013 (IIFP) Small Quantity 

Generator pending 

Pending 
 1-16 

Table 1-3. Legal/Regulatory Requirements and Authorizations for Operation of the Proposed IIFP Facility (Continued) 

Agency Authority Activity Covered Status 

Permits, Licenses, 

Authorizations, 

Approvals, and 

Consultations 

Identification Permit Dates 

State—NMED/AQB Clean Air Act Title V 

and NESHAP 

Air Operation Permit (if needed; pending consultation with State)

Submitted 1st Qtr. 2012 (IIFP); a separate NESHAP operating permit is required. 

Pending Pending 

State—NMED/HWB Hazardous 

Chemicals Information Act 

Hazardous Waste Permit 

Projected for 3rd Qtr. 2013 (IIFP) 

Pending Pending 

State – NMED/HWB Title 20, Chapter 4, 

Hazardous Waste 

EPA Waste Activity EPA ID Number 

Notification Form 8700-12 projected for 

2nd Qtr. 2013 (IIFP) 

Pending Pending 

State – NMED/RCB NMSA, Chapter 74, 

Article 3, Radiation Control and Title 20, Chapter 3 

Machine-Produced Radioactivity (X-Ray Inspection) 

May be required for security contractor 

but not required for IIFP 

Not required Not required 

State – NMED/DWB Safe Drinking Water 

Act (40 CFR 141, 142, 143; 07/01/2009) and 20-7.10 NMAC (10/15/2008) 

Drinking Water System Permit 

Projected for 2nd Qtr 

2013 (IIFP) 

Pending Pending 
 1-17 

Table 1-3. Legal/Regulatory Requirements and Authorizations for Operation of the Proposed IIFP Facility (Continued) 

Agency Authority Activity Covered Status 

Permits, Licenses, 

Authorizations, 

Approvals, and 

Consultations 

Identification Permit Dates 

State—NMED/WQB Title 20 Chapter 6, 

Groundwater 

Groundwater Discharge Plan and Permit; Liquid Waste Permit 

Projected for 3rd Qtr. 2013 (IIFP) 

Pending Pending 

State—NM WQCC NPDES NPDES Industrial 

Stormwater Permit 

Not required not required Not required 

State—RCB OSHA Regulations, 

29 CFR Part 1910; Federal FD&C Act; New Mexico Radiation Control Act 

Required for x-ray security inspection machines 

Identify permit-holder by 1st Qtr. 2011 (IIFP); submit list of source equipment 2nd Qtr. 2012 (IIFP) 

Machine-Produced Radiation Registration (X-Ray inspection) 

Security contractor may be required to obtain this permit under a separate application 

State—Utah Low-Level 

Radioactive Waste Policy Act (Northwest Interstate Compact, Utah Code Title 19 Chapter 3) 

LLW disposal at Nuclear Solutions (if chosen) 

Arrangement is needed for LLW disposal at Energy Solutions (if chosen) 

State – Washington Low-Level 

Radioactive Waste Policy Act (Northwest Interstate Compact, Compact for the State of Washington) 

LLW disposal at Hanford (Richland) (if chosen) 

Arrangement is 

needed for LLW disposal at Waste Control Specialist (if chosen) 
 1-18 

Table 1-3. Legal/Regulatory Requirements and Authorizations for Operation of the Proposed IIFP Facility (Continued) 

Agency Authority Activity Covered Status 

Permits, 

Licenses, 

Authorizations, 

Approvals, and 

Consultations 

Identification Permit Dates 

State—Texas Low-Level 

Radioactive Waste Policy Act and Texas Radiation Control Act (Texas LLW Interstate Compact with Vermont) 

LLW disposal at Waste Control Specialists (if chosen) 

Arrangement is 

needed for LLW disposal at U.S. Ecology Hanford (Richland) (if chosen). IIFP will not likely select this site but it was included as part of the impact assessment as an option. Would require approval from Rocky Mountain Compact 

(IIFP, 2012) International Isotopes Fluorine Products, Inc. “Response to NC EIS Follow Up Questions on EIS Table 1-9.” E-mail communication to J. Miller and J. Thomas (IIFP) from M. Bartlett (NRC). Table 1-9, Federal and State Permits and Requirements. ADAMS Accession No. ML12089A470.CWA—Clean Water Act; EPA—U.S. Environmental Protection Agency; ER—environmental report; FD&C—Federal Food, Drug, and Cosmetic Act; ID—identification number; IIFP—International Isotopes Fluorine Products, Inc.; LLW—low-level radioactive waste; NESHAP—National Emissions Standards for Hazardous Air Pollutants; NMAC—New Mexico Administrative Code; NMED/AQB—New Mexico Environment Department /Air Quality Bureau; NMED/HWB—New Mexico Environment Department/Hazardous Waste Bureau; NMED/RCB—New Mexico Environment Department/Radiological Control Bureau; NMED/GWQB—New Mexico Environment Department/Ground Water Quality Bureau;NMED/DWB—New Mexico Environment Department/Drinking Water Bureau; NMSA—New Mexico Statutes Annotated; NM WQCC—New Mexico Water Quality Control Commission; NPDES—National Pollutant Discharge Elimination System; NRC—U.S. Nuclear Regulatory Commission; OSHA—Occupational Safety and Health Administration; RCRA—Resource Conservation and Recovery Act.
1-19 

1.7.1 National Historic Preservation Act of 1966 Section 106 Consultation 

NRC staff initiated the NHPA Section 106 consultation process by letter dated July 2, 2010. 

NRC staff contacted the NM SHPO regarding information about historic sites and cultural 

resources that could potentially be affected by the proposed IIFP facility. In the letter, the NRC 

staff identified the Area of Potential Effect (APE) for the proposed project and requested 

information from the NM SHPO related to the proposed action’s potential to affect cultural 

resources. Also in the letter, the NRC staff stated its intent to use the NEPA process to comply 

with Section 106 of the NHPA as allowed in 36 CFR 800.8. The NM SHPO replied on 

July 15, 2010, that the SHPO had no record of any cultural resources surveys having been 

conducted and outlined the process for completing a survey, undertaking tribal consultation, and 

completing the Section 106 consultation process. IIFP conducted an archeological 

reconnaissance survey of the proposed site (as explained in later chapters of this document) 

according to New Mexico’s Cultural Properties and Historic Preservation, Standards for Survey 

and Inventory (NMHPD, 2005). By letter dated October 14, 2010, the New Mexico 

Commissioner of Public Lands, following his review of IIFP’s cultural resources survey 

document, recommended “a finding of no effect/no cultural properties/no historic 

properties....There are no documented cultural properties within the APE when considering 

direct effects. Similarly, there are no registered cultural properties within the assumed, five-mile 

APE when considering indirect effects.” The NM SHPO concurred with the New Mexico 

Commissioner of Public Lands determination on October 25, 2010. 

Consultation under NHPA with Native American Tribes (listed below) was undertaken using a 

list maintained by the NM SHPO. The list is based partially on U.S. Indian Claims Commission 

data and also on an NM SHPO Historic Preservation Division (HPD) ethnographic study, the 

National Park Service's Native American Consultation Database, and Tribes that have notified 

NM SHPO directly that they wish to be consulted. Based on tribal information provided for Lea 

County, in July 2010, the NRC staff contacted the Tribes listed below and requested information 

on historically or culturally significant resources within the APE of the proposed facility. The 

NRC staff also contacted the NM SHPO tribal liaison (Appendix B). Correspondence between 

NRC staff and the responding tribes is provided in Appendix B. 

• Apache Tribe of Oklahoma 

• Comanche Tribe of Oklahoma 

• Kiowa Tribe of Oklahoma 

• Mescalero Apache Tribe 

• Ysleta del Sur Pueblo 

• Shawnee Tribe 

NRC staff will consider comments received from tribes concerning this EIS. Otherwise, the 

coordination that has been conducted in accordance with the NHPA is complete. 

1.7.2 Endangered Species Act of 1973 Section 7 Consultation 

The NRC staff consulted with the USFWS to comply with the requirements of Section 7 of the 

Endangered Species Act (ESA). On July 2, 2010, the NRC staff sent a letter to the USFWS 

(New Mexico Ecological Field Office) describing the proposed action and requesting a list of 

threatened and endangered species and critical habitats that could potentially be affected by the 
1-20 

proposed action. The USFWS, in a letter dated August 10, 2010, provided general information 

about species of concern and critical habitat in New Mexico and Lea County, but made no sitespecific comments. In response to a verbal inquiry from the NRC staff, the NMGF responded in 

a letter dated June 21, 2011, with further information about wildlife habitat on the proposed IIFP 

site, recommendations for avoiding impacts to wildlife, and other best management practices 

(Appendix B). No federally threatened or endangered species or critical habitat have been 

identified on the proposed IIFP site to date; therefore formal Section 7 ESA consultation is not 

required for the NRC action (licensing) to occur. 

1.8 References 

(DOE, 2004) U.S. Department of Energy. 2004. Final Environmental Impact Statement for 

Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the 

Paducah, Kentucky, Site, DOE/EIS-0359. June 2004. ADAMS Accession No. ML 050380331. 

(IIFP, 2009a) International Isotopes Fluorine Products, Inc. 2009. Fluorine Extraction Process 

and Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A, ERIFP-001. December 27, 2009. ADAMS Accession No. ML100120758. 

(IIFP, 2009b) International Isotopes Fluorine Products. Inc. 2009. Fluorine Extraction Process 

and Depleted Uranium De-conversion Plant (FEP/DUP) License Application, Revision A, ERIFP-001. December 23, 2009. ADAMS Accession No. ML100630503. 

(NMHPD, 2005) New Mexico Historic Preservation Division, Department of Cultural Affairs. 

2005. New Mexico Register, Volume XVI, Number 15, Title 4, Cultural Properties and Historic 

Preservation; Chapter 10, Cultural Properties and Historic Preservation; Part 15, Standards for 

Survey and Inventory. Santa Fe, NM. August 15, 2005. ADAMS Accession No. ML112710497. 

(NRC, 2005) U.S. Nuclear Regulatory Commission. 2005. Environmental Impact Statement for 

the Proposed National Enrichment Facility in Lea County, New Mexico, NUREG-1790, Vol. 1. 

June 2005. ADAMS Accession No. ML051730238. 

(NRC, 2010a) U.S. Nuclear Regulatory Commission. 2010. Notice of Intent to Prepare an 

Environmental Impact Statement for the Proposed International Isotopes Uranium Processing 

Facility. July 8, 2010. ADAMS Accession No. ML101330539. 

(NRC, 2010b) U.S. Nuclear Regulatory Commission. 2010. Letter from Matt Bartlett (NRC) to 

John J. Miller (IIFP), “License Application for International Isotopes Fluorine Products, Inc. 

Facility – Acceptance Review (TAC No’s L32739 and L32740), February 23, 2010. ADAMS 

Accession No. ML100480302. 
 2-1 

2.0 ALTERNATIVES 

This chapter describes and compares the proposed action and its alternatives. As discussed in 

Section 2.1, the proposed action is for IIFP to construct, operate, and decommission a DUF6

deconversion facility near Hobbs in Lea County, New Mexico. In this EIS the NRC staff 

evaluates a reasonable range of alternatives to the proposed action, including alternative sites 

for the IIFP facility, alternative deconversion technologies, other DUF6 management options, 

and the no-action alternative. Under the no-action alternative, IIFP would not construct, 

operate, or decommission the proposed facility. Therefore, the no-action alternative provides a 

basis against which the potential environmental impacts of the proposed action are evaluated 

and compared. 

Section 2.1 presents detailed technical descriptions of the proposed action and related actions, 

including descriptions of the proposed site, preconstruction and construction activities, chemical 

process operations within the proposed plant, and decommissioning. Disposition of DUO2 is 

also discussed in Section 2.1. Section 2.2 describes alternatives to the proposed action, 

including the no-action alternative. The chapter concludes with a comparison of predicted 

potential environmental impacts of the proposed action and no-action alternative (Section 2.3) 

and a recommendation from the NRC staff regarding the proposed action (Section 2.4). 

2.1 Proposed Action 

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

operate, and decommission a facility (the proposed IIFP facility) in Lea County, New Mexico, for 

the deconversion of commercially generated DUF6 inventories into DUO2 and other 

deconversion products. The NRC would grant IIFP a license under 10 CFR 40 (Domestic 

Licensing of Source Material) to possess and use special nuclear material, source material, and 

byproduct material at the proposed IIFP facility. 

If the NRC issues a license to IIFP, the license would authorize IIFP to: 

• construct, operate, and decommission the proposed DUF6 conversion facility. 

• receive DUF6 cylinders from various commercial uranium enrichment facilities. 

• transport marketable deconversion byproducts to end users. 

• transport DUO2 for disposal as LLW or other potential disposition. 

IIFP anticipates that the proposed project would be implemented in two phases, but the current 

license application is for the first phase only (Phase 1), and only the potential impacts of the first 

phase are evaluated in this EIS. Phase 2 would be an expansion of the facility that would use a 

direct conversion technology described in Section 2.2.2.2.1. Because Phase 2 is a “reasonably 

foreseeable future action” (as defined in 40 CFR 1508.7), impacts associated with Phase 2 are 

considered cumulative impacts under NEPA. Cumulative impacts are discussed in 

Section 4.2.2 of this EIS. 
 2-2 

Phase 1 and 2 milestones are shown below. Phase 2 milestones are presented for 

information only. 

IIFP submitted license application to NRC December 30, 2009 

IIFP begins construction (Phase 1) 2Q 2012 

IIFP begins Phase 1 operations 4Q 2013 

IIFP submits license application for plant expansion (Phase 2) 2Q 2013 

IIFP begins construction of plant expansion (Phase 2) 2Q 2015 

IIFP begins Phase 2 operations late 2016 

The proposed action is described in detail in Sections 2.1.1 through 2.1.8. Unless otherwise 

indicated, the information presented in Section 2.1 is from the IIFP’s environmental report (IIFP, 

2009) and responses to NRC staff requests for additional information (IIFP, 2011a). 

2.1.1 Site Location and Description 

The proposed IIFP site is 22.5 km (14 mi) west of Hobbs, in Section 27 of Township 18S, Range 

36E, in Lea County, New Mexico. Figure 2-1 depicts the general site location in southeast New 

Mexico. Approximately 16 ha (40 ac) of the 259-ha (640-ac) Section would be dedicated to the 

deconversion facility. The remaining 243 ha (600 ac) would remain undeveloped. Figure 2-2 

locates the 16-ha (40-ac) facility within the Section. The Section now consists of mostly 

undeveloped land that has been used in the past for cattle grazing and gas and oil production. 

2.1.2 IIFP Deconversion Process 

At the proposed IIFP facility, the FEP/DUP would employ three basic processes, as described in 

detail in the sections that follow. In summary, the DUF6 would first be deconverted from DUF6

to depleted uranium tetrafluoride (DUF4), with marketable AHF produced as a byproduct. Then, 

DUF4 would be processed to produce two marketable deconversion byproducts: high-purity 

SiF4, and BF3, as needed. Plant throughputs are provided in Figure 2-3. The amount of silicon 

and boron byproducts produced would likely outpace the demand for these byproducts if all the 

potentially available DUF6 were converted using this process. Therefore, Phase 2 of the project 

would support a process that allows the direct conversion of DUF6 to uranium oxide, without 

producing the silicon and boron compounds. 

2.1.2.1 Deconversion of DUF6 to DUF4

As described in Chapter 1, DUF6 results from the enrichment of natural uranium during the 

manufacture of nuclear reactor fuel. It is stored and transported as a solid in cylinders 

specifically designed for these purposes. DUF6 is a solid at temperatures below 52oC (125oF). 

After receipt at the proposed IIFP facility, as the first step in the deconversion process, the 

cylinders would be placed in an autoclave enclosed in containment to vaporize the contents. 

The DUF6 vapor would be captured in a reaction vessel where it would react with hydrogen to 

produce DUF4 powder and AHF. The chemical equation for this process is as follows: 

DUF6 (gaseous) + H2 (gas) → DUF4 (solid) + 2HF (anhydrous) 

The DUF4 powder would be continuously withdrawn from the bottom of the vessel and fed to the 

FEP for further deconversion in either the silicon separation process or the boron separation 
 2-3 

 
 2-4 

 
2-5 

Figure 2-3. Plant Throughput for the DUF6 Deconversion Process 
 2-6 

process (Sections 2.1.2.2 and 2.1.2.3, respectively). Also, hydrogen fluoride (HF) can be 

anhydrous (meaning pure hydrogen fluoride without water) or not. In chemical equations, 

hydrogen fluoride is depicted as HF, but the parenthetic expression (anhydrous) is added when 

appropriate. Hydrofluoric acid is another term for hydrogen fluoride combined with water. HF 

offgases would be filtered, and any residual DUF6 would be trapped on carbon filters. The AHF 

would then be condensed to liquid form, and any entrained hydrogen burned. Offgas treatment 

is described in Section 2.1.6.4.1. AHF would be collected in 3,630-kg (8,000-lb) storage vessels 

to limit inventory should a leak occur. AHF storage vessels would be located in a building 

designed to contain a leak. The AHF would be loaded from this building into tanker trucks and 

shipped to customers. Figure 2-4 shows the process flow chart for this process. 

2.1.2.2 SiF4 Production 

To produce SiF4, the powdered DUF4 would be mixed with powdered silicon dioxide (SiO2) in a 

rotary calciner, and heated to react to form gaseous SiF4 and solid UO2 (U3O8) triuranium 

octoxide, sometimes referred to simply as uranium oxide or “yellowcake.” The chemical 

equation for this process is as follows: 

SiO2 (solid) + DUF4 (solid) → SiF4 (gas) + DUO2 (solid) 

The gaseous SiF4 would be collected from the calciner, filtered to remove any particulate 

contamination, and cooled to condense any hydrofluoric acid or other trace gases. The purified, 

gaseous SiF4 then would be collected in cold traps. The cold traps would be warmed to 

vaporize the SiF4, and the gaseous SiF4 would be stored in a vessel for subsequent packaging 

and shipment to customers. Offgas treatment is described in Section 2.1.6.4.1. Figure 2-5 

shows the process flow chart for this process. 

2.1.2.3 BF3 Production 

The BF3 production process would be very similar to that for SiF4, except that there would be a 

pretreatment step in which a feed mixture of boron oxide (B2O3) and DUF4 would be heated 

prior to mixing in the rotary calciner (Figure 2-6). The preheating would remove moisture by 

reacting the water with the DUF4, releasing gaseous (anhydrous) HF. The gaseous (anhydrous) 

HF would be filtered and scrubbed in the offgas system. The remainder of the process would 

be very nearly the same as for SiF4 production. The chemical equation for this process is 

as follows: 

2B2O3 (solid) + 3DUF4 (solid) → 4BF3 (gas) + 3DUO2 (solid) 

2.1.3 Description of the Proposed Facility 

The proposed facility would be typical of specialty industrial chemical facilities. The proposed 

16-ha (40-ac) facility would be enclosed with a security fence with a surveillance road just inside 

the fence. Pole-mounted security lighting would be installed around the entire perimeter. Entry 

into the proposed facility would be from the west via a paved road accessed from New Mexico 

Highway (NM) 483 which bounds the proposed site on the west (Figure 2-2). Structures within 

the security fence would include process, administration, and laboratory buildings; a 

maintenance shop; security facilities; utilities; cylinder storage pads; and warehouses. The 

parking lot would be outside the security fence. The tallest building is expected to be 

approximately 21 meters (m) (70 feet [ft]) high, and the tallest structure is a 40 m (131 ft) 

meteorological tower. 
2-7 

Figure 2-4. Process Flow Chart for Deconversion of DUF6 to DUF4
2-8 

Figure 2-5. Process Flow Chart for SiF4 Production 
2-9 

Figure 2-6. Process Flow Chart for BF3 Production 
2-10 

The proposed IIFP facility would have a Full DUF6 Cylinder Storage Pad with bollards to protect 

the cylinders from vehicles. The Pad is designed to be 53.3 m wide by 61 m long (175 ft wide 

by 200 ft long) and is sized to store up to 60 full cylinders. The Pad would be curbed for 

stormwater collection and provided with underground drains to a stormwater retention basin 

south of the Pad. There would also be a 32 m by 56.3 m (105 ft by 185 ft) Empty DUF6 Cylinder 

Storage Pad, with capacity for 40 empty cylinders. It would be the staging area for the shipment 

of empty cylinders. 

The main process buildings, listed below, would be on the proposed 16-ha (40-ac) facility. 

• DUF6 Autoclave Building 

• DUF4 Process Building 

• DUF4 Container Staging Building 

• Decontamination Building 

• FEP Process Building 

• FEP Oxide Staging Building 

• DUF4 Container Storage Building 

• FEP Product Storage and Packaging Building 

• AHF Staging Containment Building 

• Fluoride Products Trailer Loading Building 

• SiO2 Storage Silo 

• Potassium Hydroxide (KOH) Storage Tank 

• FEP and DUF4 Scrubbers and Scrubber Containment Pads 

Hydrogen used as a reactant in the deconversion processes would be generated onsite from 

natural gas using a vendor-supplied steam reforming system. The system would provide 

approximately 6 to 9 pounds per hour of hydrogen at 24.7 to 29.7 pounds per square inch 

absolute. The natural gas requirement is approximately 18.7 pounds per hour (420 standard 

cubic feet per hour). Other than a small surge tank, the site would not store hydrogen gas. 

All the building area aprons and areas surrounding outside equipment would have concrete 

curbing dikes designed to contain the largest possible spill of liquid chemicals, based on the 

volume of chemicals expected to be stored in each building/area. Pads for the storage of 

hazardous or corrosive chemicals would be coated to prevent leaks penetrating through the 

pads. The dikes would be equipped with pumps to transfer any spills to the Environmental 

Protection Process (EPP) equipment (Section 2.1.6.4.2). Radiological hand and foot monitors 

would be installed at exits of buildings where uranium would be handled. Fluoride and 

radiological detection systems, local alarms, and alarms in the control rooms would alert 

workers to potentially hazardous conditions. 

Auxiliary buildings would generally house: 

• materials 

• maintenance shops 
2-11 

• laboratories 

• steam boilers and supporting utilities 

• electrical utility equipment 

• sanitary water treatment equipment 

• equipment for process water treatment and recycling 

• personnel offices, break rooms, changing rooms, and restrooms 

2.1.4 Preconstruction and Construction 

Preconstruction activities include activities that would occur prior to issuance of the license and 

are discussed in cumulative impacts (Section 4.2.2). Preconstruction activities include site 

preparation activities and would not include the construction of process buildings or any safetyrelated structures. Preconstruction activities would include: 

• clearing land 

• grading the site and installing erosion controls 

• building the main entrance roadbed and drainage 

• setting up construction trailers 

• preparing preliminary site roadways and gravel parking area 

• (potentially) drilling water wells 

• constructing an electrical substation 

• stubbing in gas line to meter 

• constructing the administrative building shell 

• constructing the maintenance and storage building 

• constructing the material warehouse building shell 

• installing temporary fencing 

• constructing facility roadbeds and gravel parking areas 

• installing a geothermal heat pump loop 

• installing a firewater tank 

• installing a truck washing station 

During preconstruction, the 16-ha (40-ac) IIFP facility site would be graded to provide an 

approximately level grade at elevation 1,157 meters (3,797 ft) above mean sea level. 

Approximately 11-ha (26-ac) on the northeast would be cut approximately 0.3 meters (1 foot) in 

depth, resulting in a cut of an estimated 32,400 cubic meters (42,400 cubic yards). This 

excavated material would be used as fill in the northwest and southwest areas of the proposed 

facility location, including two isolated depressions on the west side of the site (approximately 

7.3-ha [18-ac]). The amount of fill required would be approximately 32,600 cubic meters 

(42,600 cubic yards), resulting in a deficit of 150 cubic meters (200 cubic yards) of fill needed 

that would be obtained onsite. 
2-12 

Heavy equipment that would be required for preconstruction (and construction) would include 

tractor/backhoes, graders, excavators, dozers, dump trucks, cranes, fuel trucks, water trucks, 

forklifts, and flatbeds. Additional equipment could include air compressors, concrete pumps, 

generators, and welding machines. During “construction,” which refers to all construction 

activities that occur after the license is issued, the remainder of the facility, including the process 

buildings, would be constructed. The following activities would occur during construction: 

• connecting utilities 

• completing the access road and parking lot 

• completing the construction of multiple structures including 13 process buildings, an 

administration building, laboratories, a maintenance shop, security facilities, cylinder 

storage pads, and warehouses 

• construction of a meteorological tower 

• installation of process equipment and other interior infrastructure 

• construction of the wastewater management system 

Construction of Phase 1 of the facility is expected to require 140 workers. 

During construction, a 0.6-m (2-ft) depth of topsoil (approximately 2,400 cubic meters 

[3,100 cubic yards]), would be removed in the areas of buildings and adjacent pads to provide 

adequate bearing for concrete floors and pads. Additionally, an estimated 3,000 cubic meters 

(4,000 cubic yards) would be removed at an approximate 0.6-m (2-ft) depth in the areas for the 

(full and empty) DUF4 cylinder pads. The material used to fill back to the foundation level would 

have soil compacting specifications suitable for the load bearing requirements that would be 

determined during the detailed engineering of the project. 

Foundations and footings for buildings, tanks and equipment, and for evaporation basins and 

the storm and sanitary sewer systems, would require excavation of an equivalent 3,170 cubic 

meters (4,150 cubic yards), encompassing excavation less backfill. 

The roadbed for the access road from NM 483 to the 16-ha (40-ac) site would require 

approximately 6,700 cubic meters (8,800 cubic yards) of fill. This fill would use most of the 

8,600 cubic meters (11,250 cubic yards) of material from the excavations described above. Any 

excess (or unsuitable fill material) would be spread approximately 0.15-m (6 inches [in]) deep 

and compacted over an estimated 0.4 to 0.8-ha (1 to 2-ac) area of the 258-ha (640-ac) section. 

The grading and temporary preparation of a construction access road would be included in the 

preconstruction activities, but final construction would occur during Phase 1 activities. 

2.1.5 Utilities and Other Services 

The FEP/DUP plant would require the installation of electrical and natural gas service lines from 

existing utilities that cross the proposed site and are outside the facility boundary. It is expected 

that these utility connections would be installed during preconstruction. Steam and compressed 

air would be generated on site (Section 2.1.5.4). Nitrogen would be internally generated on site 

or procured from a vendor. Hydrogen would be generated on site. Water would be obtained 

from on-site groundwater wells. 
2-13 

2.1.5.1 Electrical Power 

Most of the electrical power required by the proposed facility would be to operate four reaction 

vessels (calciners) in the FEP process building, and the refrigeration system and reaction vessel 

in the DUP process building. A new electrical substation and distribution line are proposed for 

providing electrical service to the facility. Currently 115- and 230-kilovolt transmission lines run 

along NM 483 and across Section 27. The local electric utility would install a 4.9 kilovoltampere substation and distribution lines to the facility. The substation would be within the 

facility fence. For some lighter loads, solar electric panels, both ground- and roof-mounted, 

would supplement the offsite power. 

2.1.5.2 Water 

The proposed facility would require relatively low volumes of process water because it would 

recycle process water and re-circulate cooling water. IIFP estimates that the total water supply 

requirement is less than 38,000 liters (L) (10,000 gallons [gal]) per day. Sanitary water 

requirements for showers, lavatories, drinking, toilets, and the laboratory would be 11,000 L to 

17,000 L (3,000 to 4,500 gal) per day of the total. Treated sanitary waste water would be used 

for landscape watering. Boiler blow-down would be sent to the EPP (Section 2.1.6.4.2) for 

treatment, if needed, and evaporation. 

No municipal water line runs near the proposed site. Therefore, it is anticipated that there would 

be at least one but no more than two groundwater wells to supply water for the facility. Lea 

County will install and provide one groundwater well as part of the land transfer to IIFP; IIFP 

would install another, if necessary, to obtain the desired yield for operations (of both the Phase 

1 and Phase 2 facilities operations). A package treatment plant would render the groundwater 

acceptable for potable water use. 

2.1.5.3 Natural Gas 

The proposed facility would require natural gas for two gas-fired boilers that would support 

process steam production, the autoclave feed system, and the hydrogen production plant. 

Several natural gas pipelines cross Section 27. Gas would be conveyed to the facility from one 

of these existing pipelines via a smaller-diameter distribution pipeline. 

2.1.5.4 Internal Utilities 

2.1.5.4.1 Steam 

Steam would be the primary heat source for vaporizing DUF6 in the autoclave, heating some 

process and warehouse buildings, and warming pipes as necessary to prevent solidification of 

temperature-sensitive substances. Steam requirements for the facility are estimated to be 

2,500 to 3,500 pounds per hour. Steam would be generated on site at 150 pounds per square 

inch (psig) using package boilers of about 10,000 pounds per hour capacity. 

2.1.5.4.2 Compressed Air 

Compressed air would be needed for operation of some instrumentation, control valves, dust 

collector blow-back, hopper vibrators, and miscellaneous uses. Ambient air would be filtered, 

compressed, and dried to deliver approximately 100 psig. 
2-14 

2.1.5.4.3 Nitrogen 

Gaseous nitrogen would be required for purge gas and for cooling pre-condensers in the FEP 

process building. Liquid nitrogen would be used for the cold traps. The cold nitrogen vapor 

exiting the product cold traps would be used for the pre-condenser cooling. Gaseous nitrogen 

leaving the condensers would be collected and compressed to supply gaseous nitrogen to the 

parts of the facility that require a dry inert gas. The main application would be for purge and 

seal systems, such as the rotary calciner inlet and discharge seals. IIFP plans to conduct a 

cost-benefit analysis during detailed design to determine whether to make or buy the liquid 

nitrogen or to use another cryogenic system, such as gaseous helium. It is assumed for this 

EIS that liquid nitrogen would be procured from a vendor. 

2.1.6 Facility Operations 

2.1.6.1 Workforce 

During Phase 1 operations, the continuous, fulltime workforce is expected to be approximately 

140 workers. 

2.1.6.2 Feedstocks 

The primary raw materials used in the facility would be DUF6, SiO2, and B2O3. Annual 

throughputs of these materials are provided in Figure 2-3. Other materials needed would be 

hydrogen, nitrogen, potassium hydroxide (KOH), and lime. 

2.1.6.3 Products 

The finished products are fluoride products, namely AHF, SiF4, and BF3. The byproduct of the 

facility is a chemically stable DUO2 suitable for permanent offsite disposal, if desired 

(Section 2.1.8). The expected annual production of these materials is provided in Figure 2-3. 

The design-basis inventories are provided in Table 2-1. 

2.1.6.4 Waste Streams 

The wastes from the FEP/DUP plant include gaseous emissions, process wastewaters, sanitary 

wastes, and solid wastes. These waste streams and their treatment methods are described 

below. Gaseous emissions rates are provided in Table 2-2. 

2.1.6.4.1 Process Offgas Treatment and Stacks 

The plant would have three stacks to vent treated process offgases and particulates to the 

atmosphere: the KOH Scrubbing System Stack, the DUF4 Dust Collector System Stack, and 

the FEP Dust Collector System Stack. Prior to venting, the particulate and gas process streams 

would be filtered and/or scrubbed using multi-stage equipment. Additionally, one boiler vent 

stack would release natural gas combustion products to the atmosphere. 

Offgas Treatment 

Final off-gas streams from the DUF6 to DUF4, SiF4, and BF3 processes (comprised mostly of 

nitrogen, air, and trace fluorides) would enter the Plant KOH Scrubbing System, a three-stage 
2-15 

Table 2-1. Facility Design Basis Inventories 

Material 

Maximum Limit 

Agreement with New Mexico 

Projected Average 

Phase 1 

Total depleted uranium 

(DUF6, DUO2 and DUF4) 

2,200,000 kg 

(4,851,000 lb) 

See Note 2

DUF6 See Note 1 15-20 full cylinders 

165,000-220,000 kg 

(363,000-484,000 lb)

DUF6 in process See Note 1 19,500-30,000 kg 

(43,000-66,000 lb) 

DUF4 See Note 1 63,500-136,100 kg 

(140,000-300,000 lb) 

Uranium oxides as DUO2 See Note 1 154,200-213,200 kg 

(340,000-470,000 lb) 

HF (aqueous) 23,300 kg 

(51,400 lb) 

4,500-6,800 kg 

(10,000-15,000 lb) 

AHF 45,000 kg 

(99,200 lb) 

14,000-15,900 kg 

(31,000-35,000 lb) 

SiF4 (packaged + 

in-process)

64,700 kg 

(142,700 lb) 

21,800-31,800 kg 

(48,000-70,000 lb) 

BF3 (packaged + 

in-process) 

22,400 kg 

(49,400 lb) 

7,800-15,000 kg 

(17,000-33,000 lb) 

KOH 8,100 kg 

(17,900 lb) 

6,800-7,700 kg 

(15,000-17,000 lb) 

CaF2 (calcium fluoride) 36,500 kg 

(80,500 lb) 

20,400-22,700 kg 

(45,000-50,000 lb) 

Source: IIFP, 2009 

lb = pound; kg = kilogram 

Note 1: The “Maximum Limit” applies to the total depleted uranium as either DUF6 (both in cylinders and in 

process), DUO2 or DUF4. 

Note 2: The “Projected Average” is provided as individual breakdowns for DUF6 in cylinders and in process, DUO2, 

and DUF4.

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

Facility Operations 

Pollutant Emissions Units 

CO 1,200 

(1.3) 

kg/yr 

(tons/yr) 

NO2 290 

(0.32) 

kg/yr 

(tons/yr) 

PM2.5 100 

(0.11) 

kg/yr 

(tons/yr) 

PM10 100 

(0.11) 

kg/yr 

(tons/yr) 

SO2 18 

(0.02) 

kg/yr 

(tons/yr) 
2-16 

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

Facility Operations (Continued) 

Pollutant Emissions Units 

SiF4 3.7 

(8.2) 

kg/yr 

(lbs/yr) 

BF3 64 

(141) 

kg/yr 

(lbs/yr) 

HF 53 

(117) 

kg/yr 

(lbs/yr) 

CaF2 3.5 

(7.8) 

kg/yr 

(lbs/yr) 

CaCO3 61 

(134) 

kg/yr 

(lbs/yr) 

B2O3 4.9 

(10.8) 

kg/yr 

(lbs/yr) 

U-234 5.2 x 105

(1.4 x 10-5) 

becquerels (Bq)/yr 

curies (Ci)/yr 

U-235 4.8 x 104

(1.3 x 10-6) 

Bq/yr 

(Ci/yr) 

U-238 4.4 x 107

(1.2 x 10-3) 

Bq/yr 

(Ci/yr) 

Source: IIFP, 2011a 

CO = carbon monoxide; NO2= nitrogen dioxide; PM2.5=particulate matter less than 2.5 microns in diameter; 

PM10=particulate matter less than 10 microns in diameter; CaF2=calcium fluoride; CaCO3 = calcium carbonate; 

U-234, U-235 and U-238= isotopes of uranium. 

scrubber system, to remove fluoride from the offgases prior to releasing them to the 

atmosphere. 

Two parallel systems would provide operating flexibility. The first stage of each scrubber 

system would consist of a primary wet venturi scrubber. The second stage would consist of a 

countercurrent-flow, gas-liquid packed tower scrubber. The third-stage scrubber would route 

gas exiting the secondary packed tower scrubber though a bed of sized coke (a cellular, 

carbonaceous material derived from the destructive distillation of coal or petroleum products). 

The coke would be wetted by an aqueous KOH solution that serves as the scrubber liquor. The 

aqueous KOH solution would be recycled within each of the scrubbers until the concentration of 

KOH needs replenishment (i.e., until the KOH no longer effectively captures the fluoride 

residuals, referred to as being “spent”). The KOH solution concentration in the scrubber 

equipment would be maintained to ensure it effectively reacts with (scrubs) the fluoride 

components in the gas stream. 

When the KOH scrubbing liquor concentration needs replenishment, some of the spent 

scrubbing solution, containing potassium fluoride (KF), water, and some excess KOH, would be 

pumped from the scrubber recycle tanks to the EPP (described in Section 2.1.6.4.2). The Plant 

KOH Scrubbing System process flow is depicted in Figure 2-7 and consists of a KOH storage 

tank, KOH pump tank, regenerated KOH tank, two or three (installed spare) venturi scrubbers, 

two packed towers, and two coke boxes. 
2-17 

Figure 2-7. Plant KOH Scrubbing System Process Flow 
 2-18 

The three-stage KOH scrubbing system would be designed to remove fluoride-bearing 

components in the gas streams at approximate efficiencies of greater than 80 percent, 

95 percent, and 99 percent for the first, second, and third stages, respectively. The overall 

system removal efficiency would be designed at greater than approximately 99.9 percent. The 

plant KOH scrubbing system stack would be continuously sampled to measure for traces of 

fluorides or uranium in the vent gas. 

Process Dust Collection 

Dust capture and collection systems would be installed in areas where depleted uranium 

particulates, such as DUF4 or DUO2, would be handled or processed. The dust collection 

systems would be filter-type baghouses that would remove the depleted uranium particulates 

prior to discharging the process gas to the outside environment through the DUF4 Dust Collector 

Vent Stack. 

Equipment where depleted uranium-bearing powders would be handled or stored, such as 

storage hoppers and enclosed drum packaging stations, would be connected to the dust 

collection intakes. Uranium particulates captured by the dust collection systems either would be 

recycled back to the respective process operations or packaged and sent to an approved 

off-site disposal facility. The design efficiency of baghouse dust collectors would be greater 

than 99.5 percent for each collector. At least two components would be used in series to 

ensure an overall system efficiency of greater than 99.9 percent in the collection and removal of 

particulate uranium from the vented process gas. 

Sampling and analysis for uranium would be performed routinely on each baghouse dust 

collector. If an unacceptable level of uranium carryover was detected on any given dust 

collector, it would be removed from service for maintenance. Additionally, each baghouse 

would be continuously monitored for differential pressure across the filter bag sections to ensure 

bag design integrity was maintained. 

2.1.6.4.2 Environmental Protection Process 

The EPP would treat KF solutions to regenerate KOH, and neutralize weak aqueous HF. Both 

of these waste streams originate from offgas scrubbing systems designed to prevent air 

emissions, as described in Section 2.1.6.4.1. 

A KF solution would be generated when KOH was used as a scrubbing medium. In the KOH 

regeneration process of the EPP, the KF solution, water, and excess KOH spent solution from 

the plant KOH scrubbing system would react with a lime slurry, producing calcium fluoride 

(CaF2) and regenerated KOH solution. The regenerated KOH would be recycled and reused in 

the plant scrubbing process. The CaF2 would be filtered, dried, and packaged for shipment to 

an approved disposal facility, to an HF producer, or to another potential user. 

The other stream treated in the EPP would consist of a weak aqueous HF solution, water, or 

KOH solution that may contain a low concentration of fluorides. Also, small spills that could 

occur in spill control containment areas and require clean up and that could contain weak 

fluoride concentrations would be treated in the EPP like the weak HF solution. In these cases, 

the fluoride-bearing liquids could have too much water to send to the KOH regeneration system. 

The HF neutralization process would use lime slurry to react with weak HF to produce CaF2

and water. 
 2-19 

Figure 2-8 depicts the EPP HF Neutralization and KOH Regeneration processes. These 

processes are discussed below. 

KOH Regeneration 

Lime would be fed to an agitated mix tank and mixed with water. The lime/water slurry would be 

approximately 30 percent solids. Spent KOH solution (KOH solution with a weak concentration 

of KOH) would be transferred from a storage tank to an agitated reaction vessel that has a 

volume of about 22,712 L (6,000 gal). The lime slurry would be transferred from the mix tank to 

the reaction vessel. The solutions would remain in the reaction vessel tank for one hour or 

more to ensure the reaction was complete. Then the contents of the reaction vessel would be 

transferred to a thickening tank for settling. CaF2 from the chemical reaction and excess lime 

would be transferred by a slurry pump from the bottom of the thickening tank to a rotary drum 

vacuum filter. Solids would be discharged from the filter to a dryer to remove excess water. 

Liquors would be transferred from the filter to a clarifier to allow trace solids to settle. 

Regenerated KOH solution would be decanted from the top of the clarifier and passed through a 

set of filters to the regenerated KOH storage tank. The regenerated KOH solution would be 

recycled to the Plant KOH Scrubbing System, as needed, for reuse by the scrubbers. Solids 

from the clarifier would be transferred via a slurry pump from the bottom of the clarifier to the 

rotary drum vacuum filter and subsequently transferred to the dryer. The dried material would 

be packaged and stored for sale or sent to an approved disposal facility. The primary chemical 

reaction is: 

2KF + Ca(OH)2 (calcium hydroxide) → CaF2 +2KOH 

HF Neutralization 

The HF Neutralization process would operate intermittently, as needed. A lime silo would hold 

an inventory of hydrated lime. The silo would include a dust collector. Lime would be fed to a 

mix tank and mixed with water. The slurry would be approximately 30 percent solids. Dilute HF 

solution would be transferred from the weak HF solution tank to an agitated acid reaction vessel 

with a volume of about 22,712 L (6,000 gal). The lime slurry would be transferred from the mix 

tank to the acid reaction vessel. The solutions would remain in the acid reaction vessel for one 

hour or more to ensure the reaction was complete. Then the solution from the acid reaction 

vessel would be transferred to a thickening tank for settling. After thickening, CaF2 and excess 

lime would be transferred by a slurry pump from the bottom of the thickening tank to a rotary 

drum vacuum filter. Solids would be discharged from the filter to a dryer to remove excess 

water. Liquors from the filter would be recycled to the weak HF solution tank for recycling. After 

drying, the CaF2 would be packaged for sale or disposal at an approved disposal facility. The 

primary chemical reaction is: 

2HF + Ca(OH)2 → CaF2 + 2H2O (water) 

2.1.6.4.3 Sewer Systems 

Storm Sewers and Stormwater Collection Basins 

The facility storm sewer system design assumes a 100-year storm for the Hobbs, New Mexico, 

area of 8.9 to 10.2 centimeters (cm) (3.5 to 4 in) of rain falling in one hour. IIFP performed 

preliminary engineering of the drainage system size and layout to estimate costs, determine 

requirements, and provide information for later detailed design. The preliminary design includes 
2-20 

Figure 2-8. EPP HF Neutralization and KOH Regeneration Processes 
 2-21 

the locations of the process buildings, auxiliary buildings, pads, roads, parking lot, and water 

treatment plant and electrical substation. All of the storm sewer systems would be inside the 

fenced area and would collect rainwater runoff from an estimated 8- to 10-ha (20- to 25-ac) 

area, including roadways, building roofs, and pads. 

Two collection basins are planned to handle storm water drainage surges. One basin would 

serve the Full DUF6 Cylinder Storage Pad. The other would be the main holding basin for the 

site storm sewer drainage system. Preliminary engineering calculations performed by IIFP 

estimate the main basin needs to be approximately 2,800,000 L (100,000 cubic ft) in volume, 

assuming a 20 percent freeboard above the maximum design water level. The basin would be 

double-lined with impervious synthetic materials typically used in these applications. IIFP’s 

current plans are to use a sand base with a layer of geo-synthetic liner and a second layer of 

high density polyethylene. Detail engineering and specifications would be refined after civil 

engineering data are obtained from the site surveys and after discussions with the New Mexico 

Environment Department regarding permits. 

Sanitary Sewer 

Preliminary design of the sanitary sewer system provides for capability to handle hydraulic 

loading of about 11,356 to 17,034 L (3,000 to 4,500 gal) per day. Sanitary sewer discharge 

would be treated in primary and secondary package systems for digestion and activation. 

Tertiary treatment with disinfection, probably using ultraviolet radiation, would follow. Biomass 

generated by the treatment would be removed from the site by a licensed disposal contractor. 

The triple-treated water would be re-used as process water in the facility or for landscape 

irrigation. 

Process Sewer 

Process water and solutions, and KOH liquors would be pumped, when contaminant 

concentrations dictate, from process systems or the air emissions scrubbing units, respectively, 

to the EPP via above-ground piping. Pipes would be double-walled to prevent leakage of 

hazardous solutions out of the piping system if the piping cannot be routed through areas with 

adequate spill containment. 

2.1.6.4.4 Solid Wastes 

IIFP would use solid waste management systems including facilities, administrative procedures, 

and practices for the collection, temporary storage, and disposal of categorized solid waste. No 

solid waste processing is planned. The facility would generate industrial (nonhazardous), 

radioactive, hazardous, and mixed wastes. Radioactive and mixed waste would be segregated 

according to the volume of liquid that could not be readily separated from the solids. Solid 

radioactive wastes would be low-level (radioactive) waste (LLW) as defined in 10 CFR 61, 

“Licensing Requirements for Land Disposal of Radioactive Waste.” Table 2-3 provides the 

estimated annual quantities of solid waste. 

Industrial waste, including sanitary waste, miscellaneous trash, vehicle air filters, empty cutting 

oil cans, miscellaneous scrap metal, and paper would be shipped off site for minimization, if 

appropriate, and then disposed in an appropriate licensed landfill. 
 2-22 

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

Material Estimated Annual Amount 

Low-Level Waste 1,309,000 – 2,875,000 kg 

(2,885,650 – 6,337,300 lbs) 

Hazardous Waste a 92,000 – 140,000 kg 

(203,200 – 308,400 lbs) 

Other Solid Waste 27,510 – 41,400 kg 

(60,650 – 91,300 lbs) 

Source: IIFP, 2011a 

a Includes calcium fluoride which would not be hazardous waste if it is sold as a byproduct. 

The DUO2 waste from the deconversion process could be shipped to an offsite LLW disposal 

facility licensed to accept DUO2 (Section 2.1.6.5.3 and Section 2.1.8). Other LLW, including 

dust collector bags, ion exchange resin, crushed contaminated drums, contaminated trash, 

contaminated coke, and carbon trap material would be collected in labeled containers in each 

radiological Restricted Area and transferred to the Radioactive Waste Storage Area for 

inspection. Waste would be volume-reduced, if appropriate, and disposed at a licensed LLW 

disposal facility. 

Hazardous wastes and some mixed wastes would be collected at the point of generation, 

transferred to the Waste Storage Area, inspected, and classified. Any mixed waste that could 

be processed to meet land disposal requirements would be treated in its original collection 

container and shipped as LLW for disposal at a licensed LLW disposal facility. Hazardous 

wastes would be collected and packaged in approved containers and shipped by a licensed 

transporter to a licensed hazardous waste disposal facility. There would be no on-site disposal 

of any solid waste at the IIFP facility. 

2.1.6.5 Product and Byproduct Packaging and Shipping 

Three types of products/byproducts would be shipped: AHF, FEP products (SiF4 and BF3), and 

depleted uranium oxides (e.g., DUO2). Given the hazards of fluoride products, especially AHF, 

the AHF Staging Containment Building and the FEP Products Trailer Loading Building would be 

equipped with an array of water-fog nozzles that would automatically activate in the event of a 

leak of AHF or fluoride product chemicals. Fluoride detectors would be deployed throughout the 

two buildings to ensure effective coverage. The detection and control system would be 

designed for automatically closing isolation valves at the storage tanks and at the tank trailer fill 

lines. The detection system would also provide automatic and manual controls for initiating the 

water deluge system in event of chemical leaks in either building. 

2.1.6.5.1 AHF 

The AHF Staging Containment Building and equipment would provide temporary storage of 

AHF received from the DUF6 to DUF4 process AHF condensers. AHF would be stored in the 

AHF Staging Containment Building in approximately 3,630-kg (8,000-lb) capacity tanks. Dikes 

around each storage tank would be sized to hold the contents of the storage tank, with a margin 

of safety to minimize the surface area (and evaporation rate of the AHF) in the unlikely event the 

tank breached and spilled liquid AHF. 
 2-23 

When AHF inventories reach a volume suitable for shipment, the AHF would be loaded into an 

approved tank trailer staged in the Fluoride Products Trailer Loading Building, which would be 

connected to the AHF Staging and Containment Building. The transporter-owned or customerowned tank trailer would be approved by the U.S. Department of Transportation (DOT) and of 

the design and type routinely used for shipping AHF nationwide (typically type DOT-412 trailer, 

loaded to about 13,608 to 18,144 kg [30,000 to 40,000 lb] of product). The Fluoride Products 

Trailer Loading Building would have a truck entrance door that remained closed, sealed, and 

controlled except for short periods when the tank trailer would be moved in and out. A transfer 

line from the storage tanks in the AHF Staging Containment Building would enter the tank trailer 

side of the Fluoride Products Trailer Loading Building. Safety precautions, controls, and 

barriers would prevent the tank trailer from inadvertently being moved or from contacting the fill 

line. 

2.1.6.5.2 FEP Products 

The SiF4 and BF3 products awaiting shipment to customers would be stored in the FEP Product 

Storage and Packaging Building until packaged within the Building into customer-owned, 

DOT-approved shipping cylinders (typically type 3A or 3AA). The SiF4 or BF3 product could be 

packaged into DOT-approved shipping tube trailers, and in this case the product would be 

transferred from the storage vessels to a tube trailer parked in the Fluoride Products Trailer 

Loading Building. 

2.1.6.5.3 Depleted Uranium Oxides 

DUO2 and all other LLW materials generated at the facility would be transported by truck in 

208-(wet) or 242-(dry) L (55-gal) drums in accordance with NRC and DOT packaging and 

shipping regulations (10 CFR 71 and 49 CFR 171-173). Trucks would carry 20 to 25 drums per 

shipment. The drums would be disposed of at a licensed off-site LLW disposal facility. For 

purpose of analysis in this EIS, the expected disposal site is considered to be the 

EnergySolutions facility at Clive, Utah. See Section 2.1.8 for a discussion of depleted uranium 

oxide disposal options. 

2.1.7 Decommissioning 

The proposed IIFP facility would be licensed to operate for 40 years. At the end of this period, 

unless IIFP files a timely application for license renewal, the proposed facility would be 

decontaminated and decommissioned in accordance with applicable NRC license termination 

requirements. The FEP/DUP facility would be decommissioned such that the site and 

remaining facilities could be released for unrestricted use as defined in 10 CFR 20.1402. 

Decontamination and decommissioning would occur over three years, after the NRC operating 

license expires and if no application to renew the license is submitted. Decommissioning would 

employ 40 workers for the three-year period (IIFP, 2009). 

Two possibilities exist for the facility structures and paved areas. One is to leave the structures 

and most (non-uranium-processing) support equipment in place after it is decontaminated to 

free release levels, in accordance with 10 CFR 20, for ultimate use by another industrial tenant 

or owner. The second scenario is to raze the structures and remove the pavement, restoring 

the site for use as open range land (e.g., grazing and wildlife habitat). IIFP’s analytical 

assumption is that decommissioning would involve the removal of the internal equipment (both 

Phase 1 and Phase 2 expansion, if built), utilities, and products from the building(s); however, 

the physical structures, associated foundations, access roads, and utility lines would likely 
 2-24 

remain intact, (i.e., the first scenario). Decommissioning of the proposed IIFP facility would 

include decontamination and removal of uranium-processing equipment and other materials that 

would be shipped offsite for licensed disposal. Radioactively contaminated equipment and 

materials would be sent to a licensed treatment and/or disposal facility in a manner authorized 

by the NRC (IIFP, 2009). Prior to the expiration of the license or cessation of facilities 

operation, whichever comes first, IIFP would submit a detailed decommissioning plan, which 

would undergo additional NEPA review. 

2.1.8 Depleted Uranium Disposition Options 

On average, the facility would produce approximately 0.32 to 0.36 kg (0.7 to 0.8 lb) of DUO2 for 

every pound of DUF6 processed, yielding approximately 2.5 million kg (5.6 million lb) of DUO2

annually (Figure 2-3). The DUO2 could either be disposed as LLW or recycled. Potential 

reuses of depleted uranium are as aircraft and ship ballast, as ingredients in pigments and 

glazes, as shielding material, as forklift counterweights, in armor-piercing projectiles, in high 

density concrete, as material to downblend highly enriched uranium, as a component of fuel in 

fast breeder reactors (including the proposed variant, the traveling wave reactor), as an 

ingredient in mixed-oxide fuel for thermal reactors, and as shielding/absorber in waste 

repositories. Some of these uses are conceptual and have never been employed. Others are 

in little demand or use only small quantities of depleted uranium, making them unfavorable for 

disposition of large volumes of depleted uranium. The uranium fuel cycle as currently 

configured in the U.S. does not have the capacity to accept significant quantities of depleted 

uranium (DOE, 1999). 

Depleted uranium is different from most LLW in that it consists mostly of long-lived isotopes of 

uranium, with small quantities of thorium-234 and protactinium-234. The Commission affirmed 

that depleted uranium is properly considered a form of LLW in Louisiana Energy Services, L.P. 

(National Enrichment Facility), CLI-05-5, 61 NRC 22 (January 18, 2005; NRC, 2005a). This 

means that depleted uranium could be disposed of in a licensed LLW facility if the licensing 

requirements for land disposal of radioactive waste in 10 CFR 61 are met. However, a specific 

site may place additional limits on concentration, volume, or waste form. 

Disposal options, including waste form, would be determined after licensing and may change 

over the operating life of the facility; however, licensed LLW disposal facilities, including the U.S. 

Ecology site in Richland, Washington, EnergySolutions site in Clive, Utah, DOE’s site in Area 5 

of the Nevada National Security Site (formerly the Nevada Test Site), and the Waste Control 

Specialists (WCS) facility in Andrews, Texas are potential options, provided regulatory and 

contractual conditions can be satisfied. The U.S. Ecology facility is in the Pacific Northwest 

Compact which has an agreement with the Rocky Mountain Compact (of which New Mexico is a 

member) to dispose of waste, but the U.S. Ecology facility’s license would need a revision in the 

allowable total uranium inventory. EnergySolutions accepts shipments from all states and is 

currently developing a performance assessment to establish inventory limits, if needed. 

Shipment to the Nevada National Security Site would require DOE to accept possession of the 

LLW (consistent with Section 13 of the USEC Privatization Act of 1996). 

The WCS facility is 42 km (26 mi) southeast of the proposed site but is currently limited to waste 

from the Texas Compact and therefore, would have to establish approval mechanisms for outof-compact waste to be disposed. Furthermore, the Rocky Mountain Compact would have to 

approve shipment outside the compact. The analysis in the EIS is not intended to support 

selection of the LLW disposal facility for the DUO2. 
 2-25 

2.2 Alternatives to the Proposed Action 

The range of alternatives to the proposed action was determined by considering the underlying 

purpose and need for the proposed action and consideration of the no-action alternative. In 

addition, DUF6 management options from the DOE’s programmatic EIS on long-term DUF6

management (DOE, 1999) were considered. From this evaluation, the NRC staff developed a 

set of reasonable alternatives. These alternatives include: 

• a no-action alternative under which the proposed FEP/DUP facility would not be 

constructed 

• deconversion of DUF6 at DOE facilities 

• alternative sites for the proposed facility 

• alternative technologies available for DUF6 deconversion 

• overseas deconversion of DUF6

• indefinite storage of DUF6 at the uranium enrichment facilities 

• deconversion of DUF6 at the uranium enrichment facilities 

2.2.1 No-Action Alternative 

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

and decommission the proposed IIFP facility near Hobbs, New Mexico. The proposed site 

would remain undeveloped except for preconstruction activities performed by IIFP. The 

regional economy would not be changed either positively or negatively. LLW would not be 

shipped to disposal facilities. Fluoride products would not be manufactured, sold, and shipped 

to end users. 

The comparison of impacts between the proposed action and no-action alternative is provided in 

Table 2-4. Environmental impacts of the no-action will be less than the proposed action. 

However, the no-action alternative does not serve the purpose and need. Presently, there are 

four existing or planned domestic commercial enrichment facilities: URENCO USA (formerly 

Louisiana Energy Services) National Enrichment Facility, Eunice, New Mexico; AREVA Eagle 

Rock, Idaho Falls, Idaho; American Centrifuge Plant, Piketon, Ohio; and GE Global Laser 

Enrichment, Wilmington, North Carolina. Under the no-action alternative, the four planned or 

existing domestic, commercial uranium enrichment facilities would not send their DUF6 to the 

IIFP facility for deconversion. Four other options would be open to them: (1) ship the DUF6 to a 

DOE deconversion facility; (2) ship the DUF6 to one of the deconversion facilities overseas; 

(3) indefinitely store the DUF6; or (4) construct their own deconversion facilities. As explained in 

the subsequent paragraphs of this Section and in Section 2.2.2, all of these options but the first 

are identified in Section 2.2.2 as alternatives considered but eliminated from further 

consideration in this EIS. 

DOE has constructed two deconversion plants to convert DUF6 to U3O8 and hydrofluoric acid; 

one in Piketon (Portsmouth), Ohio and one in Paducah, Kentucky (DOE, 2004a; DOE, 2004b). 

The Ohio facility began operating in October 2010, and the Kentucky facility is slated to begin 

operating in 2011. Therefore, shipment to these DOE facilities is a viable option under the 

no-action alternative. Such shipment is allowed under the provisions of the United States 

Enrichment Corporation (USEC) Privatization Act of 1996. 
 2-26 

The option to ship DUF6 to the DOE deconversion facilities was considered in the National 

Enrichment Facility EIS (NUREG-1790; NRC, 2005b). This facility, near Eunice, New Mexico, is 

now known as the URENCO USA facility. As quoted in its Commission Order CLI-05-05 (NRC, 

2005a), NRC stated (in CLI-04-3 regarding the LES facility) that, “an approach by LES to 

transfer to DOE for disposal by DOE of LES[’s] depleted tails pursuant to Section 3113 of the 

USEC Privatization Act constitutes a ‘plausible strategy’ for dispositioning the LES depleted 

tails” if the tails could be considered LLW under 10 CFR 61.1

 Commission Order CLI-05-05 

further stated that DUF6 tails are a form of LLW. Accordingly, deconversion by DOE is retained 

as part of the no-action alternative for this EIS. 

Given that DOE has a backlog of 700,000 metric tons (771,618 tons) of DUF6 (DOE, undated) 

(in approximately 57,000 cylinders) to deconvert, it is expected to take DOE approximately 

25 years to complete its mission (DOE, undated) and have the facility capacity to begin 

deconverting privately generated DUF6. The DOE process does not produce the FEP products, 

and it produces hydrofluoric acid solution rather than the more useful AHF. 

Table 2-4. Comparison of Impacts between Proposed Action and No-Action 

Alternatives 

Affected 

Environment 

Proposed Action 

IIFP would construct, operate, and 

decommission the proposed IIFP 

facility in Lea County, New Mexico. 

No-Action Alternative 

IIFP would perform preconstruction 

activities, but would not construct, 

operate, and decommission the 

proposed IIFP facility. 

Land Use The NRC staff has determined that 

land use impacts resulting from 

construction of the facility and 

restricting the current land use would 

be SMALL due to the abundance of 

other nearby undeveloped land. 

IIFP would obtain the proposed site, 

complete preconstruction of the IIFP 

facility, and institute restrictions on 

grazing and agriculture. The 16-ha 

(40-ac) site would be cleared and 

potentially reseeded. Grazing could 

resume on the entire 259-ha 

(640-ac) site. Impacts would be 

SMALL. 

Historic and 

Cultural 

Resources 

The NRC staff has determined that 

impacts of the construction and 

operations of the facility to historic 

resources or other cultural resources 

would be SMALL. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. The site would be 

cleared and graded. Impacts to 

historic and cultural resources would 

be SMALL. 

Visual 

Resources 

The NRC staff has determined that 

the proposed facility would not affect 

visual resources. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility which would not 

adversely affect visual resources. 

 

1

See Louisiana Energy Services, L.P. (National Enrichment Facility), CLI-04-3, 59 NRC 10, 22 (2004), reprinted in 69 

FR 5873, 5877 (Feb. 6, 2004).
 2-27 

Table 2-4. Comparison of Impacts between Proposed Action and No-Action 

Alternatives (Continued) 

Affected 

Environment 

Proposed Action 

IIFP would construct, operate, and 

decommission the proposed IIFP 

facility in Lea County, New Mexico. 

No-Action Alternative 

IIFP would perform preconstruction 

activities, but would not construct, 

operate, and decommission the 

proposed IIFP facility. 

Climatology, 

Meteorology, 

and Air Quality 

Small amounts of nonradioactive 

emissions and small quantities of

uranium isotopes would be released 

to the atmosphere. The NRC staff 

concludes that impacts to air quality 

during construction and operation of 

the IIFP would be SMALL to 

MODERATE. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Smaller amounts of 

nonradioactive air emissions would 

be released than by the proposed 

action. Impacts would be SMALL. 

Geology, 

Minerals, and 

Soil 

The NRC staff has concluded that 

construction impacts and operation 

of the proposed IIFP facility to 

geology, minerals, seismicity, and 

soil would be SMALL, if proper best 

management practices are instituted 

as mitigation. Note that seismicity 

was a key consideration in IIFP’s site 

evaluation process, and the 

proposed site is not in Seismic Zone 

4 or within 48 km (30 mi) of a 

quaternary active fault. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Impacts would be 

SMALL. 

Water 

Resources 

The NRC staff has concluded that no 

impacts would occur to surface 

waters, and groundwater use 

impacts during construction and 

operations are expected to be 

SMALL. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Additional groundwater 

use may or may not occur, 

depending on future uses of the site. 

Impacts would be SMALL. 

Ecological 

Resources 

The NRC staff has concluded that 

direct and indirect adverse impacts 

to ecological resources during 

construction and operation of the 

proposed facility would be SMALL. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. The 16-ha (40-ac) site 

would be cleared and potentially 

reseeded. Impacts would be 

SMALL. 

Noise The NRC staff has determined that 

the proposed facility would not affect 

ambient noise levels. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility which would not 

adversely affect ambient noise 

levels. 

Traffic and 

Transportation 

The NRC staff has concluded that 

impacts to traffic due to the IIPF 

construction and operation would be 

SMALL on NM 483 and US 62/180. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Impacts would be 

SMALL. 

Public and 

Occupational 

Regulated gaseous effluents would 

be below regulatory limits as 

IIFP would obtain the proposed site 

and complete preconstruction of the 
 2-28 

Table 2-4. Comparison of Impacts between Proposed Action and No-Action 

Alternatives (Continued) 

Affected 

Environment 

Proposed Action 

IIFP would construct, operate, and 

decommission the proposed IIFP 

facility in Lea County, New Mexico. 

No-Action Alternative 

IIFP would perform preconstruction 

activities, but would not construct, 

operate, and decommission the 

proposed IIFP facility. 

Health specified by the New Mexico Air 

Quality Bureau. Radiological 

impacts to off-site receptors from 

routine combined effluent releases 

and direct radiation are anticipated 

to be SMALL. Doses to public 

receptors at other sites of interest 

are also anticipated to be SMALL. 

The radiation exposure of involved 

workers is estimated to be well 

within public health standards and 

impacts would be SMALL. The 

impacts to human health from 

occupational injuries during 

operation would be SMALL. 

IIFP facility. Impacts would be 

SMALL. 

Waste 

Management 

Waste DUO2 and LLW materials 

would be disposed of at a licensed 

LLW disposal facility. There would 

be no onsite disposal of any solid 

waste at the IIFP facility. Hazardous 

wastes would be shipped to a 

Resource Conservation and 

Recovery Act (RCRA) disposal 

facility. The quantity of construction 

and operations hazardous and 

nonhazardous waste material would 

result in SMALL impacts that could 

be managed effectively. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Impacts would be 

SMALL. 

Socioeconomics 

and 

Environmental 

Justice 

The NRC staff has determined that 

impacts of the IIFP facility on tax 

revenues, housing, and community 

services for the two-county Region 

of Interest (ROI), consisting of Lea 

and Eddy Counties, where most inmigrating construction and 

operations workers are likely to live, 

and where the majority of economic 

impacts 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Impacts would be 

SMALL. 

Socioeconomics 

and 

Environmental 

Justice 

(Continued) 

would occur would be SMALL and 

positive; and where not positive, 

would still be SMALL. 

Decommissioning would provide 

short-term employment, and 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Impacts would be 

SMALL. 
 2-29 

Table 2-4. Comparison of Impacts between Proposed Action and No-Action 

Alternatives (Continued) 

Affected 

Environment 

Proposed Action 

IIFP would construct, operate, and 

decommission the proposed IIFP 

facility in Lea County, New Mexico. 

No-Action Alternative 

IIFP would perform preconstruction 

activities, but would not construct, 

operate, and decommission the 

proposed IIFP facility. 

depending upon the option chosen, 

the facility could be used for other 

industry and/or the site for 

agriculture. 

All resource impacts are SMALL and 

the identified minority and lowincome populations are not in close 

proximity to the proposed site, so 

impacts would not be considered 

disproportionately high and adverse 

for any populations in the region, 

including minority or low-income 

populations. 

Accidents NRC regulations and IIFP’s 

operating procedures for the 

proposed facility would ensure that 

the high and intermediate probability 

accident scenarios would be 

unlikely. Items which mitigate or 

prevent emergency conditions, and 

the implementation of emergency 

procedures and protective actions in 

accordance with the facility 

emergency plan, would limit the 

consequences and reduce the 

likelihood of accidents that could 

otherwise extend beyond the 

proposed facility site and property 

boundaries. IIFP would be required 

by NRC and DOT regulations to 

package and manage the 

transported waste to minimize the 

probability of accidental release of 

radioactive material. IIFP facility 

design, passive and active 

engineered controls, and 

administrative controls would reduce 

the likelihood of accidents. 

Therefore, the NRC staff has 

concluded that accident impacts 

would be SMALL. 

IIFP would obtain the proposed site 

and complete preconstruction of the 

IIFP facility. Impacts would be 

SMALL. 
 2-30 

2.2.2 Alternatives Considered But Eliminated 

2.2.2.1 Alternative Sites 

IIFP conducted a site selection process (IIFP, 2009) to determine a suitable location for the 

proposed facility. The NRC staff reviewed the IIFP process to determine whether an obviously 

superior site was identified. This section discusses IIFP’s site-selection process, identifies the 

candidate sites for the proposed FEP/DUP facility, and discusses NRC staff’s review of the 

process, screening criteria, and results used by IIFP for selecting the preferred site. 

The IIFP site selection process involved (1) a solicitation of community interest to find potential 

sites; (2) coarse screening to identify the viable sites among those suggested; (3) fine screening 

to further narrow to the candidate sites based on the criteria listed in Table 2-5; and (4) final site 

selection based on quantitative criteria. 

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

Evaluation Criteria 

Project 

Objective 

Impact 

Value 

Local community residents must accept and support facility siting Required Pass/Fail 

Local and state governments must support Regulatory Activities Required Pass/Fail 

Site cannot be in Seismic Zone 4 Required Pass/Fail 

Site cannot be within 50 km of a quaternary active fault Required Pass/Fail 

Presence of nearby activities or structures that could be exposed to a hazard 

by the facility (NUREG-1513) Regulatory 0.8 

Presence of nearby activities or structures that could pose a hazard to the 

facility (NUREG-1513) Regulatory 0.8 

Commitment of natural resources for site offered including the destruction or 

diminution of wildlife habitats, flora, woodlands, and marshlands Regulatory 0.8 

Presence of endangered or threatened species, or critical habitat in 

Endangered Species Act 

Regulatory 0.8 

Environmental Justice Requirements (minority and low-income populations: 

multiple effects to be considered) 

Regulatory 0.8 

Will action cause a violation of Federal, State, local, tribal laws or 

requirements for protection of environment (Air Quality, Water Quality, other) Regulatory 0.8 

Location of adjacent hazards or hazardous operations leading to cumulative 

impacts Regulatory 0.8 

State and local government financial incentives Cost 0.4 

Property tax incentive Cost 0.8 

State Income taxes Cost 0.8 

State Sales and use taxes Cost 0.8 

Transportation routes (impacts) for incoming feed material, considering 

distances & routes Cost 0.8 

Transportation cost to uranium oxide waste disposal site Cost 0.8 

Transportation cost to primary anhydrous HF buyers Cost 0.8 

Schedule time required to license and construct Schedule 0.4 
 2-31 

Table 2-5. IIFP’s Evaluation Criteria for Fine Screening (Continued)

Evaluation Criteria 

Project 

Objective 

Impact 

Value 

Existence of chemical or radiological contamination Regulatory 0.4 

Adequate water supply and cost Cost 0.4 

Presence of special interest groups (interveners) Regulatory 0.4 

Acreage Offered (min 640-acres) and cost Cost 0.4 

Waste types generated during construction, operation and demolition, 

RCRA, etc. Regulatory 0.4 

Cost of construction and operation Cost 0.4 

Electrical supply and cost Cost 0.4 

Gas supply and cost Cost 0.4 

Impact on water quality or water supply (reduction) Regulatory 0.4 

Site characteristics: Geology, topography, seismic Regulatory 0.2 

Decommissioning Requirements Regulatory 0.2 

Site characteristics: depth to frost line Regulatory 0.2 

Infrastructure incentive Cost 0.2 

Contaminants Regulatory 0.2 

Training, accessibility, availability of emergency response personnel / 

facilities Regulatory 0.2 

Existing environmental data Regulatory 0.2 

Ambient noise levels Regulatory 0.1 

Site characteristics: climatology and meteorology Regulatory 0.1 

Sanitary wastewater treatment availability Cost 0.1 

Availability of road, rail, and airport Cost 0.1 

Buildings offered and terms Cost 0.1 

Condition of land Cost 0.05 

Unemployment insurance tax Cost 0.05 

Source: IIFP, 2009 

Potential environmental impacts can be avoided or significantly reduced through proper site 

selection. IFFP used an approach to select a preferred site based on technical, environmental, 

safety, and economic considerations (IIFP, 2009). The NRC staff reviewed the site selection 

process used by IIFP and determined that the process is comprehensive because it takes into 

account all applicable criteria, structured because it follows from coarse to more fine screening 

process, and appropriate for identifying and evaluating the proposed site and alternative 

candidates. 

2.2.2.1.1 Solicitation of Interest 

IIFP determined that desirable locations for the plant would be proximate to existing, private, 

DUF6 sources and near LLW disposal facilities that could accept DUO2 for disposal. This 

resulted in IIFP soliciting site proposals from communities in the states of Texas, Idaho, and 

New Mexico (IIFP, 2011b). The IIFP inquiry package requested information about the 
 2-32 

community and any interest or proposal for attracting and accepting a DUF6 deconversion 

facility. As a result, six potential sites were identified: one in Texas, two in Idaho, and three in 

New Mexico. 

2.2.2.1.2 First-Phase Screening 

IIFP used the following criteria to evaluate the six potential sites: 

• acceptance of the proposed facility by community 

• acceptance of the proposed facility by state and local governments 

• appropriate seismic qualifications (not to be in seismic zone 4) 

• no environmental legacy potential liabilities 

• location in proximity to customers and waste disposal sites 

• availability of utilities infrastructure 

The NRC staff reviewed the IIFP’s first-phase screening process, elimination criteria, and results 

and determined that they are reasonable and appropriate because the elimination criteria 

consists of considerations relevant to the evaluation of potential impacts to environmental 

resource areas discussed in this EIS. Further, the NRC staff agrees that these elimination 

criteria allow IIFP to exclude from further consideration certain sites due to their potential 

environmental impacts. 

Sites were excluded from further consideration based on the outcomes of these screening 

criteria when applied to each potential site: two of the six potential sites were eliminated from 

consideration. One New Mexico site was eliminated because it was distant from utilities and 

population centers, and it had no characterization data. One of the Idaho sites was eliminated 

because it was located on a previous radioactive materials processing site and, thus, had 

legacy issues that IIFP chose to avoid. As a result, one Texas site, one Idaho site, and two 

New Mexico sites moved on to IFFP’s fine screening. The NRC staff agreed it was appropriate 

to eliminate the two sites, based on the first-phase screening criteria. 

2.2.2.1.3 Second-Phase Screening 

The second-phase screening occurred in two rounds in which IIFP evaluated the remaining four 

sites using used various categories of evaluation criteria. The first round evaluated the four 

sites on qualitative site-specific criteria and quantitative cost-benefit criteria. The qualitative 

criteria included public and state support, seismic characteristics, land/soil issues, land/mineral 

rights, aesthetics, and licensing and permits. The cost-benefit criteria included incentives, 

infrastructure cost, operating costs, state and local taxes, and transportation costs. 

During this screening, two sites (one in New Mexico and one in Idaho) were eliminated because 

of site-specific features and excessive land and/or infrastructure costs. Subsequently, the 

communities that had offered the eliminated sites were asked to nominate a second 

(replacement) site, resulting in a second iteration of first-phase screening. The New Mexico 

replacement site was rejected in a reiteration of first-phase screening because of numerous oil 

wells on the site and the complexity of acquiring the land. The Idaho replacement site survived 
 2-33 

this screening (IIFP, 2011b). This left three sites to undergo the second round of IIFP’s 

second-phase screening: one in Texas, one in Idaho, and one in New Mexico (the Hobbs site). 

Table 2-5 identifies the screening criteria used by IIFP in their siting selection process and the 

criterion’s relative importance. 

The NRC staff reviewed the IIFP’s second-phase screening process and determined that it is 

reasonable and appropriate as it consists of criteria allowing the applicant to consider potential 

environmental impacts as a result of the site selection process. Further, appropriate 

consideration was given to seismic potential, threatened and endangered species and critical 

habitat, economic considerations, emergency preparedness and response, air quality, 

climatology and meteorology, water quality and water supply, waste management, acreage, 

noise, nearby hazards or hazardous operations, and environmental justice. The NRC staff finds 

that consideration of these criteria is appropriate and comprehensive because it takes into 

consideration environmental resources such as wildlife habitats, potential for exposure to 

hazards to the facility, proximity to quaternary active faults, and applicable Federal State, local, 

and Tribal laws for protecting the environment. The application of the criteria allow for the 

identification and selection of a site that would be expected to result in reduced potential 

environmental impacts. 

2.2.2.1.4 Final Site Selection 

In the final site selection, the sites were evaluated by IIFP using the criteria listed in Table 2-5, 

assigning an impact value and an evaluation value to each criterion in Table 2-5 (IIFP, 2009). 

For each potential site the impact value of each criterion listed in Table 2-5 was multiplied by an 

evaluation number assigned for each potential site. The evaluation number for each criterion 

ranged from 1 for most favorable to 10 for least favorable potential site. The summation of the 

product of these multiplications produced the total score for each site. The lower the evaluation 

score, the more favorable the site. The Hobbs, New Mexico, site was ultimately selected 

because it has the lowest (best) score. 

IIFP determined that the Hobbs site offers overall the most beneficial combination of technical, 

safety, economic, and environmental factors (IIFP, 2009). IIFP selected the Hobbs, New 

Mexico, site for the proposed facility in part because it is not near an active fault, there is no 

legacy chemical or radiological contamination, there are no air quality non-attainment areas in 

the vicinity, the site is sparsely populated, the availability of water, electricity and natural gas, 

and public and state, and local support. Consideration was also given to threatened and 

endangered species, critical habitats, and historic and cultural properties. 

The NRC staff reviewed the IIFP process and determined that the process used by IIFP is 

reasonable and appropriate because the list of criteria is comprehensive and considers 

elements relevant to the evaluation of potential environmental impacts. It also includes 

regulatory requirements, and considers costs, scheduling impacts, and community support. The 

results concluding that the Hobbs site offers overall the most beneficial combination of 

environmental, technical, safety, and economic factors are reasonable. The NRC staff further 

concludes that none of the candidate sites is obviously superior to the IIFP preferred site. 
 2-34 

2.2.2.2 Alternative Technologies 

2.2.2.2.1 Direct Deconversion (IIFP Facility Phase 2) 

In Section 2.1.2, a direct conversion process is mentioned as a possible, future Phase 2 

licensing action. This technology is very similar to that of the proposed action, but it does not 

yield the marketable FEP products, SiF4 and BF3. In direct conversion, all the fluorides in the 

DUF6 would be converted to AHF. As an alternative, IIFP could seek a license for the Phase 2 

process without obtaining a license for Phase 1. The process, which directly converts DUF6 to 

uranium oxide, mainly as U3O8, is described in more detail below. 

In the direct conversion to oxide process, the DUF6 feed would be vaporized in the same type of 

autoclave as in the proposed DUF6 to DUF4 process. The DUF6 vapor would be fed to a 

first-stage reaction vessel where it would react with a feed of a vaporized mixture of HF and 

steam that has been recycled from the back end (distillation system) of the process. The 

reaction results in the formation of uranyl oxyfluoride (UO2F2) and HF. 

The UO2F2 powder would be withdrawn from the bottom of the reaction vessel and sent to a 

second-stage reaction vessel where it would undergo a reaction with steam to form U3O8 and 

HF. A more concentrated HF vapor mixture and water would exit the tops of the first and 

second stage reaction vessels and be condensed using heat exchanger equipment. The 

condensed and concentrated HF would then be distilled to produce commercial grade AHF. 

The resulting distillation bottom material of less concentrated HF would be recycled, vaporized, 

and returned as feed to the first-stage reaction vessel. 

U3O8 formed in the second-stage reaction vessel would be transferred to storage hoppers. A 

two-stage dust collector system would control and recycle U3O8 dust generated by air or gas 

flows associated with the solids handling equipment. The U3O8 in the storage hoppers would be 

packaged into DOT-approved shipping containers and transported to an off-site, licensed LLW 

disposal facility. 

The potential environmental impacts of the proposed action and the alternative technology of 

direct conversion would be nearly the same, because the throughput of DUF6 would be the 

same, both processes produce large volumes of AHF (the alternative technology somewhat 

larger), both produce the same quantity of chemically stabilized uranium (although in slightly 

different chemical forms), and the basic chemical processes are very similar. Because (1) direct 

conversion is analyzed as a cumulative impact in this EIS and (2) there is so little difference in 

the expected environmental impacts between the proposed action and the direct conversion 

alternative, this alternative is eliminated from consideration in this EIS as a separate alternative. 

2.2.2.2.2 DOE Deconversion Technology 

DOE has constructed two deconversion facilities, one at the site of the former Paducah 

Gaseous Diffusion Plant in Paducah, Kentucky and the other at the site of the former 

Portsmouth Gaseous Diffusion Plant near Piketon, Ohio. These plants were constructed to 

deconvert the approximately 700,000 metric tons (771,618 tons) of DUF6 stored at the Paducah 

plant, the Portsmouth plant, and the East Tennessee Technology Park (formerly the K-25 

Gaseous Diffusion Plant) at the Oak Ridge Reservation, Tennessee. Shipment of full DUF6

cylinders to these plants is allowed as described in Section 2.2.1 (the no-action alternative). 
 2-35 

As an alternative technology to the technology proposed in this EIS, IIFP could construct a plant 

that uses the technology of the DOE plants. The DOE deconversion process reacts DUF6 with 

water (steam) and hydrogen to produce U3O8 and aqueous HF. The DUF6 is directly converted 

to U3O8 in a one-stage reaction vessel. HF and water vapor exit the reaction vessel and are 

collected as aqueous HF. The U3O8 solids exit the reaction vessel, and are stored temporarily 

until they are shipped to a waste disposal site. DOE plans to market the aqueous HF, but any 

HF that is not sold may have to be treated as a waste liquid. This liquid waste would likely be 

reacted with lime to form CaF2 and stored in retention basins or sold. (DOE, 2004a; DOE, 

2004b). Assuming the CaF2 can be sold, it could be used to produce AHF at an industrial AHF 

production plant. 

This alternative is eliminated from consideration in this EIS because: 

• The DOE process has already been analyzed in two DOE-prepared NEPA documents 

(DOE, 2004a; DOE, 2004b), and the impacts of implementing the DOE technology 

would be sufficiently similar to the proposed action. For this reason no value would be 

gained by further analyzing this technology as an alternative to the proposed action. 

The throughput of DUF6 would be the same, both processes would produce the same 

quantity of chemically stabilized depleted uranium (although in slightly different chemical 

forms), and the basic chemical processes are very similar. 

• The DOE alternative has greater uncertainty regarding the disposition of the aqueous 

HF, and could result in higher environmental consequences should the conversion of HF 

to CaF2 and then AHF, be required. 

2.2.2.2.3 European Deconversion Technology 

Three processes can convert DUF6 to uranium oxide; the IIFP process, the DOE process, and 

the European process. The European process involves reacting DUF6 directly with steam in a 

first-stage reaction vessel, producing aqueous HF and depleted uranyl dioxyfluoride (DUO2F2). 

The DUO2F2 is processed further in a second-stage reaction vessel to form aqueous HF and 

depleted uranium oxide for disposal. The HF is collected in an aqueous form that can be sold or 

treated (IIFP, 2009). 

As with the DOE technology, this alternative is eliminated for the following reasons: 

• The impacts of implementing the European technology would be sufficiently similar to 

the proposed action such that no value would be gained by further analyzing this 

technology as an alternative to the proposed action. The throughput of DUF6 would be 

the same, both processes would produce the same quantity of chemically stabilized 

uranium (although in slightly different chemical forms), and the basic chemical processes 

are very similar (IIFP, 2009). 

• The European alternative has greater uncertainty regarding the disposition of the 

aqueous HF, and could result in higher environmental consequences should the 

conversion of HF to CaF2 and then AHF, be required. 

2.2.2.3 Overseas Shipment of DUF6 for Deconversion 

URENCO and AREVA are foreign companies that operate or are planning to operate 

enrichment plants in the U.S. These firms own and operate deconversion facilities overseas 

and could choose to ship their U.S.-generated DUF6 to those facilities for deconversion. Also, 
 2-36 

Russia has recently commissioned a deconversion facility and is planning another. Under this 

alternative, any of the four U.S.-based commercial enrichment companies could ship their DUF6

overseas for deconversion. However, this would involve shipping DUF6 long distances 

overseas and the uranium oxides would have to be shipped back to United States for licensed 

disposal (IIFP, 2009). The cost of such shipments would likely be significant. 

In its EIS for the National Enrichment Facility (now URENCO USA), the NRC staff (NRC, 2005b) 

examined three foreign disposition alternatives for DUF6: Russian re-enrichment, French 

deconversion or re-enrichment, and Kazakhstan deconversion. The NRC staff concluded, “Due 

to the costs for disposition in Russia, France, or Kazakhstan, the NRC staff does not consider 

these alternatives to be viable” (NRC, 2005b). 

For reasons discussed above, the NRC staff concludes that overseas shipment of DUF6 for 

deconversion is not a reasonable alternative. Thus, this alternative has been eliminated from 

further analysis. 

2.2.2.4 Indefinite Storage of DUF6

Commercial enrichment facilities in the U.S. could store their DUF6 at their enrichment facilities, 

much like DOE has done for decades. As described in Section 2.2.1, No-Action Alternative, the 

DOE deconversion facilities could eventually (approximately 25 years in the future) take this 

DUF6, making this alternative evolve over time to the no-action alternative. 

The DNFSB has reported that long-term storage of DUF6 represents a potential chemical 

hazard (DNFSB, 1995). DOE policy (DOE, 2000) is that alternatives for the long-term 

management of DUF6 include its deconversion to a more stable uranium oxide. DOE evaluated 

long-term storage in its Programmatic EIS on DUF6 management (DOE, 1999), but did not 

select the long-term storage option (64 FR 43358). 

In addition to creating a potential chemical hazard, the alternative of indefinite storage of DUF6

does not meet the need to deconvert this material (as discussed in Section 1.3) and has 

therefore been eliminated from consideration in this EIS. 

2.2.2.5 Commercial Enrichment Plant Deconversion of DUF6 at Uranium 

Enrichment Facilities 

The four U.S.-based enrichment companies could decide to construct and operate their own 

deconversion facilities. The only operational commercial enrichment facility in the U.S., the 

URENCO USA plant near Eunice, New Mexico, has already signed an agreement with IIFP for 

IIFP to accept URENCO’s DUF6. Furthermore, it is expected that the potential environmental 

impacts of implementing this alternative at each enrichment facility would be similar to that for 

the proposed action. However in this event these impacts would occur at up to four locations as 

a result of the construction of four deconversion facilities rather than just one as would be the 

case for the proposed action. One deconversion facility for each U.S.-based enrichment 

company would have greater environmental impacts than the construction of one facility to 

support all the enrichment facilities, which is the proposed action. Thus, the NRC staff has 

concluded that this alternative offers no meaningful advantages over the proposed action, and 

therefore does not warrant further consideration in this EIS. 
 2-37 

2.3 Comparison of Predicted Environmental Impacts 

Chapter 4 of this EIS presents a detailed evaluation of the potential environmental impacts of 

the proposed action and the no-action alternative. Table 2-4summarizes and compares these 

environmental impacts. A common element between the two alternatives is the occurrence of 

preconstruction activities. It is assumed that preconstruction activities take place under both 

alternatives and, therefore, the impacts associated with preconstruction activities would occur 

regardless of which alternative is selected. As a result, the comparison of alternatives 

presented in Table 2-4 is intended primarily to highlight the differences between the two 

alternatives after preconstruction activities have occurred. A standard of significance has been 

established for assessing potential environmental impacts. In its implementation of the Council 

on Environmental Quality’s regulations on significance (40 CFR 1508.27), NRC staff has 

assigned each impact one of the following three significance levels, as defined in NRC (2003): 

• 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. 

These impact levels are used in the summary and comparison of alternatives in Table 2-4. 

2.4 Staff Recommendation Regarding the Proposed Action 

After weighing the impacts of the proposed action in Chapter 4 and comparing the impacts of 

the proposed action and the no-action alternative in Table 2-4, the NRC staff, in accordance 

with 10 CFR 51.91(d), sets forth its NEPA recommendation regarding the proposed action. 

The NRC staff recommends that, unless safety issues mandate otherwise, the proposed license 

be issued to IIFP. The NRC staff has concluded that potential environmental impacts are in all 

aspects SMALL or MODERATE, and application of the environmental monitoring program 

described in Chapter 6 and the proposed IIFP mitigation measures discussed in Chapter 5 

would eliminate or substantially lessen any potential adverse environmental impacts associated 

with the proposed action. 

The conclusion of the NRC staff is that the overall benefits of the proposed IIFP Facility 

outweigh the environmental disadvantages and costs based on consideration of the following: 

• The need for a facility to deconvert the domestic stockpile of DUF6 into more stable 

depleted uranium oxides; and 

• The potential environmental impacts from the proposed action are in most aspects 

SMALL with the exception of short term construction related air quality impacts and in 

some cases, beneficial. 

2.5 References 

(DNFSB, 1995) U.S. Defense Nuclear Facilities Safety Board. 1995. Integrity of Uranium 

Hexafluoride Cylinders. Technical Report DNFSB/TECH-4. May 5, 1995. 
 2-38 

(DOE, undated) U.S. Department of Energy. Undated. Transporting DOE Uranium Oxide from 

Portsmouth Ohio, and Paducah Kentucky. Portsmouth/Paducah Project Office, Lexington, KY. 

ADAMS Accession No. ML110120583. 

(DOE, 1999) U.S. Department of Energy. 1999. Final Programmatic Environmental Impact 

Statement for Alternative Strategies for the Long-term Management and Use of Depleted 

Uranium Hexafluoride, DOE/EIA-0269. Office of Nuclear Energy, Science and Technology, 

Washington D.C. April 1999. ADAMS Accession No. ML050180302. 

(DOE, 2000) U.S. Department of Energy. 2000. Assessment of Preferred Depleted Uranium 

Disposal Forms. ORNL/TM-2000/161, Oak Ridge, TN. June 2000. ADAMS Accession 

No. ML060110351. 

(DOE, 2004a) U.S Department of Energy. 2004. Final Environmental Impact Statement for 

Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the 

Paducah, Kentucky Site, DOE/EIS-0359, Washington, D.C., June 2004. ADAMS Accession 

No. ML050380331. 

(DOE, 2004b) U.S. Department of Energy. 2004. Final Environmental Impact Statement for 

Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the 

Portsmouth, Ohio Site, DOE/EIS-0360, Washington, D.C., June 2004. ADAMS Accession 

No. ML051030392. 

(IIFP, 2009) International Isotopes Fluorine Products. 2009. Fluorine Extraction Process and 

Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A, 

ER-IFP-001, Revision A. December 27, 2009. ADAMS Accession No. ML100120758. 

(IIFP, 2011a) International Isotopes Fluorine Products, Inc. 2011. Fluorine Extraction Process 

and Depleted Uranium De-conversion Plant (FEP/DUP) Official Responses to Environmental 

Report RAIs, Revision A. March 31, 2011. ADAMS Accession No. ML110970481. 

(IIFP, 2011b) International Isotopes Fluorine Products, Inc. 2011. “Site Selection Information 

for International Isotopes Fluorine Products, Incorporated (IIFP) Fluorine Extraction and 

Depleted Uranium Deconversion Facility near Hobbs in Lea County, New Mexico,” E-mail, 

September 22, 2011. ADAMS Accession No. ML11265A322. 

(NRC, 2003) U.S. Nuclear Regulatory Commission. 2003. Environmental Review Guidance for 

Licensing Actions Associated with NMSS Programs. Final Report. NUREG 1748, Division of 

Waste Management, Washington, D.C. August 2003. ADAMS Accession No. ML032450279. 

(NRC, 2005a) U.S. Nuclear Regulatory Commission. 2005. In the matter of Louisiana Energy 

Services, L.P. (National Enrichment Facility), CLI-05-05, Memorandum and Order. Docket 

No. 70-3103-ML. January 18, 2005. ADAMS Accession No. ML050180295. 

(NRC, 2005b) U.S. Nuclear Regulatory Commission. 2005. Environmental Impact Statement 

for the Proposed National Enrichment Facility in Lea County, New Mexico, NUREG-1790, 

Vol. 1. Washington, D.C. June 2005. Available at http://www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr1790/vl/. ADAMS Accession No. ML051730238. 
 3-1 

3.0 AFFECTED ENVIRONMENT 

This chapter describes the existing regional and local environmental conditions at and near the 

proposed IIFP site before any preconstruction activities begin and prior to the proposed action. 

This chapter presents information on land use; historic and cultural resources; visual resources; 

climatology, meteorology, and air quality; geology, minerals and soils; water resources; 

ecological resources; socioeconomic resources; traffic and transportation; noise; and public and 

occupational health. The data and information presented here provide a baseline against which 

to assess impacts (Chapter 4) of the proposed action described in Chapter 2 of this EIS. 

3.1 Site Location 

The proposed IIFP site would occupy Section 27, in Township 18S, Range 36E of southeastern 

New Mexico, in Lea County. The 259-ha (640-ac) site is approximately 22.5 kilometers (km) 

(14 miles [mi]) west of Hobbs, New Mexico, 27.4 km (17 mi) west of the Texas/New Mexico 

border, and 362 km (225 mi) southeast of Albuquerque, New Mexico. The nearest population 

center is Hobbs, New Mexico, which had an estimated population of 30,838 in 2009 (USCB, 

2010a). The nearest important permanent surface water is the Pecos River, approximately 146 

km (91 mi) west of the site. The southern boundary of Section 27 is 1.6 km (1 mi) north of U.S. 

Highway 62/180 (US 62/180) and the western boundary is NM 483. Figures 3-1 and 3-2 depict 

the 80-km (50-mi) and 10-km (6-mi) radii surrounding the site, respectively, and are referred to 

in subsequent analyses. 

IIFP has set aside approximately 16 ha (40 ac) in the northeast quadrant of the proposed site 

for the deconversion facility (see Figure 2-2). The remainder of Section 27 would remain as 

undeveloped (IIFP, 2009). The facility’s location was selected to avoid, to the extent possible, 

utility rights-of-way including overhead transmission lines and underground pipelines. The 

facility would be enclosed by a security fence with a surveillance road just inside the fence. See 

Section 2.1.3 for a list of the structures at the facility. 

3.2 Land Use 

This section includes a description of land use on and near the proposed IIFP site, including a 

description of offsite areas and the regional setting. For the purposes of this EIS, the Region of 

Influence (ROI) for land use is defined as the area within a 10-km (6-mi) radius of the center 

point of the proposed IIFP site (see Figure 3-2 for site location and nearby features within the 

ROI). 

The proposed IIFP site is in Section 27, in Township 18S, Range 36E of southeastern New 

Mexico, in Lea County, approximately 22.5 km (14 mi) west of Hobbs, New Mexico. Property 

ownership in the county (which is approximately 1.1 million ha [2.8 million ac] in size) is 

17 percent Federal ownership, 31 percent State ownership, and 52 percent private ownership. 

The Federally owned land is primarily in the southwestern portion of the county, the Stateowned land is located throughout the central portion of the county, and the privately owned land 

primarily extends from north to south in the county’s eastern portion. Large tracts of land in Lea 

County are privately owned by farmers, ranchers, and oil, gas, and mining companies. 

Urbanized areas near cities and towns include smaller tracts used for residential, municipal, and 

commercial purposes. Approximately 93 percent of Lea County is used as range land for 

grazing and approximately 4 percent is used for crop farming. Urban areas and the roadway 
 3-2 

 
 3-3 

 
 3-4 

system account for the county’s remaining land use. Most of the land actively farmed in Lea 

County is irrigated (Leedshill-Herkenhoff et al., 2000). 

The public roadways closest to the proposed IIFP site are US 62/180 running east-west and 

NM 483 running north-south (Figure 3-2). These roadways mostly traverse open range land in 

the ROI. 

The proposed 259-ha (640-ac) IIFP site and the surrounding ROI are largely undeveloped. The 

land has been used for cattle grazing and for gas and oil development (IIFP, 2009). There are 

715 oil or gas wells within the 10-km (6-mi) ROI. Seven of these wells, all of which have been 

abandoned, are within 1.6 km (1.0 mi) of the site (Oil and gas wells are discussed in more detail 

in Section 3.6.3). Both overhead and underground utilities, and their associated rights-of-way, 

cross the site and the ROI. Several overhead transmission lines and underground gas/oil 

pipelines run generally east to west across the proposed IIFP site. Xcel Energy’s Cunningham 

Station, just west of Section 27, has four groundwater monitoring wells in Section 27 (see 

Figures 3-2 and 3-14). Three other energy production facilities are within 10 km (6 mi) of the 

proposed facility: the Colorado Energy Station (also known as the Hobbs Generating Station) is 

2.4 km (1.5 mi) northeast of the proposed IIFP site; the Xcel Energy Maddox Generating Station 

is 3.7 km (2.3 mi) east-southeast of the proposed site; and the DCP Midstream Linam Ranch 

Plant is 5 km (3.1 mi) southeast of the proposed site (Figure 3-2). 

The nearest residence is west-northwest of the site approximately 2.6 km (1.6 mi) from the 

northern boundary of the site (Figure 3-2). There are no public recreational areas or National 

Register of Historic Places (NRHP)-listed historic structures or properties within 10 km (6 mi) of 

the proposed facility. 

Other than the proposed IIFP facility (Phase 1 and Phase 2), there are no current developments 

or proposed developments in the ROI. The proposed IIFP site is not subject to local or county 

zoning, land use planning, or associated review process requirements; and there are no 

potential conflicts of land use plans, policies, or controls (Appendix A). 

The State of New Mexico and Lea County have transferred ownership of the proposed 259-ha 

(640-ac) site from the State and Lea County to IIFP. The transfer to IIFP was part of an 

economic incentives package developed by the Economic Development Corporation of Lea 

County. The land transfer was carried out in accordance with the New Mexico Economic 

Development Act. 

See Section 3.6.4 for a discussion of farmland protection programs in New Mexico. 

3.3 Historic and Cultural Resources 

This section includes a description of the potential and documented human habitation on and 

near the proposed IIFP site, and a discussion of significant offsite historic resources and the 

regional setting. The ROIs for historic and cultural resources are explained later in this section, 

corresponding to Areas of Potential Effect (APEs), which vary for different resources that could 

be directly or indirectly affected. 

Southeastern New Mexico was settled by humans approximately 12,000 years ago. The 

cultural sequence in the region includes six chronological periods: the Paleo-Indian period 

(10,000 B.C. to 7,000 B.C.), the Archaic period (5,000 B.C. to A.D. 1000), the Formative period 

(A.D. 900 to 1500), the Protohistoric/Spanish Colonial period (1541 to 1800), the Mexican 
 3-5 

period (1828 to 1834), the Territorial period (1834 to 1912), and the Statehood period (1912 to 

present) (NMHPD, 2001). 

While archeological sites documenting occupation during all of these periods have been 

identified in southeastern New Mexico, the proposed project site on the Llano Estacado is part 

of a flat, arid plain without permanent or even intermittent water sources. While the PaleoIndians used the Llano Estacado for hunting when the climate was less arid (prior to 6000 B.C.), 

it was not hospitable to more extensive human occupation (Rothman and Holder, 1998). 

Archaeological resource records indicate prehistoric, protohistoric, and historic human 

occupation in areas of southeastern New Mexico within the Llano Estacado only in areas with 

reliable potable water, shelter, and food. Therefore, because there is no permanent water 

source near the site (see Section 3.7.2), the potential for archeological resources is low at the 

IIFP site and any prehistoric, protohistoric, or historic activity would have been transient. Only 

isolated artifacts have been found in the vicinity of the proposed IIFP site (Daras, 2009). 

3.3.1 Prehistoric Occupation 

The initial prehistoric period in New Mexico, the Paleo-Indian period, is characterized by kill 

sites, camp sites, butchering sites, and lithic quarries associated with small, nomadic groups 

subsisting by the hunting of now-extinct large game animals such as mammoths and large 

bison. The Paleo-Indian period is better represented in the southeastern quadrant of the State 

than in any other area of New Mexico (Main, 1992). Several Paleo-Indian hunting sites have 

been found on the Llano Estacado, although none have been found in the vicinity of the 

proposed IIFP site (Daras, 2009). During the Archaic period, people became more sedentary 

as a society, settling in small bands along major watercourses in response to drier conditions. 

The vicinity of the proposed IIFP site, far from permanent watercourses, would have been 

unattractive for hunting, gathering, or settlement (Rothman and Holder, 1998). During the 

Formative (or Ceramic) period tribal groups became increasingly settled and concentrated 

within villages and base campsites. Formative period sites also were generally located near 

permanent sources of water, and the proposed site’s setting within the Llano Estacado - far from 

watercourses - remained unsuitable for increasingly sedentary and growing populations 

(Rothman and Holder, 1998). Therefore, the proposed IIFP site is not expected to yield 

significant Formative period archaeological resources. 

3.3.2 Historic Indian Tribes 

By the early 1540s, when Spanish explorer Vasquez de Coronado arrived in New Mexico, the 

southeastern quadrant of the State was dominated by small hunter-gatherer groups and small 

settlements along river valleys such as the Pecos (Rothman and Holder, 1998). The groups 

occupying the region included the Suma, the Tigua, and the Jumano (Gerald, 1974; Kelley, 

1986; Hickerson, 1994). In the nineteenth century, these groups were replaced by Apache and 

Plains Indians, including the Kiowa and Comanche (Hickerson, 1994). Tribal testimony before 

the U.S. Indian Claims Commission indicates that the proposed IIFP site lies west of a large 

area used and/or or occupied by the Plains Apache, Comanche, and Kiowa; and east of a large 

area used by the Mescalero Apache (ICC, 1979). However, the proposed IIFP site was not 

known to be occupied, or known to have been used, other than for hunting, by tribes who 

occupied lands to the east (Plains Apache, Comanche, and Kiowa) and west (Mescalero 

Apache). 

Today, the Mescalero Apache Reservation is approximately 190 km (118 mi) west of the 

proposed site, in northeast Otero County, New Mexico. The Kiowa, Plains Apache, and 
 3-6 

Comanche reservations are in south central Oklahoma, approximately 570 km (354 mi) to the 

northeast. A remnant group of the Tigua (Ysleta del Sur Pueblo) has traditional-use areas, 

where activities such as hunting and gathering have traditionally occurred, in the general project 

area, which includes large areas appropriate for traditional cultural uses throughout the region. 

Therefore, the land containing the proposed IIFP site is not unique in providing traditional 

cultural use opportunities for Native Americans. 

3.3.3 Historic Euro-American Exploration and Settlement 

Historic Euro-American interests in the region began with Spanish exploration in the mid- to 

late-sixteenth century during the Protohistoric/Spanish Colonial Period. There is no indication 

that any of the Spanish expeditions during the sixteenth and seventeenth centuries ventured 

near the vicinity of the proposed project site, with almost all activity confined to the river valleys 

of the Rio Grande and Pecos River (Rothman and Holder, 1998). The Llano Estacado region 

was one of the last areas of New Mexico to be settled by Euro-Americans, because of the lack 

of surface water and semiarid climate. No settlement or significant activities took place in the 

vicinity of the proposed site during the Mexican Period. In the 1810s and 1820s, sheep 

ranchers, formerly concentrated west of and along the Rio Grande River, began to move into 

the eastern plains and the Pecos Valley (Merlan, 2010), but would not likely have ventured into 

the dry Llano Estacado region in the vicinity of the proposed site, and no archeological 

resources from this period were found in the vicinity of the proposed IIFP site. 

During the Territorial Period, some Texas cattle ranchers drove their herds through 

southeastern New Mexico along the Goodnight-Loving Trail, which followed the Pecos River 

approximately 80 km (50 mi) west of the proposed site (Clampitt, 2008). Euro-American 

settlement in the area began in the late nineteenth and early twentieth centuries during the 

Territorial period, prior to New Mexico achieving statehood in 1912. After the American Civil 

War, homesteaders established ranches at Monument Springs, near Monument, New Mexico 

(Anderson, Undated). 

The Hat Ranch, established in 1890 and variously known as “Monument Springs” and the 

“Monument Springs Ranch,” was the largest ranch in the area. It operated on more than one 

million acres of purchased and leased public lands from Seminole, Texas westward to the 

Pecos River, and northward to the vicinity of Tatum, New Mexico, including the area of the 

proposed project. The ranch headquarters was established near Monument Springs, about 

10 km (6 mi) south-southeast from the southern extent of the proposed IIFP site (Anderson, 

Undated). As one of New Mexico's first large-scale cattle ranching operations, the Hat Ranch at 

its peak in the early 1900s had 50,000 head of cattle, 500 saddle horses, 26 water wells, and 

several windmills and ranch houses (Anderson, Undated; NMMA, Undated), however, no 

structures associated with the Hat Ranch have been documented on the IIFP site. 

During the early Statehood Period, most of the land continued to serve as pasture for cattle 

grazing. In the open-range tradition, no fences were used to demarcate property lines in Lea 

County into the 1910s and 1920s (Merlan, 2010). The ranch continues operation today on 

reduced acreage, and the headquarters remain at Monument Spring, where the ranch owners 

reside (Hat Ranch, 2010). The Hat Ranch is not listed in or determined eligible for the NRHP, 

but is listed on New Mexico’s State list of historic resources (NMHPD, 2011). 
 3-7 

3.3.4 Archaeological and Historic Resources at the Proposed IIFP Site 

This section describes the historic and cultural resources in the vicinity of the proposed IIFP 

facility. Historic and cultural resources include archaeological sites, architectural resources 

(such as historic structures, objects, districts, or landscapes) and places of cultural importance 

to groups for maintaining their heritage. Cultural resources are nonrenewable; that is, once 

adversely altered, the information contained in cultural resources cannot be recovered. 

The National Historic Preservation Act of 1966, as amended (NHPA), requires that all adverse 

effects to National Register of Historic Places (NRHP)-listed and eligible historic and cultural 

resources be considered during Federal undertakings, such as the NRC licensing activity for the 

proposed IIFP facility. The requirement to consider adverse effects to cultural resources takes 

the form of a consultation process and/or mitigation. A resource is eligible for listing on the 

NRHP if it meets at least one of the following four criteria (36 CFR 60.4): (1) association with an 

historic person, (2) association with a historic event, (3) representation of the work of a master, 

or (4) potential to provide information on the history or prehistory of the United States. 

Section 106 of the NHPA identifies the process for considering whether a project would affect 

significant cultural resources, which are discussed in Chapter 4 of this EIS. The archaeological 

APE for the Section 106 review for the proposed IIFP facility is the 16 ha (40 ac) proposed 

facility site (Figure 2-2), the access road from NM 483, and an external parking lot immediately 

outside the security fence surrounding the facility property all of which would be directly affected 

by construction. The architectural resource APE includes the viewshed from any NHRP-eligible 

historic resources which would include the proposed facility structures. The APE also considers 

the potential auditory or direct physical impacts of the project to historic architectural resources. 

A distance of 10 km (6 mi) from the project site was determined to be an appropriate APE, 

based on the height of the facility security fence and the facility buildings, which would generally 

be less than 6 m (20 ft) high. 

The Section 106 process requires consultation between the lead Federal agency and the State 

Historic Preservation Office (SHPO), which is the custodian of information on cultural resources 

for the State. The Section 106 process also requires that Federally recognized Native American 

Tribes who have ancestral interest in the property be consulted to determine if resources 

important to the Tribe are present (36 CFR 800.2(4)(c)(ii)). 

Information on historic and archaeological resources at the proposed IIFP site was obtained by 

a file review completed by the applicant’s archaeological resources consultant at the Historic 

Preservation Division of the New Mexico Office of Cultural Affairs on April 17, 2009, and from an 

archaeological survey conducted by IIFP’s archaeological consultant in response to the New 

Mexico State Land Office for the proposed project in May 2009 (Daras, 2009). 

According to the Archaeological Resource Management Records Section of the New Mexico 

Office of Cultural Affairs, the proposed IIFP site had not been the focus of a cultural resource 

survey, and no archaeological or historic architectural resources were identified at the proposed 

site prior to the 2009 cultural resources survey (Daras, 2009) conducted by the applicant. 

The New Mexico State Register of Cultural Resource Properties lists one historic resource 

within 10 km (6 mi) of the proposed site. This is the cluster of stone ranch houses and 

outbuildings that make up the Hat Ranch Headquarters (Site LA 43256, SR #162), which is 

approximately 9.5 km (5.9 mi) from the southern boundary of the proposed site. As noted 

earlier, the Hat Ranch Headquarters has not been listed in or determined eligible for the NRHP 
 3-8 

(NMHPD, 2011); therefore, it is not an historic property subject to protection under Section 106 

of the National Historic Preservation Act. 

IIFP’s archaeological consultant conducted a cultural resource survey in May 2009 on the entire 

249-ha (640-ac) Section 27 tract. The survey was conducted according to New Mexico’s 

Cultural Properties and Historic Preservation, Standards for Survey and Inventory (NMHPD, 

2005 and consisted of systematic surface pedestrian coverage at 15-m (49-ft) intervals. The 

survey identified three isolated artifacts, but no archaeological sites. The isolated artifacts were 

the distal end of a San Jose (Archaic period) chert projectile point, a gray quartzite 

hammerstone, and three decolorized manganese glass vessel fragments. In accordance with 

Section 18-6-5 of the New Mexico Cultural Properties Act, the archaeological consultant 

completed a “negative survey report” to describe the survey and record the isolated artifact 

occurrences. The isolated occurrences were recorded, and the State Land Office and their 

contract archaeologists recommended no further archaeological studies or evaluations (Daras, 

2009). The State Land Office cultural resources survey did not note the presence of any historic 

structures or structural remains. 

Consultation with Native American Tribes was undertaken using a list maintained by the New 

Mexico (NM) SHPO. The NRC staff received three responses (Appendix B). On July 13, 2010, 

the Ysleta del Sur Pueblo stated that the Pueblo believes the project will not adversely affect 

traditional, religious, or culturally significant sites, but requested consultation should human 

remains or artifacts regulated by the Native American Graves Protection and Repatriation Act

be discovered. On June 15, 2011, the Tribal Historic Preservation Officer for the Comanche 

tribe noted that he had no comments on the project. On July 13, 2011, the Shawnee Tribe’s 

Tribal Historic Preservation Department concurred that no known historic properties would be 

impacted by the project, but also requested consultation if archaeological materials are 

encountered during construction or operation of the facility. 

In a letter dated October 14, 2010, from David C. Eck, Trust Land Archaeologist, in the office of 

the State of New Mexico Commissioner of Public Lands, to Jan Biella, New Mexico Historic 

Preservation Division (Appendix B), the Commissioner’s Office states that it “recommends a 

finding of no effect/no cultural properties /no historic properties... There are no documented 

cultural properties within the Area of Potential Effect (APE) when considering direct effects. 

Similarly, there are no registered cultural properties within the assumed, five-mile APE when 

considering indirect effects.” The New Mexico State Historic Preservation Officer concurred 

with this determination (Appendix B). 

3.4 Visual Resources 

This section includes a description of the visual setting on and near the proposed IIFP site. For 

the purposes of this EIS, the ROI for visual resources is defined as the area within a 10 km 

(6 mi) radius of the center point of the proposed IIFP site; accounting for the view of, and view 

from, the proposed facility. 

The 259-ha (640-ac) site is flat and sparsely developed with a few irregularly spaced structures 

for natural gas and oil extraction, and overhead transmission lines. The proposed IIFP facility 

would be approximately 22.5 km (14 mi) west of the nearest population center, Hobbs, New 

Mexico, and would not be visible from Hobbs. As noted in Section 3.2, four energy industry 

facilities are less than 10-km (6-mi) of the proposed site, and three are visible from the site. The 

proposed IIFP site is 1.6 km (1 mi) north of US 62/180 and is bordered on the west by NM 483. 
 3-9 

Although the proposed IIFP facility would be located near the center of the site, it is anticipated 

that it would be visible from both roads. 

No mountain ranges are in the site vicinity. The landscape of the site and vicinity is typical of a 

semi-arid climate and consists of caliche soils with Plains vegetation such as mesquite bushes 

and native prairie grasses. 

As noted in Section 3.2, no recreational areas are within 10 km (6 mi) of the site. The closest 

recreation facilities are golf courses 12 km (7.5 mi) east and northeast (Hobbs Country Club, 

2010; Ocotillo Park Golf Course, 2010), and a motorsports park, also 12 km (7.5 mi) northeast 

(Hobbs Motorsport Park, 2010). These recreational facilities are not within the visual resources 

ROI of the site. The nearest residence is approximately 2.6 km (1.6 mi) northwest of the site 

boundary. A State-listed historic site, Monument Springs, is approximately 10 km (6 mi) 

southeast of the site. 

IIFP assessed the scenic quality of the proposed IIFP site using the U.S. Bureau of Land 

Management (BLM) visual resource inventory process (BLM, 2007). A visual rating is 

determined by evaluating potential impacts of a proposed project on the surrounding area. 

Classes range from Classes I and II (most valued), through Class III (moderate value), to Class 

IV (least valued). Based on the visual resource inventory, the proposed IIFP site was 

determined to be in Class IV (IIFP, 2009). This rating means that the level of change to the 

characteristic landscape can be high, and allows for the greatest level of landscape 

modification. 

3.5 Climatology, Meteorology, and Air Quality 

3.5.1 Climatology 

The climate in the region of the proposed IIFP site is semi-arid with mild temperatures, low 

precipitation and humidity, and a high evaporation rate. The weather is often dominated in the 

winter by high-pressure systems in the central part of the U.S. and low-pressure systems in 

north-central Mexico. The region is typically affected by low-pressure systems located over 

Arizona in the summer (WRCC, 2010). 

The mean monthly temperature over the last 98 years has ranged from 5.7oC (42.2oF) in 

January to 26.8oC (80.2oF) in July. July is the hottest month with an average maximum of 

34.3oC (93.9oF) and an average minimum of 19.2oC (66.6oF). January is the coldest month with 

an average minimum of -2.3oC (27.9oF) and an average maximum of 13.6oC (56.4oF) 

(WRCC, 2010). 

The average annual total rainfall in Hobbs, New Mexico, is 40.54 cm (15.96 in). Average 

monthly rainfall ranges from 1.14 cm (0.45 in) in January to 6.58 cm (2.59 in) in September. 

The mean annual snowfall in Hobbs is 12.7 cm (5.01 in) (WRCC, 2010). 

Thunderstorms occur in Lea County throughout the year, though they are most common in the 

spring and summer, and occasionally include hail. Thunderstorms occur on average 36 days 

per year. Summer rains fall almost entirely during brief, but frequently intense, thunderstorms. 

Rain showers and thunderstorms from June through September account for more than half the 

annual precipitation. The general southeasterly circulation towards the Gulf of Mexico brings 

moisture from the Pacific into New Mexico, and strong surface heating, combined with lifting as 

the air moves over higher terrain, causes air currents and condensation. As storms move inland 
 3-10 

from the Pacific Coast, much of the moisture is precipitated over the coastal and inland 

mountain ranges of California, Nevada, Arizona, and Utah. Much of the remaining moisture falls 

on the western slope of the Continental Divide, which is west of the proposed site, and over 

northern and high-central mountain ranges. Winter is the driest season in eastern New Mexico. 

On average, nine tornadoes are reported per year in New Mexico. Ninety-two tornadoes were 

reported in Lea County from January 1950 to May 2010. There has only been one tornado 

reported in Hobbs, New Mexico, in May 1997 (NCDC, 2010). 

Wind speeds in New Mexico are usually moderate, although relatively strong winds often 

accompany occasional weather fronts during late winter and spring and sometimes occur just in 

advance of thunderstorms. Frontal winds may exceed 48.3 kilometers per hour (km/hr) 

(30 miles per hour [mph]) for several hours and reach peak speeds of more than 80.5 km/hr 

(50 mph) (WRCC, 2010). Winds are generally stronger in the eastern plains, to the north of the 

proposed facility, than in other parts of the state. Winds are generally from the southeast in 

summer and from the west in winter, but local surface wind directions will vary greatly because 

of local topography and mountain and valley breezes (WRCC, 2010). 

Blowing sand may occur occasionally in the area due to the combination of strong winds, sparse 

vegetation, and the semi-arid climate. High winds associated with thunderstorms are frequently 

a source of localized blowing dust. Dust storms that cover an extensive region are rare; and 

those that reduce visibility to less than 1.6 km (1 mi) occur only with the strongest pressure 

gradients such as those associated with intense extra-tropical cyclones which occasionally form 

in the area during winter and early spring (DOE, 2006). 

3.5.2 Greenhouse Gases 

Greenhouse gases (GHGs) include those gases, such as carbon dioxide (CO2), water vapor, 

nitrous oxide (N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and 

sulfur hexafluoride (SF6), that are transparent to solar (short-wave) radiation but opaque to long 

wave (infrared) radiation from the earth’s surface. The net effect over time is a trapping of 

absorbed radiation and a tendency to warm the planet’s surface and the boundary layer of the 

earth’s atmosphere, which constitute the “greenhouse effect” (IPCC, 2007). Some direct GHGs1

(CO2, CH4, and N2O) are both naturally occurring and the product of industrial activities, while 

others, such as the hydrofluorocarbons, are man-made and are present in the atmosphere 

exclusively due to human activities. Each GHG has a different radiative forcing potential, which 

is defined as the gas’ ability to affect a change in climatic conditions in the troposphere2 (IPCC, 

2007). The radiative efficiency of a GHG is directly related to its concentration in the 

atmosphere. 

As a way to compare the radiative forcing potentials of various GHGs without directly calculating 

changes in their atmospheric concentrations, an index known as the Global Warming Potential 

(GWP) (IPCC, 2007) has been established with CO2 as the reference point3

. GWPs are 

calculated as the ratio of the radiative forcing that would result from the emission of 1 kg 

 

1

Direct GHGs are those gases that can directly affect global warming once they are released into the 

atmosphere. 

2

Radiative forcing potential is expressed as the amount of thermal energy [in watts] trapped by the gas 

per square meter of the earth’s surface. 

3

Water vapor is the most abundant and most dominant greenhouse gas in the atmosphere. However, it is 

neither long-lived nor well mixed in the atmosphere, varying from 0 to 2 percent. CO2 is the most 

abundant of GHGs released to the atmosphere after water vapor. 
 3-11 

(2.2 lbs) of a GHG to that which would result from the emission of 1 kg (2.2 lbs) of CO2 over a 

fixed period of time. GWPs represent the combined effect of the amount of time each GHG 

remains in the atmosphere and its ability to absorb outgoing thermal infrared radiation. As the 

reference point in this index, CO2 has a GWP of 1. On the basis of a 100-year time horizon, 

GWPs for other key GHGs are as follows: 21 for CH4, 310 for N2O, 11,700 for HFC-23, and 

23,900 for SF6 (IPCC, 2007). Indirect GHGs, carbon monoxide (CO), nitrogen oxides (NOx)

4

, 

nonmethane volatile organic compounds (NMVOCs), and sulfur dioxide (SO2), indirectly affect 

terrestrial solar radiation absorption by influencing the formation and destruction of tropospheric 

and stratospheric ozone or, in the case of SO2, by affecting the absorptive characteristics of the 

atmosphere. 

3.5.2.1 Greenhouse Gas Emissions and Sinks in the United States 

The U.S. Environmental Protection Agency (EPA) is responsible for preparation and 

maintenance of the official U.S. Inventory of Greenhouse Gas Emissions and Sinks to comply 

with existing commitments under the United Nations Framework Convention on Climate 

Change. GHG sinks are those activities or processes that can remove GHGs from the 

atmosphere. GHG emissions5 are reported in sectors, using the GWPs established in the 

Second Assessment Report of the Intergovernmental Panel on Climate Change (IPCC)6

. Site 

preparation, construction, operation, and decommissioning of the proposed IIFP facility would 

result in the release of GHGs as a result of the same human activities that were identified by 

EPA as the sources of GHGs in the U.S. Inventory. Results of the most recent report on the 

U.S. Inventory of GHG Emissions and Sinks (EPA, 2010a) for direct GHGs that are most 

relevant to the proposed IIFP facility include: 

• The primary GHG emitted by human activities in the U.S. was CO2, representing 

approximately 85.1 percent of the total GHG emissions. 

• In 2008, total U.S. GHG emissions were 6,957 teragrams of CO2 equivalent 

(Tg CO2 Eq), an increase of 14 percent from 1990. 

• Overall emissions of GHGs fell 2.9 percent from 2007 to 2008. 

• CO2 emissions for 2008 were 5,921.2 Tg CO2 Eq, of which 5,572.8 was the result of the 

combustion of fossil fuel primarily related to electricity generation (2,363.5), 

transportation (1,785.3), industrial applications (819.3), residential heating (342.7), and 

commercial applications (219.5) (this considers only fossil fuel emissions in the 50 U.S. 

states, not the U.S. territories). 

• Fifty-three percent of the CO2 emissions related to transportation were the result of 

consumption of gasoline in privately owned vehicles; the remainder was from 

combustion of fuels in diesel trucks and aircraft. 

• Emission of CH4 in 2008 as a result of combustion of fossil fuels in mobile sources was 

2.0 Tg CO2 Eq. 

 

4

NOx represents all thermodynamically stable oxides of nitrogen, excluding nitrous oxide (N2O). 5

In keeping with the GWP convention that names CO2 as the reference gas, assigning it a GWP of 1, 

GWPs of other direct GHGs are expressed as equivalents (Eq.) of CO2, as teragrams (Tg) of CO2

equivalent (Tg CO2 Eq.). One Tg is equal to 1012 grams, or one million metric tons (1.102 million tons). 6

IPCC assessment reports are a compilation of separate reports of the various working groups that are 

established by the Panel. IPCC periodically updates assessment reports to incorporate newly 

established data, including revisions to GWPs and radiative forcing potentials of GHGs. 
 3-12 

• Emission of N2O in 2008 as a result of combustion of fossil fuels in mobile sources was 

26.1 Tg CO2 Eq. 

• Emission of HFCs (released from equipment) in 2008 was 113 Tg CO2 Eq. 

• Emission of SF6 in 2008 as a result of electrical transmission and distribution7

 was 

13.1 Tg CO2 Eq. 

• The primary GHG sinks functional in 2008 included carbon sequestration in forests, 

trees in urban areas, agricultural soils, and landfilled yard trimmings and food scraps, all 

of which, in aggregate, offset 13.5 percent of the total GHG emissions in 2008. 

• The most significant emissions of indirect GHGs in 2008 included: 

o 13,578 Tg CO2 Eq. of NOx, primarily from mobile fossil fuel combustion (7,441), 

stationary fuel combustion (5,148), and industrial processes (520). 

o 60,739 Tg CO2 Eq. of CO, primarily from mobile fossil fuel combustion (51,533), 

stationary fossil fuel combustion (4,792), and industrial processes (1,682). 

o 13,254 Tg CO2 Eq. of NMVOCs, primarily from mobile fossil fuel combustion 

(5,447), solvent use (3,834), industrial processes (1,804), and stationary fossil 

fuel combustion (1,321). 

o 10,368 Tg CO2 Eq. of SO2, primarily from stationary fossil fuel combustion 

(8,891), industrial processes (795), and mobile fossil fuel combustion (472). 

As noted above, consumption of fossil fuels for electricity generation represents the single 

greatest source of CO2 emissions in 2008 (2,363.5 Tg CO2 Eq.). The total gross GHG 

emissions in the United States from all sectors (transportation, industrial, residential, and 

commercial) in 2008 were 6,957 Tg CO2 Eq. Net emissions (considering all emissions and 

sinks) were 6,016.4 Tg CO2 Eq. 

3.5.2.2 Greenhouse Gas Emissions in New Mexico 

A review of statewide emissions of GHGs can inform an understanding of the impact anticipated 

GHG emissions from the proposed IIFP facility would have in a regional context. Among the 

United States, New Mexico ranks 35th with respect to GHGs emissions and 35th in population, 

based on 2003 data (CRS, 2007). The Center for Climate Strategies8

, published a report in 

November 2006 on New Mexico’s Greenhouse Gas Inventory and Reference Case Projections 

for the period 1990–2020 (CCS, 2006). Table 3-1 shows New Mexico GHG emissions by 

sector. Table 3-2 compares the most recent GHG inventories by sector in New Mexico with the 

United States as a whole in calendar year 2000. 

 

7

SF6 is a gas at standard conditions and is used as a dielectric medium in high-voltage electrical 

equipment. 

8

The Center for Climate Strategies is a public-purpose, nonprofit, nonpartisan 501(c)(3) partnership 

organization established in 2004 to assist in climate policy development at the Federal and State levels. 
 3-13 

Table 3-1. New Mexico GHG Emissions, by Sector 

Sector 

Carbon Dioxide Equivalents 

(million metric tons) 

19901 20001 20102 20202

Electricity Production 29.5 33.2 33.3 38.8 

Coal 28.0 30.7 30.4 35.5 

Natural Gas 1.4 2.5 2.9 3.2 

Oil 0.0 0.0 0.0 0.0 

Residential/Commercial/Non-Fossil Industrial (RCI) 7.0 7.3 8.5 9.9 

Coal 0.1 0.2 0.2 0.2 

Natural Gas 3.8 4.6 4.5 5.4 

Oil 3.1 2.5 3.8 4.3 

Wood (CH4 and N2O) 0.0 0.0 0.0 0.0 

Transportation 11.0 14.2 17.6 22.3 

On-road Gasoline 7.2 8.7 10.2 12.2 

On-road Diesel 2.5 4.2 5.6 7.9 

Natural Gas, LPG, Other 0.1 0.1 0.1 0.1 

Jet Fuel and Aviation Gasoline 1.2 1.2 1.6 2.0 

Fossil Fuel Industry 15.2 19.5 20.3 20.7 

Natural Gas Industry 12.7 17.0 17.3 17.7 

Oil Industry 2.3 2.3 2.3 2.3 

Coal Mining (Methane) 0.2 0.2 0.7 0.7 

Industrial Processes3 0.5 1.5 2.0 2.8 

ODS Substitutes 0.0 0.5 1.3 2.3 

PFCs in Semi-conductor Ind. 0.1 0.5 0.2 0.1 

SF6 from Electric Utilities 0.2 0.1 0.1 0.0 

Cement & Other Industry 0.2 0.4 0.4 0.4 

Waste Management 0.8 1.2 1.4 1.2 

Solid Waste Management 0.6 1.0 1.1 0.9 

Wastewater Management 0.2 0.2 0.3 0.3 

Agriculture 4.5 6.0 6.4 6.7 

Manure Management & Enteric Ferment (CH4) 2.3 3.5 4.1 4.4 

Agricultural Soils (N2O) 2.2 2.4 2.3 2.3 

Total Gross Emissions 68.5 82.9 89.4 102.4 

Forestry and Land Use -20.9 -20.9 -20.9 -20.9 

Net Emissions (incl. forestry) 47.6 62.0 68.5 81.5 

Source: CCS, 2006 

1

Historical estimates 

2

Projected estimates

3

The proposed facility would be classified in the Industrial Processes sector. 
 3-14 

Table 3-2. Comparison of New Mexico vs. U.S. GHG Emissions (Percent) by Sector1

Sector Percent of State Total 

GHG Emissions2

Percent of U.S. GHG 

Emissions2

Electricity 40 32 

Fossil fuel industry (CH4) 23 3 

Transportation 17 26 

Agriculture 7 7 

Residential/commercial fuel use 5 9 

Non-Fossil Industrial fuel use 4 14 

Waste 2 4 

Industrial processes 2 5 

Source: CCS, 2006 

1

All data, calendar year 2000 

2

As shown in Table 3-1, total net CO2 emissions for New Mexico for the year 2000 were 62 million metric tons (68 

million tons) of CO2 equivalents. For the United States for that same year, total net CO2 emissions were 5,977 million 

metric tons (6,588 million tons) (EPA, 2010a) 

In March 2010, the NMED published the Inventory of New Mexico Greenhouse Gas Emissions: 

2000-2007 which presented estimates of historical New Mexico anthropogenic GHG emissions. 

This information was compiled to support efforts to address anthropogenic climate change, 

including those of the Climate Change Action Implementation Team, which was created by 

Executive Order 2006-69 – New Mexico Climate Change Action. As reported in the inventory, 

after a 3 percent annual GHG emissions growth rate experienced from 1990 to 2000, the total 

(gross) direct emissions in New Mexico remained essentially level from 2000 to 2007 despite a 

6.7 percent growth in New Mexico’s population over that period (NMED, 2010a). 

3.5.2.3 Projected Impacts from Construction and Operation of the Proposed IIFP 

 Facility on Carbon Dioxide and Other Greenhouse Gases 

Site preparation, construction, operation, and decommissioning of the proposed IIFP facility can 

be expected to result in emissions of CO2 and other GHGs through various mechanisms, 

primarily from combustion of fossil fuels in both mobile and stationary sources. Individual 

contributions of construction and operations are discussed in Chapter 4. Transportation 

volumes used in the following sections were established in Section 4.1.2.9 and are applied here 

without modification. 

3.5.3 Meteorology 

The closest National Climatic Data Center Cooperative Network weather station to the IIFP site 

with the longest length of service is the Hobbs weather station, at the Hobbs Regional Airport, 

approximately 13 km (8 mi) east of the proposed site, which has been in service since 1912. 

The most recent data available for the Hobbs weather station from the Western Regional 

Climate Center are from July 2010. 

Table 3-3 presents a summary of temperatures from the Hobbs weather station from 1912 to 

2010. July, on average, is the hottest month and January is the coldest month. The highest 

temperature measured over the period of record, 45.6oC) (114oF), occurred in June 1998. The 

lowest temperature measured, -21.7oC (-7oF), occurred in January 1962. 
 3-15 

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

Monthly Averages Daily Extremes 

Month Maximum Minimum Mean High Date Low Date 

January 13.6°C 

(56.4°F) 

-2.3°C 

(27.9°F) 

5.7°C 

(42.2°F) 

28.3°C 

(83°F) 1/11/1953 -21.7°C 

(-7°F) 1/11/1962 

February 16.6°C 

(61.8°F) 

0.0°C 

(32.0°F) 

8.3°C 

(46.9°F) 

30.6°C 

(87°F) 2/12/1962 -18.9°C 

(-2°F) 2/2/1985 

March 20.6°C 

(69.1°F) 

3.1°C 

(37.5°F) 

11.8°C 

(53.3°F) 

35.0°C 

(95°F) 3/27/1971 -17.2°C 

(1°F) 3/2/1922 

April 25.4°C 

(77.8°F) 

7.9°C 

(46.3°F) 

16.7°C 

(62.1°F) 

36.7°C 

(98°F) 4/30/1928 -7.8°C 

(18°F) 4/4/1920 

May 29.8°C 

(85.6°F) 

12.9°C 

(55.3°F) 

21.3°C 

(70.4°F) 

41.7°C 

(107°F) 5/30/1951 1.1°C 

(34°F) 5/2/1916 

June 33.9°C 

(93.0°F) 

17.5°C 

(63.5°F) 

25.7°C 

(78.2°F) 

45.6°C 

(114°F) 6/27/1998 4.4°C 

(40°F) 6/3/1919 

July 34.4°C 

(93.9°F) 

19.2°C 

(66.6°F) 

26.8°C 

(80.2°F) 

43.3°C 

(110°F) 7/15/1958 10.0°C 

(50°F) 7/1/1927 

August 33.4°C 

(92.2°F) 

18.7°C 

(65.6°F) 

26.1°C 

(78.9°F) 

41.7°C 

(107°F) 8/9/1952 8.3°C 

(47°F) 8/29/1916 

September 29.9°C 

(85.8°F) 

15.2°C 

(59.3°F) 

22.5°C 

(72.5°F) 

40.6°C 

(105°F) 9/5/1948 1.1°C 

(34°F) 9/23/1948 

October 25.0°C 

(77.0°F) 

9.1°C 

(48.4°F) 

17.1°C 

(62.7°F) 

36.7°C 

(98°F) 10/3/2000 -11.1°C 

(12°F) 10/29/1917

November 18.4°C 

(65.2°F) 

2.7°C 

(36.8°F) 

10.6°C 

(51.0°F) 

31.1°C 

(88°F) 11/1/1952 -15.6°C 

(4°F) 11/29/1976

December 14.3°C 

(57.7°F) 

-1.4°C 

(29.4°F) 

6.5°C 

(43.7°F) 

28.9°C 

(84°F) 12/9/1922 -18.3°C 

(-1°F) 12/24/1983

Source: WRCC, 2010 

Table 3-4 summarizes precipitation at the Hobbs weather station from 1912 to 2010. 

September, on average, is the wettest month, while January and February receive the least 

precipitation. The one-day maximum rainfall of 19.05 cm (7.5 in) occurred in September 1995. 

The NRC staff prepared an EIS for the National Enrichment Facility in Eunice, New Mexico 

(NRC, 2005). The NRC staff examined climatology data from four weather stations in the area: 

Eunice, New Mexico; Hobbs, New Mexico; Midland-Odessa, Texas; and Roswell, New Mexico. 

Table 3-5 describes these weather stations’ locations relative to the proposed IIFP site, and the 

historic records available for each station. 

The data presented in the National Enrichment Facility EIS indicate that the general wind 

patterns for Midland-Odessa, Hobbs, and Eunice were similar (NRC, 2005). Roswell data 

appeared to have a stronger northerly and westerly component. 

Midland-Odessa and Hobbs had comparable climate data based on a comparative analysis of 

meteorological data at the four weather stations nearest the proposed IIFP site (Table 3-5). 
3-16 

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

Rainfall Snowfall 

Month Mean High Year Low Year 1-Day Maximum Mean High Year 

January 1.14 cm 

(0.45 in) 

7.52 cm 

(2.96 in) 1949 0.00 1924 3.07 cm (1.21 in) 1/11/49 3.30 cm (1.3 in) 31.75 cm (12.5 in) 1983 

February 1.19 cm 

(0.47 in) 

6.22 cm 

(2.45 in) 2010 0.00 1917 5.08 cm (2.0 in) 4/10 2.79 cm (1.1 in) 36.32 cm (14.3 in) 1973 

March 1.42 cm 

(0.56 in) 

7.57 cm 

(2.98 in) 2000 0.00 1918 5.08 cm (2.00 in) 3/20/02 1.27 cm (0.5 in) 25.40 cm (10.0 in) 1958 

April 2.01 cm 

(0.79 in) 

13.13 cm 

(5.17 in) 1922 0.00 1917 4.75 cm (1.87 in) 4/20/26 0.51 cm (0.2 in) 22.86 cm (9.0 in) 1983 

May 5.05 cm 

(1.99 in) 

35.13 cm 

(13.83 in) 1992 0.00 1938 13.21 cm (5.20 in) 5/22/92 0.0 0.0 1913 

June 4.78 cm 

(1.88 in) 

23.62 cm 

(9.30 in) 1921 0.00 1924 11.23 cm (4.42 in) 6/7/18 0.0 0.0 1913 

July 5.38 cm 

(2.12 in) 

23.90 cm 

(9.41 in) 1988 0.00 1954 11.35 cm (4.47 in) 7/19/88 0.0 0.0 1913 

August 6.12 cm 

(2.41 in) 

23.29 cm 

(9.17 in) 1920 0.10 cm (0.04 in) 1938 11.30 cm (4.45 in) 8/9/84 0.0 0.0 1913 

September 6.58 cm 

(2.59 in) 

32.99 cm 

(12.99 in) 1995 0.00 1939 19.05 cm (7.50 in) 9/15/95 0.0 0.0 1913 

October 4.01 cm 

(1.58 in) 

20.70 cm 

(8.15 in) 1985 0.00 1917 14.22 cm (5.60 in) 10/9/85 0.25 cm (0.1 in) 11.43 cm (4.5 in) 1976 

November 1.42 cm 

(0.56 in) 

11.00 cm 

(4.33 in) 1978 0.00 1915 9.65 cm (3.80 in) 11/4/78 1.52 cm (0.6 in) 41.91 cm (16.5 in) 1980 

December 1.42 cm 

(0.56 in) 

12.90 cm 

(5.08 in) 1986 0.00 1917 4.72 cm (1.86 in) 12/21/42 2.54 cm (1.0 in) 24.13 cm (9.5 in) 1986 

Annual 40.54 cm 

(15.96 in) 

81.76 cm 

(32.19 in) 1941 13.41 cm (5.28 in) 1917 19.05 cm (7.50 in) 9/15/95 12.7 cm (5.0 in) 68.83 cm (27.1 in) 1980 

Source: WRCC, 2010 
 3-17 

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

Station 

Distances and Direction from 

Proposed Site 

Length of Record 

(years)1 Station Elevation 

Eunice, New Mexico 34 km (21 mi) south of site 1 (1993) 1,050 m (3,445 ft) 

Hobbs, New Mexico 13 km (8 mi) east of site 16 (1982-1997) 1,115 m (3,658 ft) 

Midland-Odessa, Texas 138 km (86 mi) southeast 

of site 16 (1982-1997) 872 m (2,861 ft) 

Roswell, New Mexico 129 km (80 mi) northwest 

of site 16 (1982-1997) 1,118 m (3,668 ft) 

Source: NRC, 2005 and WRCC, 2010 

1

Years of compiled data for climatology analysis. 

Because Midland-Odessa was a first-order weather station with data completeness exceeding 

EPA requirements, NRC staff used the data from the Midland-Odessa weather station for its 

dispersion modeling for the National Enrichment Facility EIS. Hourly meteorological 

observations at Midland-Odessa were used to generate wind rose plots. Monthly wind speeds 

and prevailing wind directions at Midland-Odessa for the years 1987 to 1991 are presented in 

Figure 3-3. The annual mean wind speed was 17.7 km/hr (11 mph) and the prevailing wind 

direction was 180 degrees with respect to north. The maximum 5-second wind speed was 

112.7 km/hr (70 mph) (NRC, 2005). At Hobbs, the average wind speed varied from 16.1 km/hr 

(10.0 mph) for the month of August to 21.6 km/hr (13.4 mph) for the month of April. The annual 

average wind speed recorded at Hobbs was 18.3 km/hr (11.4 mph). The prevailing wind 

direction was out of the north blowing to the south. 

3.5.4 Air Quality 

3.5.4.1 Regulatory Setting 

3.5.4.1.1 Criteria Pollutants 

Under the Clean Air Act, the EPA has established National Ambient Air Quality Standards 

(NAAQS) that specify the maximum concentrations for seven criteria air pollutants: CO, 

particulate matter with aerodynamic diameters of 10 microns or less (PM10), particulate matter 

with aerodynamic diameters of 2.5 microns or less (PM2.5), ozone, SO2, lead, and NO2. New 

Mexico also has ambient air quality standards in place (New Mexico Ambient Air Quality 

Standards [NMAAQS]), which are equal to or more stringent than the NAAQS. NMAAQS are 

enforced by New Mexico, and allowed under the Clean Air Act by EPA. Table 3-6 lists the 

Federal and Mew Mexico Ambient Air Quality Standards. Areas with air quality as good as or 

better than the standards are designated as “attainment areas.” Areas with air quality that is 

worse than the standards are designated as “non-attainment areas.” Areas that were 

designated non-attainment and subsequently re-designated as attainment due to meeting the 

standards are termed “maintenance areas.” States with maintenance areas are required to 

develop an air quality maintenance plan as an element of the State Implementation Plan. 

The EPA divided the nation into 247 Air Quality Control Regions (AQCRs) based on a number 

of factors that influence regional air quality including climate and meteorology, topography, 

vegetation, land use patterns, population characteristics, and growth projections. Lea County is 

in the Pecos-Permian Basin Intrastate AQCR (40 CFR 81.242) and is in attainment for all of the 

NAAQS, as is the rest of the Pecos-Permian Basin Intrastate AQCR (40 CFR 81.332). The 
 3-18 

Figure 3-3. Wind Roses for Midland-Odessa, Roswell, Hobbs, and Eunice for 1993 

Source: NRC, 2005 

closest non-attainment areas are in the El Paso-Las Cruces-Alamogordo Interstate AQCR 

(40 CFR 81.82), approximately 314 km (195 mi) southwest of the proposed IIFP facility. The 

Anthony area in Doña Ana County, New Mexico and the city of El Paso in El Paso County, 

Texas are designated as moderate non-attainment areas under the PM10 NAAQS 

(40 CFR 81.332 and 40 CFR 81.344). 
 3-19 

3.5.4.1.2 Hazardous Air Pollutants 

Provisions of the Clean Air Act as amended required EPA to establish technology-based 

standards for Hazardous Air Pollutants (HAP). Under Federal law, HAPs are those air 

pollutants listed in Section 112 of the Clean Air Act for which no NAAQS have been established. 

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

Pollutant Averaging Period NAAQS NMAAQS 

CO 8-hour 9 ppm 

(10 mg/m3

) 

8.7 ppm 

1-hour 35 ppm 

(40 mg/m3) 

13.1 ppm 

NO2 Annual 0.053 ppm 0.05 ppm 

24-hour None5 0.10 ppm 

1-hour 0.100 ppm None5

Ozone 8-hour 0.075 ppm None 

1-hour1 0.12 ppm None 

SO2 Annual Revoked6 0.02 ppm 

24-hour Revoked6 0.10 ppm 

3-hour 0.50 ppm None 

1-hour 0.075 ppm None 

PM2.5 Annual 15.0 μg/m3 None 

24-hour 35 μg/m3 None 

PM10 Annual Revoked7 None 

24-hour 150 μg/m3 None 

Lead Rolling 3-month 0.15 μg/m3 None 

Total Suspended 

Particulates 

Annual Geometric Mean Not an NAAQS Pollutant 60 μg/m3

30-day 90 μg/m3

7-day 110 μg/m3

24-hour 150 μg/m3

Hydrogen Sulfide (H2S) 1-hour2 Not an NAAQS Pollutant 0.010 ppm 

1⁄2-hour3 0.100 ppm 

1⁄2-hour4 0.030 ppm 

Total Reduced Sulfur 1⁄2-hour2 Not an NAAQS Pollutant 0.003 ppm 

1⁄2-hour3 0.010 ppm 

1⁄2-hour4 0.003 ppm 

Source: : 40 CFR 50; NMAC 20.2.3 

1

The 1-hour ozone NAAQS will not apply to an area one year after the effective date of the designation of that area 

for the 8-hour ozone NAAQS. The effective designation date for most areas is June 15, 2004 (40 CFR 50.9). 2

For the state, except for the Pecos-Permian Basin Intrastate AQCR. 3

For the Pecos-Permian Basin Intrastate AQCR. 

4

For within 5 miles of the corporate limits of municipalities within the Pecos-Permian Basin Intrastate AQCR. 5

Regulatory agencies have not established standards. 

6

The 24-hour and annual SO2 NAAQS was revoked by EPA on June 22, 2010. 7

The annual PM10 NAAQS was revoked by EPA on September 21, 2006. 

μg/m3

 = micrograms per cubic meter 

mg/m3

 = milligrams per cubic meter 

ppm = parts per million 
 3-20 

There are currently 188 hazardous air pollutants listed, including, but not limited to, the 

pollutants controlled by the National Emissions Standards for Hazardous Air Pollutants 

(NESHAP) program (40 CFR 61 and 63). 

3.5.4.1.3 Prevention of Significant Deterioration 

Under the Clean Air Act, the EPA established Prevention of Significant Deterioration (PSD) 

regulations, which apply to proposed new or modified sources in an attainment area that have 

the potential to emit NO2, PM2.5, PM10, or SO2 in excess of predetermined levels 

(40 CFR 52.21). Allowable deterioration to air quality can be expressed as the incremental 

increase in ambient concentrations of criteria pollutants, or PSD increment. Increments for 

criteria pollutants are based on the PSD classification of the area. Class I areas, which include 

certain national parks and wilderness areas, allow the lowest amount of permissible 

deterioration by precluding development near designated areas. All other areas of the United 

States are Class II areas where moderate, well-controlled industrial growth is allowed. The 

allowable PSD increments for Class I and Class II areas are identified in Table 3-7. 

The proposed IIFP facility is in a PSD Class II area. There are no PSD Class I areas within 

100 km (62 mi) of the proposed IIFP facility (40 CFR 81, Subpart D). The nearest PSD Class I 

areas to the proposed IIFP facility are Carlsbad Caverns National Park and the Guadalupe 

Mountains National Park, located about 114 km and 154 km (71 mi and 96 mi), respectively, 

southwest of the proposed site. Therefore, due to the distances involved to the closest PSD 

Class I areas; there is no reason to expect deterioration of air quality from the volumes of IIFP 

facility-generated NO2, particulate matter, and SO2. 

Table 3-7. Allowable Prevention of Significant Deterioration Increments 

Pollutant Averaging Period 

Class I PSD Increment 

(μg/m3) 

Class II PSD Increment 

(μg/m3) 

NO2 Annual 2.5 25 

PM2.5 Annual 1 4 

24-hour 2 9 

PM10 Annual 4 17 

24-hour 8 30 

SO2 Annual 2 20 

24-hour 5 91 

3-hour 25 512 

Source: 40 CFR 52.21 

3.5.4.1.4 Regional Haze 

Regional haze is a visibility impairment caused by cumulative air pollutant emissions from 

numerous sources over a wide geographic area. The primary cause of regional haze in many 

parts of the country is light scattering from fine particles (PM2.5) in the atmosphere. Course 

particles (PM10) can also contribute to light extinction. Section 169 of the Clean Air Act

established a national goal for visibility, defined as the “prevention of any future, and remedying 

of any existing, impairment of visibility in Class I areas...from manmade air pollution.” Under 

the regional haze rule, States are required to develop State Implementation Plans to address 

visibility at designated mandatory PSD Class I areas, including designated national parks, 
 3-21 

wilderness areas, and wildlife refuges (40 CFR 51.309). A visibility analysis is required for each 

PSD Class I area located within 100 km (62 mi) of any new or modified major stationary sources 

whose emissions exceed PSD modeling thresholds. As discussed above, there are no PSD 

Class I areas within 100 km (62 mi) of the proposed IIFP so no visibility analysis is required. 

3.5.4.1.5 General Conformity for Federal Actions 

According to Section 176 of the Clean Air Act (40 CFR 51.853), a Federal agency must make a 

conformity determination in the approval of a project with air emissions that exceed specified 

thresholds in nonattainment and/or maintenance areas. This General Conformity Rule ensures 

that the actions taken by Federal agencies in non-attainment and maintenance areas meet 

national standards for air quality and do not cause further degradation to air quality which would 

be inconsistent with the attainment and maintenance of ambient air quality standards. The 

proposed project is not in a non-attainment or maintenance area; therefore, no general 

conformity analysis is required. 

3.5.4.2 Existing Conditions 

Air quality in Lea County, New Mexico is considered unimpaired. Farming, ranching, oil and gas 

development, a few industrial facilities, and vehicular traffic are the primary activities that would 

affect ambient air quality. 

The closest air quality monitoring station to the proposed IIFP site is in Hobbs, New Mexico. 

The Hobbs station monitors NO2, ozone, PM2.5, and PM10. The nearest air quality monitoring 

stations for CO, SO2, and lead are in Rio Rancho, New Mexico, Artesia, New Mexico, and El 

Paso, Texas, respectively. The monitored criteria pollutant concentrations for the years 2006 

through 2008 are summarized in Table 3-8. 

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

Pollutant 

Averaging 

Time NAAQS 2006 2007 2008 

Monitor 

Location 

CO (ppm) 8-hour 9 1.4 0.6 NA Rio Rancho, 

NM1

1-hour 35 1.6 1.1 NA 

NO2 (ppm) Annual 0.053 0.008 0.006 0.006 Hobbs, NM 

1-hour 0.100 0.054 0.053 0.052 

Ozone (ppm) 8-hour 0.075 0.075 0.064 0.067 Hobbs, NM 

SO2 (ppm) Annual 0.03 0.001 0.001 0.001 Artesia, NM 

24-hour 0.14 0.004 0.001 0.001 

3-hour 0.50 0.017 0.005 0.001 

1-hour 0.075 0.066 0.011 0.002 

PM2.5 (μg/m3) Annual 15.0 6.82 7.26 6.85 Hobbs, NM 

24-hour 35 12.5 14.8 14.6 

PM10 (μg/m3) 24-hour 150 60 55 39 Hobbs, NM 

Lead (μg/m3) Quarterly 0.15 0.04 0.05 0.02 El Paso, TX 

Source: EPA, 2009a 

1

The CO monitor in Rio Rancho did not operate in 2008. 
 3-22 

3.6 Geology, Minerals, and Soil 

3.6.1 Regional and Site Near-surface Geology 

The proposed IIFP site is in the Llana Estacado section of the Southern High Plains 

physiographic region. The Llana Estacado is an isolated mesa that slopes gently to the eastsoutheast and covers a large part of eastern New Mexico and western Texas. The Mescalero 

Ridge escarpment, which defines the southwestern limit of the Llano Estacado (Figure 3-4) 

crosses the western and central portions of Lea County as a nearly perpendicular cliff 

(Nicholson and Clebsch, 1961). 

The site is underlain by (in descending order) Quaternary-age alluvium, Triassic- and 

Cretaceous-age rocks, and Permian-age rocks that fill the Permian Basin. The Permian Basin 

underlies an area approximately 402 km (250 mi) wide and 483 km (300 mi) long and is a major 

oil and natural gas producing area (UTPB, 2010). Beginning in 1921, more than 40,000 

exploration wells and 200,000 development wells have been drilled in the Permian Basin region 

(Scholle, 2000). The Basin produces 17 percent of the nation’s crude oil (UTPB, 2010). The 

Basin is also a major source of potassium salts (potash) (UTPB, 2010). Oil, gas, and potash 

production in Lea County are summarized in Section 3.6.3. 

According to the EPA, there were 95 point sources of criteria pollutants in Lea County, New 

Mexico for emissions year 2002 (EPA, 2009b). Emission data for 2002 are the most recent data 

available from EPA. Motor vehicles and various area sources also contributed to the criteria 

pollutant emissions in Lea County. Table 3-9 presents a summary of the 2002 annual Criteria 

Air Pollutants emissions for Lea County. 

The Ogallala Formation consists of valley-fill deposits of clay, silt, fine- to coarse-grained sand, 

gravel and caliche (hardened calcium carbonate), the distributions of which vary both vertically 

and horizontally. The formation ranges in thickness from 0 to as much as 107 m (350 ft) 

(Fahlquist, 2003; Tillery, 2008). Locally, the top of the Ogallala Formation consists of a resistant 

layer of caliche as thick as 18 m (60 ft) (Nicholson and Clebsch, 1961). 

Table 3-9. Lea County Criteria Pollutant Emissions in 2002 

Pollutant 

Point 

metric tons 

per year 

(tons per year) 

Mobile 

metric tons 

per year 

(tons per year) 

Area 

metric tons 

per year 

(tons per year) 

Total 

metric tons 

per year 

(tons per year) 

CO 7,250 (7,992) 13,376 (14,744) 618 (681) 21,244 (23,417) 

NO2 25,605 (28,225) 1,386 (1,528) 128 (141) 27,119 (29,894) 

SO2 7,197 (7,933) 67.8 (74.7) 68.5 (75.5) 7,334 (8,084) 

PM2.5 214 (236) 47.9 (52.8) 2,630 (2,899) 2,892 (3,188) 

PM10 244 (269) 57.2 (63.1) 24,747 (27,279) 25,048 (27,611) 

VOC 1,996 (2,200) 1,067 (1,176) 1,373 (1,513) 4,436 (4,890) 

Source: EPA, 2009b 

Quaternary-age alluvial deposits underlying the site consist of sand ranging up to 1 m (3 ft) thick 

(Hunt, 1977) that mantles the underlying late Tertiary-age Ogallala Formation (NMBGMR, 

2003). 
 3-23 

3.6.2 Seismicity and Volcanism 

The proposed IIFP site is in a seismically quiet region, with local earthquakes of relatively small 

magnitude (moment magnitude of less than 2 on the Modified Mercalli-Revised 1931 scale 

[MM]). No Quaternary faults or folds, thought to be associated with most earthquakes of 

moment magnitude 6 or greater over the last 1.6 million years, exist in the southeast New 

Mexico/west Texas region (Crone and Wheeler, 2000; Machette et al., 1988; Yarger, 2009). 

The nearest faulting is more than 161 km (100 mi) west of the site and is associated with the 

Rio Grande Rift. 

Seismic activity in southeastern New Mexico is typically of small magnitude and generally 

caused by oil field injection activities. However, the largest recent major earthquake (5.0 MM) in 

New Mexico occurred south of Eunice in January, 1992 (Sanford et al., 2002; Sanford et al., 

2006; Yarger, 2009). A seismic event of 5.0 MM would be felt outside only and observed inside 

by swinging doors or swaying wall pictures. 

The New Mexico Institute of Mining and Technology using instrumental data has estimated 

probabilistic seismic hazards for New Mexico of duration magnitude 2.0 MM or greater for the 

time period 1962 through 1998 (Sanford et al., 2002; Sanford et al., 2006). Figure 3-5 shows 

the probabilistic seismic hazard map in the format of peak horizontal ground acceleration (PGA) 

at 10 percent probability of exceeding 6 MM in a 50-year period (or, approximately once every 

500 years). PGA is a measure of earthquake force at ground surface and is an index of hazard 

for structures. The units for PGA are in percent gravity (g). As shown in Figure 3-5, the highest 

predicted PGA, approximately 0.18 g, is approximately 40 km (25 mi) north of Socorro. The 

IIFP site area has a predicted PGA of approximately 0.02 g. A PGA of 0.02 g is considered the 

acceleration level at which considerable damage can begin to occur to poorly designed or 

weakly-built structures of masonry, adobe, or stone (Sanford et al., 2002; Sanford et al., 2006). 

New Mexico has experienced almost 700 volcanic events over the past 5 million years, ranging 

from small basalt flows to large eruptions. The volcanic events are roughly aligned with two 

zones of structural weakness that cross New Mexico: the Colorado Plateau Transition Zone 

and the Rio Grande Rift. The most recent volcanic activities were the eruptions of two relatively 

large basalt flows associated with the tectonic activity along Rio Grande Rift: the Carrizozo and 

McCarty’s basalts (Limburg, 2009). The Carrizozo basalt covers approximately 329 km2

(127 mi2

) near the town of Carrizozo, approximately 258 km (160 mi) west of the site. Studies 

indicate that the age of the basalt flow is between 4,800 and 5,200 years. The McCarty basalt 

flow covers approximately 344 km2

 (133 mi2) near the town of Grants, approximately 547 km 

(340 mi) northwest of the site. Isotope studies indicate that the Grants flow is approximately 

3,000 years old (Zimbelman and Johnston, 2001). 

3.6.3 Minerals 

Mineral resources in Lea County include industrial minerals such as fluorite and gypsum; 

construction materials such as potash, caliche, sand, and gravel; and energy sources such as 

coal, oil, and gas (Figure 3-6). 

Although there are no designated mining districts in Lea County (McLemore et al., 2007), 

industrial and construction materials including potash, salt, sulfur, sand, gravel and caliche are 

mined at the eight active commercial mines/pits/mills in Lea County listed on Table 3-10. 
 3-24 

 
 3-25 

 
 3-26 

 
 3-27 

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

Name Commodity Operation 

Lea County Pit Base course, crushed rock, caliche, top soil, sand Pit/Mill 

Hawthorne Pit Caliche Pit 

Constructors Aggregate, caliche, other Pit 

Eunice Pit Sand and gravel Pit 

Old Baldy Pit Aggregate Pit 

Intrepid Potash Potash Mill 

Rowland Salt Salt Mine 

Eunice Plant Sulfur Sulfur Pit 

Sources: USGS, 2005a; Pfeil, et al., 2001; NMEMNRD, 2010a 

Caliche caps the Llano Estacado to a maximum thickness of 18 m (60 ft). It is mined throughout 

southeastern New Mexico, including Lea County, for construction and cement uses. Lea 

County is riddled with hundreds of small, abandoned caliche pits that were used by the New 

Mexico Department of Transportation for road construction material. There is a small caliche pit 

in the southeastern corner of Section 27. Caliche is currently mined at the Hawthorne Pit north 

of Lovington in Lea County. 

Coal is not mined in Lea County (McLemore et al., 2007). 

The New Mexico portion of the Permian Basin contains 1,112 designated, discovered oil 

reservoirs and 672 designated, discovered gas reservoirs. Large active oil and gas fields have 

existed in Lea County for more than 50 years (Leedshill-Herkenhoff et al., 2000). 

According to the New Mexico Oil & Gas Wells database (NMEMNRD, 2010b), 715 oil or gas 

wells are within a 10-km (6-mi) radius of the proposed IIFP site. Seven of these wells are within 

a 1.6-km (1-mi) radius. The seven wells were drilled between 1987 and 1999, but subsequently 

abandoned. One abandoned well is in the extreme southwestern corner of Section 27, but no 

oil or gas wells are located within the proposed facility boundary. The locations of the seven 

wells are shown in Figure 3-7, and well details are summarized in Table 3-11. The proposed 

IIFP site has been explored for oil and gas and caliche. The site has very limited leasable, 

locatable, or marketable mineral resources (NMEMNRD, 2010a; NMEMNRD,2010b; NMT, 

2010; Pfeil, et al., 2001; USGS, 2005a). 

3.6.4 Soil 

Soils occupying the southern High Plains in Lea County generally comprise shallow to deep 

gravelly and loamy soils, or deep sandy soils formed from windblown and water-deposited 

materials in the Quaternary and late Tertiary periods. Soft or hard caliche is generally found 

below the soils in most of the southern High Plains. 

Soils underlying the proposed IIFP site include those of Kimbrough, Lea, Portales, Stegall 

and Slaughter soil associations. The distribution of these soil associations are shown in 

Figure 3-8, and the soil characteristics are summarized in Table 3-12. 

In October 2010, a study was conducted by GL Environmental, Inc. for IIFP (GL Environmental, 

2010a). They collected two soil samples from the site, which were analyzed to characterize 
 3-28 

 
 3-29 

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

Grid Name 

American 

Petroleum Institute 

(API) Number 

Spud 

Date1

Depth Meters 

(ft) Comments 

Yates Petroleum Corp 3002529864 1987 3,360 (11,025) Plugged and 

abandoned 

Chevron USA Inc 3002528999 1999 3,475 (11,400) Abandoned 

Basin Alliance LLC 3002528083 1982 3,708 (12,164) Abandoned 

Westbrook Oil Corp 3002526605 1999 1,728 (5,670) Abandoned 

Shell Oil Company 3002512733 1999 1,612 (5,289) Abandoned 

Getty Oil Company 3002503974 1999 1,433 (4,700) Abandoned 

Texas Pacific & Pure 3002503977 1999 3,733 (12,245) Abandoned 

Source: NMT, 2010 

1

Spud date is the date when the drill bit first hits the ground. 

API = American Petroleum Institute 

Table 3-12. Site Soil Characteristics 

Soil Association 

Soil 

Map 

Symbol 

Section 27 

Hectares 

(Acreage) Description 

Kimbrough gravelly 

loam 

KO 17.7 (43.7) Gravelly loam from zero to 15.2 cm (6 in). Cemented 

material from 15.2 to 40.6 cm (6 to 16 in). Welldrained with a very low capacity to transmit water. 

Kimbrough-Lea 

Complex 

KU 227.3 

(561.7) 

Loam from zero to 66 cm (26 in). Cemented material 

from 25.4 to 66 cm (10 to 26 in). Well-drained with a 

very low capacity to transmit water. 

Portales loam PC 18 (44.5) Farmland of Statewide Importance. Loam from zero 

to 20.3 cm (8 in). Clay loam from 20.3 to 152.4 cm (8 

to 60 in). Well-drained with a high capacity to transmit 

water. 

Portales-Stegall 

loam 

PS 0.4 (0.9) Farmland of Statewide Importance. Loam from zero 

to 22.9 cm (9 in). Clay loam from 22.9 to 71.1 cm (9 

to 28 in). Cemented material from 71.1 to 96.5 cm 

(28 to 38 in). Variable from 96.5 to 152.4 cm (38 to 

60 in). Well-drained with a very low to moderate 

capacity to transmit water. 

Stegall and 

Slaughter soils 

SS 2.0 (5.0) Farmland of Statewide Importance. Loam from zero 

to 5.1 cm (2 in). Clay from 5.1 to 38.1 cm (2 to 15 in). 

Cemented material from 38.1 to 63.5 cm (15 to 25 in). 

Variable from 63.5 to 152.4 cm (25 to 60 in). Welldrained with a very low to moderately high capacity to 

transmit water. 

Source: NRCS, 2010 
 3-30 

 
 3-31 

baseline soil conditions. The soil samples were collected from a depth of 6 in and analyzed for 

radiological parameters, RCRA metals, volatile organic compounds (VOCs) and semi-volatile 

organic compounds (SVOCs). 

U-234 was reported in the two soil samples at concentrations from 4.42 × 10-7 to 5.95 × 10-7

microcuries per gram (μCi/g). U-235/-236 was reported in concentrations from 5.58 × 10-9 to 

2.60 × 10-8 μCi/g. U-238 results were from 5.86 × 10-7 to 5.95 × 10-7 μCi/g. All isotope 

concentrations are consistent with background levels in the site area. 

Detected RCRA metals included barium with concentrations from 88.5 to 109 milligrams per 

kilograms (mg/kg), cadmium from 0.27 to 0.42 mg/kg, chromium from 10.0 to 12.2 mg/kg, and 

lead from 11.7 to 14.7 mg/kg. All other RCRA metals were at less than laboratory method 

detection limits. These elements are not uncommon in soils, but levels may have been elevated 

due to past petrochemical-related operations in the area. No VOCs or SVOCs were detected 

(GL Environmental, 2010a). 

New Mexico has farmland protection programs to help slow the conversion of farmland to 

developed uses. Farmland is usually divided into three distinct categories: prime farmland, 

unique farmland, and farmland of statewide or local importance. Prime farmland is land of 

exceptional physical and chemical soil characteristics that can be used in agriculture with 

minimum input of nutrients, labor, etc. Prime farmland cannot be committed to urban 

development or water storage. Unique farmland is of lower quality than prime farmland but is 

still able to produce high-value food or grain products. Farmland of statewide or local 

importance does not meet the criteria for prime or unique farmland, but the soil is still 

considered important for the production of food and fiber. 

The proposed IIFP site has approximately 20.4 ha (50.5 ac) of soils classified as farmland of 

statewide importance. The soils on the proposed site do not include tracts of land that have 

been designated for agriculture by state law (Carter, 2010). 

3.7 Water Resources 

These sections consider the groundwater and surface water use, and groundwater and surface 

water quality that could affect water use or quality at the site, or be affected by the construction 

or operation of the proposed IIFP facility. 

3.7.1 Groundwater 

Regional and site-specific data on the physical and hydrologic characteristics of the 

groundwater resources at, and in the vicinity of, the site are summarized in this section to 

provide basic data for an evaluation of impacts on the aquifers of the area. 

3.7.1.1 Regional Groundwater 

The High Plains aquifer, also known as the Ogallala aquifer, is a regional aquifer system that 

underlies 450,660 km2

 (174,000 mi2) in parts of eight States: Colorado, Kansas, Nebraska, New 

Mexico, Oklahoma, South Dakota, Texas, and Wyoming (USGS, 2010a; McGuire et al., 2003). 

Because of its large size, the High Plains aquifer has been geographically subdivided into three 

aquifer regions: the southern High Plains, central High Plains, and the northern High Plains. 

About 27 percent of the irrigated land in the United States overlies this aquifer system, which 

yields about 30 percent of the nation’s groundwater for irrigation. In addition, the aquifer system 
 3-32 

provides drinking water to 82 percent of the population within the aquifer boundary (USGS, 

2010a). 

The proposed IIFP site and surrounding region are underlain by the southern High Plains 

aquifer (Hart and McAda, 1985). The southern High Plains aquifer is an unconfined aquifer and 

is composed primarily of Quaternary-age alluvial sediments and the Tertiary-age Ogallala 

Formation. The Ogallala Formation, which underlies about 80 percent of the High Plains, is the 

principal geologic unit forming the aquifer (USGS, 2010a). The Ogallala aquifer is typically 

underlain by impermeable clays and shale, although in some places the underlying Cretaceousage formations are hydraulically connected to the aquifer. Beneath the Ogallala aquifer in the 

Lea County underground water basin (UWB) are the Triassic-age Lower Dockum Group Santa 

Rosa aquifer and the deeper Permian-age rocks, which include the Rustler Formation, Capitan 

aquifer, and San Andres aquifer (Figure 3-9) (NMOSE, 2009; McCoy and Perry, 2004). 

3.7.1.2 Local Groundwater 

Groundwater resources in Lea County include hydrogeologic strata within five UWBs 

(Figure 310). The UWBs are areas of underground water with reasonably ascertainable 

boundaries declared by the New Mexico Office of the State Engineer (NM OSE). The four 

primary basins, from north to south, are the Lea County UWB, the Capitan UWB, the Carlsbad 

UWB, and the Jal UWB. A small area (approximately 142 km2

 [55 mi2]) of a fifth UWB, the 

Roswell UWB, lies beneath west-central and northeast Lea County. The UWBs are designated 

based on their distinct hydrogeologic configurations, which do not typically end at county or 

State boundaries. The four primary UWBs include the following primary aquifers: Lea County 

UWB (Ogallala aquifer), Capitan UWB (Capitan aquifer), Carlsbad UWB (Santa Rosa aquifer), 

and the Jal UWB (Alluvial aquifer) (Leedshill-Herkenhoff et al., 2000). 

The Lea County UWB is discussed in detail below because it underlies the proposed IIFP site. 

Following that discussion, site and vicinity groundwater are more specifically characterized. 

3.7.1.2.1 Lea County Underground Water Basin 

The proposed IIFP site is above the Lea County UWB, which encompasses 5,646 km2

(2,180 mi2

) and covers most of northern Lea County and small portions of Chaves and Eddy 

Counties in southeast New Mexico (Stephens & Assoc., 2009). The basin boundaries are 

shown in Figures 3-9, 3-10, and 3-11. 

The Ogallala aquifer is the primary water source in the Lea County UWB, which extends the 

width of Lea County to the east and west. To the south, the Lea County UWB is bounded by 

the Mescalero Ridge and associated escarpment (Figures 3-11 and 3-4), which indicates the 

southern extent of the High Plains aquifer. The maximum saturated thickness of the Ogallala 

aquifer within the UWB is about 76 m (250 ft) (Leedshill-Herkenhoff et al., 2000). The depth to 

groundwater in the Ogallala Formation is approximately 9.1 m (30 ft) in the site area 

(Figure 3-12). 

Generally, the Ogallala Formation has an upward fining of sediments, which may have a 

significant effect on the distribution of porosity and permeability in the aquifer, controlling both 

the amount of water that can be stored and its movement through the aquifer (Stephens & 

Assoc., 2009). 
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The hydraulic conductivity of the Ogallala aquifer in the Lea County UWB, as reported by a 

number of different studies (McGuire et al., 2003; Musharrafieh and Chudnoff, 1999; Stephens 

& Assoc., 2009), ranges from 0.9 to 80 m per day (3 to 262 ft per day), with higher hydraulic 

conductivities near Hobbs (i.e., near the proposed IIFP site) and eastward toward the Texas 

border. Irrigation well yields in the aquifer range from 757 to nearly 7,571 liters per minute 

(L/min) (200 to nearly 2,000 gallons per minute [gpm]) (Leedshill-Herkenhoff et al., 2000). 

Discharge from the Ogallala aquifer in Lea County occurs through groundwater pumping and 

subsurface flow. The largest amount of natural groundwater discharge is the subsurface flow 

into Texas (Figure 3-11). A small amount of groundwater discharges through the Quaternary 

alluvium to southern Lea County (McAda, 1984). 

The principal source of recharge to the aquifer occurs from precipitation infiltrating into the 

subsurface, primarily in areas covered by dune sand or playa lakes. Annual average recharge 

is estimated to range from 1.3 to 2.5 cm (0.5 to 1 in) (Tillery, 2008). It is estimated that 

approximately 3,840,000 ha-m (31,100,000 ac-ft) of groundwater is presently in storage in the 

UWB, of which only 45 percent (approximately 1,730,000 ha-m [14,000,000 acre-ft]) can 

actually be recovered because the saturated thickness of much of the aquifer is too shallow for 

water recovery to be feasible (Musharrafieh and Chudnoff, 1999; Leedshill-Herkenhoff et al., 

2000). 

Under pre-pumping conditions, recharge of the Ogallala aquifer was in equilibrium with natural 

discharge. Because current pumping for municipal, industrial, irrigation and other uses exceed 

the Ogallala’s recharge rate, the aquifer has experienced significant drawdown. The water level 

in the Ogallala aquifer has declined as much as 30 m (97 ft) in the Lea County UWB from 1914 

to 2007. The area of maximum saturated thickness is generally near or coincident with the area 

of maximum water-level decline, which is north of Hobbs and near the Texas state line (Tillery, 

2008). Groundwater in the Ogallala aquifer flows east-southeast towards Texas (Figure 3-11). 

Depths to groundwater in the Lea County UWB range from 6.1 m (20 ft) in the Monument area 

to 76 m (250 ft) near the exposed caprock of the Mescalero Ridge (Figure 3-12) (Tilllery, 2008; 

Musharrafieh and Chudnoff, 1999). 

Modeling by Musharrafieh and Chudnoff (1999) and observed water level declines indicate 

portions of the aquifer may become unsaturated by the year 2045. Other portions of the aquifer 

are also predicted to have a saturated thickness inadequate to sustain existing water rights 

(NMOSE, 2009). 

Due to the limited groundwater supply within the southern High Plains aquifer, the NM OSE 

issued an order on March 10, 2009 closing the southern High Plains aquifer to the filing of 

applications under NMSA Section 72-12-3, which is the statute that regulates wells for new 

appropriations other than those applications filed under Section 72-12-1. The order does not 

apply to applications filed under NMSA Section 72-12-1.1 (wells required for relatively small 

amounts of water for single or multiple households, or for drinking or sanitary uses in 

conjunction with a commercial operation); Section 72-12-1.2 (livestock wells); or 

Section 72-12-1.3 (wells used for a period not to exceed one year for specifically listed 

purposes) (NMOSE, 2009). 

Applications filed under NMSA Section 72-12-3 to appropriate groundwater from the units listed 

on Table 3-13 are considered on a case-by-case basis (NMOSE, 2009). 
 3-38 

Table 3-13. Summary of Potential Deep-Aquifer Groundwater Sources for Lea County 

Aquifer 

Geologic 

Age 

Typical Depth to 

Top of Aquifer 

m (ft) bgs 

Typical Thickness 

m (ft) 

Estimate 

Yields 

L/min (gpm) 

Santa Rosa aquifer Triassic 150 to 335 

(500 to 1,100) 

60 to 76 (200 to 250) 

[730 (2,400) max] 

23 to 379 

(6 to 100) 

Rustler Formation Upper 

Permian 

210 to 410 

(700 to 1,350) 

24 to 43 (80 to140) 

[110 (360) max] 

38 to 379 

(10 to 100) 

Capitan aquifer Permian 850 to 1,400 

(2,800 to 4,600) 

270 to 430 

(900 to1,400) 

[670 (2,200) max] 

189 to 4,921 

(50 to 1,300) 

San Andres aquifer Permian 910 to 1,500 

(3,000 to 5,000) 

210 to 610 

(700 to 2,000) 833 (220) 

Source: McCoy and Perry, 2004 

bgs = below ground surface 

gpm = gallons per minute 

L/min = litters per minute 

The NM OSE guidelines for new groundwater withdrawal applications for all UWBs include 

block administration and local assessment methods to limit aquifer drawdown. The block 

administration consists of 1.6 km2

 (1 mi2) blocks that correspond to model cells in the 

groundwater-flow model (Musharrafieh and Chudnoff, 1999). A 40-year planning period ending 

in 2045 has been selected for block administration (NMOSE, 2009). 

Model cells predicted to become unsaturated or with an inadequate saturated thickness for 

continued well operation require a higher level of restriction. Areas requiring such restriction are 

designated Critical Management Areas (CMAs). The CMAs include those model cells predicted 

to have a saturated thickness of 17 m (55 ft) or less by the year 2045 (Figure 3-13). 

Key aspects of the NM OSE guidelines for new groundwater applications include the following: 

(1) water rights can be moved from one block to another throughout the basin, (2) the 

administrative groundwater flow model will be used to determine regional drawdowns resulting 

from an application, (3) applications to move water rights cannot create more drawdown than 

0.0076 m/yr (0.025 ft/yr) in a CMA, or 0.061 m/yr (0.20 ft/yr) in a non-CMA, and (4) local area 

impacts from the proposed water-rights application will be performed and will include evaluation 

of impacts to the saturated thickness and reductions in water columns of existing wells (NMOSE 

2009). On March 10, 2009, the NM OSE issued an order closing the Lea County UWB to the 

filing of groundwater applications (NMOSE, 2009). In 1999, in order to meet the projected 

groundwater demands of Lea County, 138 applications were filed by the Lea County Water 

Users Association to appropriate 6,389 ha-m (51,797 ac-ft) per year of groundwater, which was 

essentially all the unappropriated groundwater in the Lea County UWB (Leadshill-Herkenhoff 

et al., 2000). 

A portion of the applications to appropriate groundwater, totaling 4,215.2 ha-m (34,173 ac-ft) per 

year, have been assigned to Lea County during (at least) the 40-year planning period to allow 

the County to hold the subject water rights unused until the rights can be put to beneficial use at 

projects currently under construction, select future projects, and homes and businesses in 

unincorporated areas. The proposed IIFP site has been included in Lea County’s 40-Year 

Water Development Plan as an area of proposed development where up to 21.6 ha-m (175 

ac-ft) per year of the Lea County’s water rights would be put to beneficial use. The estimated 
 3-39 

 
 3-40 

quantity of groundwater that Lea County would need by the end of the 40-year planning period 

for all projects that currently exist, are being constructed, or have a high likelihood of being 

constructed in the near future is 1,173.5 ha-m (9,514 ac-ft) per year (Leadshill-Herkenhoff et al., 

2000). 

3.7.1.2.2 Site and Vicinity Groundwater 

A data query of the NM OSE Statewide well database on water supply wells within 1.6 km (1 mi) 

of the site is summarized in Table 3-14, and the locations of the wells are shown in Figure 3-14. 

The depth to groundwater in the 10 water supply wells within 1.6 km (1 mi) of the site ranges 

from 8.5 to 21 m (28 to 70 ft) below ground surface (bgs). One well (L 04011) has insufficient 

data and was most likely not completed. The wells are installed in the Ogallala aquifer at 

depths ranging from 35 to 62.5 m (115 to 205 ft) bgs. 

Xcel Energy’s Cunningham Station, located just west of Section 27 has four groundwater 

monitoring wells (M-3, CU-6, -8, and -9) in Section 27 (Figure 3-14). 

According to the NM OSE Statewide well database (2010), 261 groundwater wells are within a 

10-km (6-mi) radius of the site (Figure 3-15). Most of the wells are categorized as prospecting 

wells. There is a domestic well approximately 2.6 km (1.6 mi) northwest of the site. 

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

Owner POD Number 

Well 

Use 

Drill 

Date 

Total Depth

m (ft) 

Depth to 

Water 

m (ft) 

Well Yield

L/min 

(gpm) 

Abbott, Murrell L 03757 PRO 1957 38.1 (125) 13.7(45) NA 

Abbott, Murrell L 03928 PRO 1958 35 (115) 18.3 (60) NA 

NA L 04011 PUB NA NA NA NA 

Abbott Bros L 05176 X IND 1965 60.4 (198) 16.8 (55) 200 (53) 

Abbott Bros L 05176 X-2 

(M-3) IND 1965 50 (164) 16.8 (55) 151 (40) 

Abbott Bros L 05176 X-3 IND 1965 58 (190) 21.3 (70) 159 (42) 

Abbott Bros L 05176 X-4 IND 1965 54 (177) 21.3 (70) 144 (38) 

Abbott Bros L 05176 X-5 IND 1965 62.5 (205) 15.2 (50) 151 (40) 

Abbott Bros L 05176 X-6 IND 1965 61.9 (203) 8.5 (28) 151 (40) 

NA L 07469 DOM 1976 48.8 (160) 21.3 (70) NA 

Keith, Ronny L 12341 POD1 SAN 2009 58 (190) 21.3 (70) NA 

Source: NMOSE, 2010 

DOM = Domestic 

IND = Industrial 

NA = Not available 

POD = Point of diversion 

PRO = Prospecting/development of natural resources 

PUB = Construction of public works 

SAN = Sanitary in conjunction with a commercial use 
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The nearest municipal water system is the City of Hobbs municipal system, approximately 

16 km (10 mi) east northeast of the site. The system comprises 29 active groundwater supply 

wells, which are grouped into five well fields or systems. The wells range in depth from 54 to 

81.7 m (177 to 268 ft) bgs, and the depth to water ranges from 23 to 51 m (75 to 167 ft) bgs. 

Yields for the wells range from 927 to 3,407 L/min (245 to 900 gpm). The combined yield from 

the five systems is estimated at 59,620 L/min (15,750 gpm) when the pumps are running 

24 hours a day (Stephens & Assoc., 2009). 

3.7.1.3 Groundwater Use 

Groundwater use for Lea County, as reported by the NM OSE, is summarized in Table 3-15. 

Irrigation systems are the largest users (72.8 percent) of groundwater in the county, followed by 

mining (9.9 percent) and public water supply systems (7.2 percent). Smaller amounts of 

groundwater are used by industry, electric power generators, livestock, and domestic/ 

commercial users. 

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

Groundwater Use Category 

Groundwater Use 

ha-m (ac-ft) 

Commercial (self-supplied) 403 (3,264) 

Domestic (self-supplied) 175 (1,419) 

Industrial (self-supplied) 751 (6,088) 

Irrigated Agriculture 16,698 (135,371) 

Livestock (self-supplied) 453 (3,670) 

Mining (self-supplied) 2,265 (18,365) 

Power (self-supplied) 545 (4,415) 

Public Water Supply 1,648 (13,360) 

Total 22,937 (185,952) 

Source: NMOSE, 2008 

ha-m = hectare meters 

ac-ft – acre feet 

3.7.1.4 Groundwater Quality 

This section considers the groundwater quality of aquifers that could affect water use at the 

proposed site, or be affected by the construction or operation of the proposed IIFP facility. 

3.7.1.4.1 Regional Groundwater Quality 

In 2001, the U.S. Geological Survey (USGS) National Water-Quality Assessment Program 

collected groundwater samples from 48 wells screened in the Southern High Plains aquifer, 

primarily from domestic wells in eastern New Mexico and western Texas. Depths of wells 

sampled ranged from 30 to 152 m (100 to 500 ft), with a median depth of 61.3 m (201 ft). 

Depths to water ranged from 10 to 136 m (34 to 445 ft) bgs, with a median depth of 40.8 m 

(134 ft). 

Of 240 parameters analyzed in the 48 wells, EPA public drinking-water standards or guidelines 

were exceeded in one or more wells for arsenic, boron, chloride, dissolved solids, fluoride, 
 3-44 

manganese, nitrate, radon, strontium, or sulfate. Pesticides were detected at very low 

concentrations (<1 mg/L) in fewer than 20 percent of the samples (Fahlquist, 2003). 

Groundwater quality data from the City of Hobbs municipal drinking water system between 2005 

and 2009 are summarized in Table 3-16. Each of the 29 wells comprising the system is 

screened in the Ogallala aquifer. The data indicate that groundwater quality in the aquifer near 

Hobbs is good and water quality standard exceedances are rare. 

3.7.1.4.2 Site Groundwater Quality 

The three monitoring wells along the western Section boundary (Figure 3-13) were installed by 

Xcel Energy to monitor for the presence of contaminants in groundwater that could originate 

from an unlined cooling tower pond at the Cunningham Station, and runoff from agricultural 

fields. Groundwater analytical data collected from monitoring wells CU-6, -8, and -9 indicate 

that of seven constituents sampled, sulfate, total dissolved solids, and chloride exceeded the 

New Mexico Water Quality Bureau Control Commission Standards for Groundwater (NMAC 

20.6.2); however, boron, chlorite, pH and nitrates (including nitrate nitrogen) are below or within 

the standards. Groundwater quality data were not available for monitoring well M-3 

(GL Environmental, 2010b). 

3.7.2 Surface Water 

The Southern High Plains Basin in New Mexico encompasses 14,211 km2

 (5,487 mi2) in Curry, 

Roosevelt, Chavez, and Lea Counties (NMWQCC, 2002). The Mescalero Ridge (see 

Figure 3-4) separates the Southern High Plains (and the associated Texas Gulf Basin 

watershed) from the Pecos River Basin watershed. The proposed IIFP site lies just east of the 

Mescalero Ridge, in the Southern High Plains Basin and the Texas Gulf Basin watershed (see 

Figure 3-4). 

No perennial streams traverse the Southern High Plains although there are some ephemeral 

streams that occasionally have large flows after rain storms. Surface water in Lea County is 

limited to intermittent streams, lakes, and numerous small playa lakes that result from heavy 

rainfall during the summer (Leedshill-Herkenhoff, Inc. et al., 2000). Surface drainage to playa 

lakes captures 80 to 90 percent of rainfall (Sublett and Peery, 2009). There is no true drainage 

system off the High Plains within Lea County. 

Several depressions that hold water after rainfalls dot Section 27. Two dry stream beds bisect 

the southern portion of the Section from the northwest to the southeast, outside the boundaries 

of the proposed facility (Figure 3-16). The US ACE has determined that these ephemeral 

surface waters are not jurisdictional wetlands (USACE, 2011). 

The nearest surface waters flow through Monument Draw, which is an ephemeral stream that 

can have large flows (Leedshill-Herkenhoff, Inc. et al., 2000). The headwaters of Monument 

Draw’s nearest tributary is approximately 4 km (2.5 mi) from the nearest Section boundary and 

the main reach is approximately 10 km (6 mi) from the nearest Section boundary. The nearest 

permanent lake is approximately 32 km (20 mi) southwest of the proposed IIFP site 

(Figure 3-17). The site is in an area classified as an undetermined risk for flooding (Zone D) by 

the Federal Emergency Management Agency (FEMA) (Figure 3-18) (eHow, undated). 

Properties in Zone D lie outside areas that are known floodplains, but may still flood. 
 3-45 

Table 3-16. Summary of City of Hobbs Municipal Water System Groundwater Water 

Quality, 2005 – 2009 

Parameter 

MCLa

(μg/Lb

) 

Number of 

Detections 

Detected Concentrations (μg/Lb

) 

Minimum Maximum Average 

1,2-Dichloroethane 5 3 0.47 0.61 0.52 

Antimony, Total 6 4 0.09 0.13 0.11 

Arsenic 10 13 6.5 8.1 7.29 

Barium 2,000 13 43.51 89 69.77 

Benzene 5 2 0.58 0.81 0.70 

Beryllium, Total 4 1 0.25 0.25 0.25 

Bromodichloromethane 100 3 0.08 0.3 0.16 

Bromoform 100 4 0.092 12 6.43 

Chloroform 100 4 0.057 0.24 0.13 

Chromium 100 13 2.9 18.8 7.09 

Combined Uranium 30 6 0.00321 0.00927 0.01 

Dibromochloromethane 100 3 0.055 0.37 0.23 

Dichloromethane 5 5 4.35 5.62 4.89 

Ethylbenzene 700 1 0.50 0.50 0.50 

Fluoride (mg/L) 4 13 0.719 1.13 0.91 

Gross Beta Particle Activity (pCi/L) 4 6 2.869 7.305 4.33 

Iron (mg/L) 0.3c 1 0.0134 0.0134 0.0134 

Nickel 100 13 0.3 3.51 1.46 

Nitrate (as N) (mg/L) 10 12 2.69 5.82 4.01 

Nitrate plus Nitrite (as N) (mg/L) 10 30 2.7 6.97 4.24 

pH (standard units) 6.5 to 8.5c 1 7.24 7.24 7.24 

Radium-226 (pCi/L) 5 2 0.175 0.382 0.28 

Radium-228 (pCi/L) 5 1 1.082 1.082 1.082 

Selenium 50 13 0.00589 18 5.24 

Total Haloacetic Acids) 60 11 1 105.3 14.01 

Total Trihalomethanes 80 20 0.602 13.95 6.85 

Thallium, Total 2 2 0.05 0.05 0.05 

Xylenes, Total 10,000 6 0.7 2.05 1.37 

Note: Includes water quality data for five ground storage reservoirs and Well 5, which pumps directly into the 

distribution system. Samples were collected after the raw water had been chlorinated. 

Source: Stephens & Associates, 2009. 

a

Maximum contaminant level specified in EPA National Primary Drinking Water Regulations (40 CFR 141 (2010)) 

b

Unless otherwise noted 

c

EPA National Secondary Drinking Water Regulations (40 CFR 143 (2010)) 

μg/L = micrograms per liter 

MCL = maximum contaminant level 

mg/L = milligrams per liter 

pCi/L = picocuries per liter 
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3.8 Ecological Resources 

This section describes the ecological communities on the 259-ha (640-ac) proposed IIFP site, 

which includes the 16-ha (40-ac) proposed facility, and in the vicinity of the proposed site. It 

also discusses important species that occur or have the potential to occur on the site or in the 

vicinity, and habitats in the vicinity that are important to those species. 

Surveys were conducted for IIFP for vegetation and wildlife, including the dunes sagebrush 

lizard (Sceloporus arenicolus) and the lesser prairie chicken (Tympanuchus pallidicintus), two 

Federal candidate species (GL Environmental, 2010c; GL Environmental, 2010d; SORA, 2011). 

The dunes sagebrush lizard’s range encompasses the IIFP site and a BLM resource 

management plan has been proposed to preserve habitat for the lesser prairie-chicken and the 

dunes sagebrush lizard, roughly 11 km (7 mi) from the IIFP site, and create a travel corridor for 

the lesser prairie-chicken roughly 52 km (32 mi) from the site, as discussed in Section 3.8.6.3. 

3.8.1 Ecosystems in the Proposed Facility 

As described in Section 3.6.1, the site is on the Llano Estacado of the Southern High Plains 

physiographic region. The western portion of the Llano Estacado supports shortgrass prairie 

habitat, and the southern portion is transitional to the more arid Chihuahuan Desert. The site 

lies in a transitional zone between two distinct ecoregions: Western Great Plains Shortgrass 

Prairie and Apacherian-Chihuahuan Mesquite Upland Scrub (Figure 3-19) (USGS, 2010b). 

3.8.1.1 Western Great Plains Shortgrass Prairie 

Western Great Plains Shortgrass Prairie habitat covers approximately 55 percent of the 

proposed site. The short grasses that dominate the system are extremely drought- and grazingtolerant. This ecosystem is characterized by blue grama grass (Bouteloua gracilis). Scattered 

shrub and dwarf-shrub species such as sand sagebrush (Artemisia filifolia), prairie sagewort 

(Artemisia frigida), little sagebrush (Artemisia tridentate), fourwing saltbush (Atriplex 

canescens), crispleaf buckwheat (Eriogonum effusum), broom snakeweed (Gutierrezia 

sarothrae), and pale desert-thorn (Lycium pallidum) may also be present. Climate, fire, and 

grazing maintain this system (NatureServe, 2009; USGS, 2010b). 

3.8.1.2 Apacherian-Chihuahuan Mesquite Upland Scrub 

Apacherian-Chihuahuan Mesquite Upland Scrub habitat covers approximately 45 percent of the 

proposed site. This ecosystem often occurs as invasive upland shrublands such as those that 

are concentrated in the foothills and piedmont of the Chihuahuan Desert (NatureServe, 2009). 

Vegetation is dominated typically by honey mesquite (Prosopis glandulosa) or velvet mesquite 

(Prosopis velutina) and succulents. Grass cover is typically low and composed of desert 

grasses such as low woollygrass (Dasyochloa pulchella), bush muhly (Muhlenbergia porteri), 

curlyleaf muhly (Muhlenbergia setifolia), and tobosagrass (Pleuraphis mutica) (NatureServe, 

2009). During the last century, the area occupied by this ecosystem has increased through 

conversion of desert grasslands as a result of drought, overgrazing by livestock, and decreases 

in fire frequency (NatureServe, 2009; USGS, 2010b). 
 3-50 

 

 
 3-51 

3.8.1.3 Wetland and Riparian Habitat 

As described in Section 3.7.2, there are no wetlands or stream systems within the footprint of 

the proposed facility. Depressions that hold ephemeral water, which are located throughout 

Section 27, are important breeding and nursery sites for amphibians, and can be important 

stopovers for migrating waterfowl and shorebirds. Vegetated arroyos, such as the one running 

across the southern part of Section 27 (and outside the 16-ha [40-ac] facility footprint), serve as 

excellent wildlife corridors, and nesting habitat for birds (New Mexico Department of Game and 

Fish [NMGF] correspondence in Appendix B). 

3.8.2 Vegetation of the Proposed Facility 

Most of the plant species on the proposed facility are typical of Plains-Mesa Grassland and 

Desert Grassland communities (Dick-Peddie, 1993). These communities are characterized by 

significant amounts of grasses and less than 10 percent of total cover being forbs and shrubs 

(Dick-Peddie, 1993). 

A vegetation survey was conducted by GL Environmental on behalf of IIFP at the proposed 

16-ha (40-ac) facility on October 16, 2010 to determine total vegetative cover and relative cover 

(GL Environmental, 2010c). Total vegetative cover represents the percentage of ground that 

has living vegetation on it compared to bare ground or litter. Relative cover represents the 

fraction of total vegetative cover that is composed of a certain species or category of plants 

(e.g., perennial plants). Total vegetative cover is approximately 45 percent with 98 percent of 

this cover consisting of perennial grasses, including blue grama, burrograss (Scleropogon 

bevifolius), black grama (Bouteloua eripoda), and James Galleta grass (Pleuraphis jamesii). 

Shrubs included honey mesquite and hedgehog cactus (Echinocereus sp.). Forbs on the site 

included Texas croton (Croton texensis), Texas blueweed, (Helianthus ciliaris), and curly cup 

gumweed (Grindelia squarrosa) (GL Environmental, 2010c). 

3.8.3 Wildlife that Could Occur on the Site and Proposed Facility 

Wildlife that could occur on the IIFP site include species typical of arid grassland and desert 

habitats. Table 3-17 lists mammals, birds, amphibians, and reptiles that could be present on the 

site, based on habitat requirements, and presents information regarding their preferred habitats. 

The table was compiled from the lesser prairie-chicken survey (SORA, 2011) conducted by 

SORA on behalf of IIFP for the proposed site in April 2011 and surveys conducted in 2004 for 

the Louisiana Enrichment Services (LES) National Enrichment Facility, located approximately 

33 km (20 mi) southeast of the proposed IIFP (NRC, 2005). Comparison with the LES site is 

appropriate because both facilities are in the transition zone from the shortgrass prairie to the 

Chihuahuan desert (USDA, 2004). 

A diverse assemblage of animals, including several commercially and recreationally important 

game species are typical of this habitat. Pronghorn “antelope” (Antilocapra americana) and 

mule deer (Odocoileus hemionus) are plentiful in eastern New Mexico (NMGF, 2009). NMGF 

has assigned sections of the State to specific Antelope Management Units in order to better 

manage pronghorn antelope populations. The proposed IIFP site is within Antelope 

Management Unit 26, one of several management units in southeastern New Mexico. An 

estimated 44 pronghorn were harvested from this Management Unit in 2007-2008 (NMGF, 

2008a). The site is also a part of New Mexico Game Management Unit 31. Approximately 

500 mule deer were harvested from Game Management Unit 31 in 2009 (NMGF, 2010a). 
 3-52 

Table 3-17. Mammal, Bird, Amphibian, and Reptile Species Likely to be Present at the 

Proposed Site and Vicinity 

Common Name Scientific Name 

Mammals Preferred Habitat 

Black-tailed jackrabbit Lepus californicus Grasslands and open areas 

Black-tailed prairie dog Cynomys ludovicianus Shortgrass prairie 

Cactus mouse Peromyscus eremicus Grasslands, prairies, and mixed 

vegetation 

Collared peccary Dicotyles tajacu Brushy, semi-desert, chaparral, 

mesquite, and oaks 

Coyote Canis latrans Open space, grasslands, and 

brush country 

Deer mouse Peromyscus maniculatus Grasslands, prairies, and mixed 

vegetation 

Desert cottontail Sylvilagus audubonii Arid lowlands, brushy cover, and 

valleys 

Mule deer Odocoileus hemionus hemionus Desert shrubs, chaparral, and 

rocky uplands 

Ord’s kangaroo rat Dipodomys ordii Hard desert soils 

Plain’s pocket gopher Geomys bursarius Deep soils of the plains 

Pronghorn Antilocapra americana Sagebrush flats, plains, and 

deserts 

Raccoon Procyon lotor Brushy, semi-desert, chaparral, 

and mesquite 

Southern Plains woodrat Neotoma micropus Grasslands, prairies, and mixed 

vegetation 

Spotted ground squirrel Spermophilus spilosoma Brushy, semi-desert, chaparral, 

mesquite, and oaks 

Striped skunk Mephitis mephitis All land habitats 

Swift fox Vulpes velox Rangeland with short grasses and 

low shrub density 

White-throated woodrat Neotoma albigula Grasslands, prairies, and mixed 

vegetation 

Yellow-faced pocket gopher Pappogeomys castanops Deep soils of the plains 

Birds Seasonal Preference 

American kestrel Falco sparverius Year round 

Ash-throated flycatcher Myiarchus cinerascens Spring 

Bewick’s wren Thyromanes bewickii Spring and summer 

Black-chinned hummingbird Archilochus alexandri Spring 

Blue grosbeak Guiraca caerulea Summer 

Bullock’s oriole Icterus bullockii Summer 

Cassin’s sparrow Aimophila cassinii Spring and Fall 

Cactus wren Campylorhynchus 

brunneicapillus 

Year round 
 3-53 

Table 3-17. Mammal, Bird, and Amphibian, and Reptile Species Likely to be Present at 

the Proposed Site and Vicinity (Continued) 

Common Name Scientific Name 

Birds (Continued) Seasonal Preference 

Chihuahuan raven Corvus cryptoleucus Year round 

Common raven Corvus corax Summer and winter 

Crissal thrasher Toxostoma dorsale Migrant 

Eastern meadowlark Sturnella magna Year round 

European starling Sturnus vulgaris Year round 

Gambel’s quail Lophortyx gambelii Rare 

Great-tailed grackle Quiscalus mexicanus Year round 

Green-tailed towhee Pipilo chlorurus Migrant 

Horned lark Eremophila alpestris Spring 

House finch Carpodacus mexicanus Spring and summer 

Killdeer Charadrius vociferus Spring and summer 

Lark bunting Calamospiza melanocorys Winter 

Lark sparrow Chondestes grammacus Spring and summer 

Loggerhead shrike Lanius ludovicianus Summer 

Long-eared owl Asio otus Summer and winter 

Mallard Anas platrhynchos Spring 

Mourning dove Zenaida macroura Spring and summer 

Nighthawk Chordeiles minor Spring 

Northern mockingbird Mimus polyglottos Summer 

Northern bobwhite Colinus virginianus Spring 

Pyrrhuloxia Cardinalis sinuatus Winter 

Red-tailed hawk Buteo jamaicensis Winter 

Red-winged blackbird Agelaius phoeniceus Year round 

Roadrunner Geococcyx californianus Uncommon 

Sage sparrow Amphispiza belli Uncommon 

Say’s phoebe Sayornis saya Spring 

Scaled quail Callipepla squamata Spring and summer 

Scissor-tailed flycatcher Tyrannus forficatus Migrant 

Scott’s oriole Icterus parisorum Summer and winter 

Swainson’s hawk Buteo swainsoni Summer 

Turkey vulture Cathartes aura Summer 

Vermillion flycatcher Pyrocephalus rubinus Winter and migrant 

Vesper sparrow Pooecetes gramineus Spring 

Western burrowing owl Athene cunicularia hypugaea Spring 

Western kingbird Tyrannus verticalis Summer 
 3-54 

Table 3-17. Mammal, Bird, and Amphibian, and Reptile Species Likely to be Present at 

the Proposed Site and Vicinity (Continued) 

Common Name Scientific Name 

Amphibians/Reptiles Preferred Habitat 

Coachwhip Masticophis flagellum Mixed grass prairie and desert 

grasslands 

Collared lizard Crotaphytus collaris Desert grasslands 

Eastern fence lizard Sceloporus undulates Mixed grass prairie and desert 

grasslands 

Garter snake Thamnophis sp. Desert grasslands 

Ground snake Sonora semiannulata Desert grasslands 

Longnose leopard lizard Gambelia wislizenii Mixed grass prairie and desert 

grasslands 

Lesser earless lizard Holbrookia maculata Mixed grass prairie and desert 

grasslands 

Longnosed snake Rhinocheilus lecontei Desert grasslands 

Ornate box turtle Terrapene ornate ornata Desert grasslands and shortgrass 

prairie 

Pine-gopher snake Pituophis melanoleucus Shortgrass prairie and desert 

grasslands 

Plains blackhead snake Tantilla nigriceps Shortgrass prairie and desert 

grasslands 

Plains spadefoot toad Spea bombifrons Shallow to standing pools of water 

Rattlesnakes Crotalus sp. Shortgrass prairie and desert 

grasslands 

Six-lined racerunner Cnemidophorus sexlineatus Mixed grass prairie and desert 

grasslands 

Tiger salamander Ambystoma tigrinum Tall-grass and mixed prairie 

Texas horned lizard Phrynosoma cornutum Desert grasslands 

Western whiptail lizard Cnemidophorus tigris Mixed grass prairie and desert 

grasslands 

Source: NRC, 2005; USDA, 2004; eBird, 2011; SORA, 2011 

Lea County also provides opportunities to hunt small birds, most notably scaled quail (Callipepla 

squamata) and Northern bobwhite (Colinus virginianus). Scaled quail occur primarily in semiarid rangelands with mixed scrub communities (shrubs, grasses, and bare ground) (NMGF, 

2008b). The vegetation on the proposed IIFP site provides habitat for scaled quail. Northern 

bobwhites also occur in southeastern New Mexico, including Lea County (NMGF, 2008b). 

Northern bobwhite habitat in New Mexico is characterized by large expanses of native warmweather grasses mixed with annual weeds and legumes, with dense, brushy areas for escape 

cover and roosting (NMGF, 2008b). The near absence of dense thickets on the proposed IIFP 

site suggests that it offers only marginal Northern bobwhite habitat. 
 3-55 

3.8.4 Wildlife Travel Corridors for Resident and Migratory Species 

3.8.4.1 Migratory Species 

Southeastern New Mexico, including Lea County, is within the Central Flyway, one of the four 

major North American bird migration corridors between nesting and wintering grounds (CFC, 

undated; TPWD, 2007). Birds of prey associated with the Central Flyway include the American 

kestrel (Falco sparverius), ferruginous hawk (Buteo regalis), Swainson’s hawk (Buteo 

swainsoni) and others. Waterfowl that use the Central Flyway to move between breeding areas 

in Canada and wintering areas in Texas and Mexico include the mallard (Anas platrhynchos), 

American widgeon (Anas americana), green-winged teal (Anas crecca) and others. Songbirds 

that migrate along the Central Flyway include the American goldfinch (Spinus tristis), Western 

kingbird (Tyrannus verticalis), lark bunting (Calamospiza melanocorys), vesper sparrow 

(Pooecetes gramineus) and others. Common shorebirds associated with the Central Flyway 

include the killdeer (Charadrius vociferus), greater yellowlegs (Tringa melanoleuca), spotted 

sandpiper (Actitis macularia), least sandpiper (Calidris minutilla) and others (Stokes and Stokes, 

1996). Depending on the availability of food and water that may be temporarily present in the 

depressions that dot Section 27 during seasonal migrations, migratory birds such as these could 

occasionally be present on or in the vicinity of the site. 

3.8.4.2 Resident Species 

Wildlife corridors are typically linear habitats that link larger habitats. They can serve a region 

(e.g., a river followed by migratory waterfowl), a landscape (e.g., a transmission corridor right-ofway that connects two natural areas), or a local site (e.g., a gully or strip of trees that deer use 

to move between bedding and feeding areas). There are no terrain features at the proposed 

IIFP site that would serve as wildlife corridors. 

3.8.5 Critical Habitats 

Under the Endangered Species Act “critical habitat” is defined as: (1) specific areas within the 

geographical area occupied by the [listed] species at the time of listing, if they contain physical 

or biological features essential to conservation, and those features may require special 

management considerations or protection; and (2) specific areas outside the geographical area 

occupied by the [listed] species if the agency determines that the area itself is essential for 

conservation. 

The nearest critical habitat is the Pecos River, approximately 146 km (91 mi) northwest of the 

site, which supports the Pecos bluntnose shiner (Notropis simus pecosensis). This fish is listed 

as Federally threatened (USFWS, 2010a). 

3.8.6 Wildlife Sanctuaries, Wildlife Management Areas, Refuges, and Preserves 

Wildlife sanctuaries, management areas, refuges, and preserves are areas designated by the 

NM GF as open to wildlife-associated recreation activities beyond the traditional uses of hunting 

and fishing. 

3.8.6.1 Green Meadow Lake 

Green Meadow Lake is a New Mexico-designated Wildlife Area approximately 16 km (10 mi) 

northeast from the proposed site (NMGF, Undated 1). Migratory waterfowl using the Central 

Flyway may rest at the lake during migrations. 
 3-56 

3.8.6.2 Prairie Chicken Wildlife Area 

The New Mexico-designated Prairie Chicken Wildlife Area comprises parcels throughout 

southeastern New Mexico that provide habitat for the preservation and restoration of the lesser 

prairie-chicken (NMGF, Undated 2). The closest Prairie Chicken Wildlife Area is more than 

80 km (50 mi) from the proposed site. 

3.8.6.3 Lesser Prairie-Chicken Habitat Preservation Area of Critical Environmental 

 Concern and Proposed Lesser Prairie-Chicken Expansion Corridor 

In 2008, the BLM issued a Record of Decision (ROD) to implement a resource management 

plan (RMP) for all resources on approximately 343,983 surface ha (850,000 surface ac) of 

public land in parts of Chaves, Eddy, Lea, and Roosevelt Counties in southeastern New Mexico. 

To meet some of the objectives of this RMP, the BLM will establish a 23,472-ha (58,000-ac) 

Lesser Prairie-Chicken Habitat Preservation Area of Critical Environmental Concern (ACEC) to 

maintain and enhance habitat for the lesser prairie-chicken and the dunes sagebrush lizard. 

The entire RMP area lies west and south of the proposed facility location; the nearest part of the 

RMP area is approximately 11 km (7 mi) due south of the site (Figure 3-20) (BLM, 2008). 

Additionally, the BLM has proposed a Lesser Prairie-Chicken Expansion Corridor in 

southeastern New Mexico in order to maintain a north-south travel way for lesser prairiechickens. No final decision has been made about the corridor (BLM, 2010) which is 51.5 km 

(32 mi) from the proposed site at its nearest boundary (Figure 3-20). 

The IIFP proposed site does not provide optimal habitat for the lesser prairie-chicken and is not 

included in the ACEC nor in the proposed corridor. 

3.8.7 Special-Status Species 

The Endangered Species Act defines an endangered species as any species which is in danger 

of extinction throughout all or a significant portion of its range, and a threatened species as any 

species which is likely to become an endangered species within the foreseeable future 

throughout all or a significant portion of its range. 

According to the New Mexico Rare Plant Technical Council there are no special-status plant 

species in Lea County (NMRPTC, 1999). 

The U.S. Fish and Wildlife Service (USFWS) maintains lists of endangered and threatened 

species, candidate species, and species of concern for Lea County (USFWS, 2010b; USFWS, 

2010c). The Northern aplomado falcon (Falco femoralis septentrionalis), the black-footed ferret 

(Mustela nigripes), and the least tern (Sterna antillarum athalassos) are listed as Federally 

endangered species occurring in Lea County (USFWS, 2010b; NMGF, 2010b). 

Candidate species are those that the USFWS has sufficient information to propose that they be 

added to the Federal list of threatened and endangered species, but the listing action has been 

precluded by other higher priority listing activities. Two candidate species are listed as 

potentially occurring in Lea County: the lesser prairie-chicken and the dunes sagebrush lizard. 

On December 14, 2010, the USFWS issued a proposal to list the dunes sagebrush lizard as a 

Federally endangered species (USFWS, 2010d). The USFWS also maintains a list of species 

of concern, however, these species are not protected by law. There are eight Federal species 
 3-57 

 
 3-58 

of concern in Lea County: black-tailed prairie dog (Cynomys ludovicianus), swift fox (Vulpes 

velox), American peregrine falcon (Falco peregrinus anatum), arctic peregrine falcon (Falco 

peregrinus tundrius), Baird’s sparrow (Ammodramus bairdii), Bell’s vireo (Vireo bellii), western 

burrowing owl (Athene cunicularia hypugaea), and the yellow-billed cuckoo (Coccyzus 

americanus) (USFWS, 2010b). 

Based on the best available information, the swift fox and western burrowing owl could occur on 

or visit the proposed site. It is unlikely that the dunes sagebrush lizard (GL Environmental, 

2010d) or the lesser prairie-chicken (SORA, 2011) would occur at the site. The black-tailed 

prairie dog has not been reported as occurring within Lea County; and the American peregrine 

falcon, arctic peregrine falcon, and Baird’s sparrow have been reported only rarely or very rarely 

in Lea County. No preferred habitat for the Northern aplomado falcon, least tern, black-footed 

ferret, Bell’s vireo, or yellow-billed cuckoo occurs on the proposed site. 

Endangered, threatened, candidate species, and species of concern listed by the USFWS and 

the State of New Mexico for Lea County are described in the following sections and presented 

in Table 3-18. 

Table 3-18. Rare, Threatened or Endangered Species Listed for Lea County, New 

Mexico 

Common Name Scientific Name 

Federal 

Statusa

State 

Statusa

Mammals 

Black-footed ferret Mustela nigripes E2 - 

Black-tailed prairie dog Cynomys ludovicianus S2 - 

Swift fox Vulpes velox S1 - 

Birds 

American peregrine falcon Falco peregrinus anatum S2 T1

Arctic peregrine falcon Falco peregrinus tundrius S2 T1

Baird’s sparrow Ammodramus bairdii S2 T1

Mammals 

Bald eagle Haliaeetus leucocephalus - T1

Bell’s vireo Vireo bellii S2 T1

Broad-billed hummingbird Cynanthus latirostris magicus - T1

Least ternb Sterna antillarum athalassos E1 E1

Lesser prairie-chicken Tympanuchus pallidicinctus C2 - 

Northern aplomado falcon Falco femoralis septentrionalis E2 E1

Western burrowing owl Athene cunicularia hypugaea S2 - 

Yellow-billed cuckoo Coccyzus americanus S2 - 

Amphibians/Reptiles 

Dunes sagebrush lizard Sceloporus arenicolus PE3 E1

Sources: 1 NMGF, 2010b; 2 USFWS, 2010b; 3 USFWS, 2010d a C = Candidate, E = Endangered, T = Threatened, S = Species of Concern, PE = Proposed Endangered, - = Not 

listed. b

 The least tern is not listed by the USFWS as occurring in Lea County, however, it is listed by the New Mexico 

Department of Game and Fish as occurring in Lea County. 
 3-59 

3.8.7.1 Federally Endangered Species 

Northern Aplomado Falcon 

The Northern aplomado falcon is listed as both a Federal and State endangered species. The 

preferred habitat in New Mexico for this species consists of open yucca desert land from the Rio 

Grande westward and north to Deming and Separ. The few nests known to occur in New 

Mexico were in areas of yucca grassland (USGS, 2005b; NMGF, 2010c). This habitat does not 

occur on the proposed site. 

Black-Footed Ferret 

The black-footed ferret is a Federally listed endangered species, but is not listed by the State of 

New Mexico. The historic range of the black-footed ferret included all of New Mexico; however, 

it was extirpated from most of its range, including New Mexico, by the 1960s. Black-footed 

ferrets are being reintroduced to their historic range, and the State of New Mexico has pursued 

reintroduction efforts (USFWS, 2008). The black-footed ferret is limited to open habitat, the 

same habitat used by prairie dogs: grasslands, steppe, and shrub steppe. The black-footed 

ferret has co-evolved with the prairie dog; their ranges and habitat closely overlap; however, the 

prairie dog has fewer protective regulations than the ferret (USFWS, 2008; USGS, 2005b). The 

preferred habitat does not occur on the proposed site. 

Least Tern 

The least tern is Federally listed as endangered and is also listed as endangered by the State of 

New Mexico. Its historic distribution was coincident with the major river systems of the Midwest 

as its habitat includes barren shorelines of lakes, rivers, and reservoirs (USGS, 2005b). The 

least tern has not been documented in Lea County, but has been reported as a migrant in Eddy 

County, just west of the proposed site, and has been documented breeding at Bitter Lake 

National Wildlife Refuge in Chaves County, approximately 161 km (100 mi) northwest of the 

proposed site (NMGF, 2010c; USGS, 2005b). No rivers, lakes, or reservoirs occur on the site; 

therefore, no habitat for this species is present on the proposed site. 

3.8.7.2 Federally Proposed Endangered Species 

Dunes Sagebrush Lizard 

On December 14, 2010, the USFWS issued a proposal to modify the listing of the dunes 

sagebrush lizard from its current status as a Federal candidate species to that of endangered; 

this species is already listed as endangered by the State of New Mexico (USFWS, 2010c). 

The range of the dunes sagebrush lizard within New Mexico appears to be confined to areas of 

active sand dunes vegetated by shinnery oak (Quercus havardii) in the extreme southeastern 

portion of the state and adjoining areas of Texas; although adjacent open habitats may be used 

in some places (NMGF, 2010c). The range stretches from eastern Chaves County, 

southernmost Roosevelt, and northernmost Lea Counties, southward and eastward into 

northeastern Eddy and south/central Lea counties. The closest part of the range lies 11.9 km 

(7.4 mi) south of the boundary of the facility site (Figure 3-20) (BLM, 2008; Center for Biological 

Diversity, 2002). Shinnery oak and sand dunes do not occur on the proposed IIFP site and; 

therefore, it is unlikely for the dunes sagebrush lizard to occur at the proposed site 

(GL Environmental, 2010d). 
 3-60 

3.8.7.3 Federal Candidate Species 

Lesser Prairie-Chicken 

The lesser prairie-chicken is a candidate species for Federal protection due to habitat loss 

(USGS, 2005b). See Section 3.8.6.3 for a discussion on the BLM Lesser Prairie-Chicken ACEC 

and proposed Lesser Prairie-Chicken Expansion Corridor. 

Lesser prairie-chickens are most common in dwarf shrub-mixed grass vegetation, interspersed 

with short-grass or mixed-grass habitats. They are also found in shinnery oak and bunch 

sumac and squaw bush (USGS, 2005b). Lea County is historically known to have habitat for 

lesser prairie-chickens, but the proposed site is at the southern periphery of their range 

(BLM, 2010; SORA, 2011). The IIFP site could provide suitable habitat for the lesser prairiechicken, though there are limited water sources on the site (SORA, 2011). 

3.8.7.4 Federal Species of Concern 

American Peregrine Falcon 

The American peregrine falcon is Federal species of concern and is listed as threatened by the 

State of New Mexico. It breeds in mountain areas and migrates essentially statewide; however, 

this species has only been reported rarely in Lea County (NMGF, 2010b). 

Arctic Peregrine Falcon 

The arctic peregrine falcon is a Federal species of concern and is listed as threatened by the 

State of New Mexico. This species is migratory and is found in a variety of habitats including 

forests, grasslands, and the Chihuahuan Desert Scrub (NMGF, 2010c). It is a very rare migrant 

through the State of New Mexico, but was reported in Lea County in 2007 (NMGF, 2010b). 

Baird’s Sparrow 

The Baird’s sparrow is a Federal species of concern and is listed as threatened by the State of 

New Mexico. Found in a variety of habitats ranging from desert grasslands to prairies and 

mountain meadows, the Baird’s sparrow is a transient species in eastern and southern New 

Mexico and is considered rare to uncommon in Lea County (NMGF, 2010b). 

Bell’s Vireo 

Bell’s vireo is a Federal species of concern and is listed as threatened by the State of New 

Mexico. It winters south of the Mexican border and is a rare summer resident in Lea County 

(NMGF, 2010b). In New Mexico, this species occurs in riparian and wooded lowland habitats 

(NMGF, 2010c), none of which occur on the proposed site. 

Black-Tailed Prairie Dog 

The black-tailed prairie dog is a Federal species of concern, but it is not listed by the State of 

New Mexico. The black-tailed prairie dog commonly occurs in shortgrass prairie habitats 

(USGS, 2005b; NMGF, 2010c). However, it has not been reported in Lea County (NMGF, 

2010b). 
 3-61 

Swift Fox 

The swift fox is a Federal species of concern, but it is not listed by the State of New Mexico. It 

is a year-round resident throughout the State, inhabiting shortgrass, midgrass and mixed 

prairies and adapting to overgrazed pastures, plowed fields, and fencerows (NMGF, 2010c). 

Western Burrowing Owl 

The Western burrowing owl is a Federal species of concern, but it is not listed by the State of 

New Mexico. Habitats include well-drained grasslands, prairies, steppes, deserts, and 

agricultural lands. The owls normally migrate south in late fall, but may not migrate if there are 

abandoned mammal burrows, which the owl uses for nests (NMGF, 2010c). This species has 

been reported only in the summer in Lea County; however, it has been documented as a year 

round resident in southern New Mexico (USGS, 2005b; NMGF, 2010c). 

Yellow-Billed Cuckoo 

The yellow-billed cuckoo population in eastern New Mexico is listed as a Federal species of 

concern, while the population in western New Mexico is a Federal candidate species; but it is 

not listed by the State of New Mexico. Yellow-billed cuckoos are often associated with riparian 

forests and deciduous woodlands (USGS, 2005b; NMGF, 2010c). They have been reported to 

occur in Lea County during the fall (USGS, 2005b; NMGF, 2010b). 

3.8.7.5 New Mexico Threatened Species 

Bald Eagle 

The bald eagle was removed from the Federal endangered and threatened species list in 2007; 

however, it remains listed as threatened by the State of New Mexico and it still receives 

protection under the Bald and Golden Eagle Protection Act, Lacey Act, and Migratory Bird 

Treaty Act. It is a rare visitor to Lea County (NMGF, 2010b). 

Broad-billed Hummingbird 

The broad-billed hummingbird is listed as a threatened species by the State of New Mexico. It 

is rare in Eddy County (adjacent to Lea County) and is not known to occur in Lea County. It is 

usually associated with riparian woodlands (NMGF, 2010c), none of which occur on the 

proposed site. 

3.9 Socioeconomics and Environmental Justice 

This section describes the socioeconomic resources that have the potential to be affected by 

the construction and operation, and decommissioning of the IIFP facility at a rural site near 

Hobbs, New Mexico. The section is divided into six major subsections: (1) demography, 

including minority and low-income populations (environmental justice); (2) employment and 

income; (3) taxes; (4) housing; (5) public utilities; and (6) public services. These subsections 

include discussions of spatial (e.g., regional, vicinity, and site) and temporal (e.g., 10-year 

increments of population growth) considerations, where appropriate. Supporting analyses are 

provided in Appendix D – Socioeconomics. 
 3-62 

NRC staff collected and analyzed regional socioeconomic data, including the commuting points 

of origin and destination of all workers among Lea County and its neighboring counties, to 

determine the appropriate socioeconomic ROI. 

The NRC staff considered counties with their land area mostly within the 80-km (50-mi) radius of 

the site, or with a small portion of the area within the 80-km (50-mi) radius, but with a large 

population center within the 80-km (50-mi) radius, which was assumed to be a reasonable 

commuting distance. Two counties in New Mexico and three counties in Texas have these 

characteristics: Lea County and Eddy Counties, in New Mexico, and Andrews, Gaines, and 

Yoakum Counties in Texas. 

Commuting patterns of working residents in Lea County demonstrate a preference for a work 

site in Lea County, and residents of the surrounding counties have demonstrated a reluctance 

to drive to a worksite in Lea County. However, Carlsbad and the Waste Isolation Pilot Plant are 

in Eddy County, approximately 80 km (50 mi) from the proposed site, and some residents with 

the appropriate skill set for the IIFP facility may commute to the proposed IIFP facility. Despite 

the limited employment opportunities in Andrews, Gaines, and Yoakum Counties, few residents 

of those counties work in Lea County, even with its larger employment base. Therefore, it is 

reasonable to assume that most of the IIFP workforce will come from Lea or Eddy Counties. 

Changes in population are the key driver of impacts to socioeconomics. Therefore, the 

proposed action has the potential to impact socioeconomics (employment, population, income, 

housing, infrastructure, and community services) within Lea and Eddy Counties, because those 

are the counties most likely to incur population increases due to the proposed action, and it is 

unlikely to affect socioeconomic variables in the Texas counties. 

Based on this analysis, NRC staff assumes that the socioeconomic ROI for this project is Lea 

and Eddy Counties, New Mexico. The majority of the socioeconomic impacts would be 

expected to occur in Lea County because the proposed IIFP site is in Lea County, and 

because of Lea County’s population characteristics, commuting patterns, and amenities. See 

Figure 3-21 for the counties and major populated areas within the ROI. 

3.9.1 Demography 

3.9.1.1 Populations within the Socioeconomic ROI 

The socioeconomic ROI comprises Lea and Eddy Counties, New Mexico. The proposed IIFP 

site would be in unincorporated Lea County, New Mexico. The nearest population center, 

Hobbs, is approximately 22.5 km (14 mi) east of the proposed site. The nearest residence is 

approximately 2.6 km (1.6 mi) northwest of the proposed site (Figure 3-2). 

Table 3-19 lists selected population characteristics of the counties in the ROI, and for 

comparison, New Mexico. Population characteristics, including race, ethnicity, and population 

density of the counties in the ROI broadly reflect those same characteristics in New Mexico. 

The ROI 2009 estimated population of 112,938 is about 5.6 percent of the 2009 estimated New 

Mexico population (Table 3-19). The racial and Hispanic demographics of the ROI residents 

generally reflect the racial and Hispanic demographics of residents in New Mexico as a whole. 

However, the ROI has a noticeably greater percentage than the state of persons who identified 

themselves as of the white race and a markedly smaller percentage of persons who identified 

themselves as “American Indian and Alaskan Native.” Both ROI counties are sparsely 

populated, as is New Mexico. New Mexico’s average density is 15 persons per square mile, 
 3-63 

 
 3-64 

Table 3-19. Select Population Characteristics of Counties within the ROI and the State 

of New Mexico 

New Mexico Lea County 

Eddy 

County 

Population, 2009 estimatea 2,009,671 60,232 52,706 

White, percent 83.6 90.5 93.5 

Black, percent 3.1 5.8 2.5 

American Indian and Alaskan Native, percent 9.7 1.4 1.6 

Asian, percent 1.5 0.7 0.8 

Native Hawaiian and other Pacific Islander, percent 0.2 0.1 0.2 

Two or more races, percent 1.9 1.5 1.4 

Hispanic or Latino Origin, percentb 45.6 49.6 43.4 

Average Family Size, 2008c 3.23 2.93 3.04 

Land Area, 2000, square milea 121,356 4,393 4,182 

Persons per square mile, 2000a 15.0 12.6 12.4 

Source: 

a

USCB, 2010a 

b

Hispanics may be of any race, so are also included in applicable race categories 

c

USCB, 2010b 

and Lea and Eddy counties’ densities are between 12 and 13 persons per square mile. The 

average density in the United States is about 80 persons per square mile (USCB, 2010a). The 

average family size in Lea County (2.93 people) and in Eddy County (3.04 people) is smaller 

than the average family size in New Mexico (3.23 people) (USCB, 2010b). 

Table 3-20 provides 2009 estimated population information for Lea and Eddy Counties and their 

incorporated municipalities. In 2009, the population of Lea County was estimated to be 60,232 

(USCB, 2010c). Slightly more than half of the county’s population resides in Hobbs, the largest 

municipality in the county (USCB, 2010d). Hobbs is the largest city in southeastern New Mexico 

and serves as a commercial center for the population within the 80-km (50-mi) radius of the 

proposed site. The Lea County seat, Lovington, had an estimated 2009 population of 10,108 

(USCB, 2010d). Other incorporated communities in the county include Eunice, Jal, and Tatum. 

Tables 3-21 and 3-22 provide historic populations, population estimates, and population 

projection data, including average annual growth rates, for the counties in the ROI, and for 

comparison, New Mexico. Historically, the population growth rates in the ROI counties have 

generally lagged the population growth rate of New Mexico. The projected population growth 

rates for the counties also lag the projected growth rates for the state. 

In 2009, the Eddy County population was estimated to be 52,706 (USCB, 2010a). Carlsbad, the 

county seat, is the largest city in the county with approximately half of the county population 

(USCB, 2010d). Northeastern sections of Carlsbad are within 80 km (50-mi) of the proposed 

site (Figure 3-1) but most of the town is just outside the 80-km (50-mi) radius. Other 

incorporated communities in Eddy County include Artesia, Hope, and Loving. 
 3-65 

Table 3-20. Population Estimates of ROI Counties and Incorporated Municipalities, 

2009 

Political Jurisdiction 

2009 Estimated 

Population 

Percent of County 

Population 

Lea Countya 60,232 -- 

Euniceb 2,809 4.7 

Hobbsb 30,838 51.2 

Jalb 2,074 3.4 

Lovingtonb 10,108 16.8 

Tatumb 767 1.3 

Eddy Countya 52,706 -- 

Artesiab 11,338 21.5 

Carlsbadb 26,259 49.8 

Hopeb 109 0.2 

Lovingb 1,366 2.6 

Source: 

a

USCB, 2010c 

b

USCB, 2010d 

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

Political Jurisdiction 1990a 2000b 2009b

New Mexico 1,515,069 1,819,046 2,009,671 

Lea County 55,765 55,511 60,232 

Eddy County 48,605 51,658 52,706 

Average Annual Growth Rate 

Political Jurisdiction 1990 to 2000a,b 2000 to 2009b

New Mexico 1.85% 1.11% 

Lea County -0.05% 0.91% 

Eddy County 0.61% 0.22% 

Source: 

a

USCB, 2000b 

b

USCB, 2010c 

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

Political 

Jurisdiction 2005a

 2010a 2020a 2030a 2035a

New Mexico 1,969,292 2,162,331 2,540,145 2,864,796 3,018,289 

Lea County 57,006 60,896 67,479 72,928 75,716 

Eddy County 52,167 54,145 58,294 60,764 61,605 

Average Annual Growth Rate 

Area 2005 to 2010 2010 to 2020 2020 to 2030 2030 to 2035 

New Mexico 1.89% 1.62% 1.21% 1.05% 

Lea County 1.33% 1.03% 0.78% 0.75% 

Eddy County 0.75% 0.74% 0.42% 0.28% 

Source: BBER, 2008 

a

Population projections are built on slightly different base year numbers than those presented in Table 3-22. 
 3-66 

3.9.1.2 Environmental Justice: Minority and Low Income Populations 

3.9.1.2.1 Methodology 

On February 11, 1994, the President signed Executive Order 12898, “Federal Actions to 

Address Environmental Justice in Minority Populations and Low-Income Populations,” which 

directs all Federal agencies to develop strategies that consider environmental justice in their 

programs, policies, and activities. Environmental justice is described in the Executive Order as 

“identifying and addressing, as appropriate, disproportionately high and adverse human health 

or environmental effects of its programs, policies, and activities on minority populations and lowincome populations.” On December 10, 1997, the Council on Environmental Quality (CEQ) 

issued Environmental Justice Guidance under the National Environmental Policy Act (CEQ, 

1997). The NRC has provided general guidelines on the evaluation of environmental analyses 

in Environmental Review Guidance for Licensing Actions Associated with NMSS [Nuclear 

Material Safety and Safeguards] Programs (NUREG-1748) (NRC, 2003), and issued a final 

policy statement on the Treatment of Environmental Justice Matters in NRC Regulatory and 

Licensing Actions (69 FR 52040) and environmental justice procedures to be followed in NEPA 

documents prepared by the NRC’s Office of Nuclear Material Safety and Safeguards (NMSS). 

NRC’s NMSS environmental justice guidance, as found in Appendix C to NUREG-1748 (NRC, 

2003), recommends that the area for assessment for a facility in a rural area be a circle with a 

radius of approximately 6.4 km (4 mi) whose centroid is the facility being considered. However, 

the guidance also states that the scale should be commensurate with the potential impact area. 

Therefore to ensure consistency with the accident analysis, which considers airborne impacts to 

populations within an 80-km (50-mi) radius, the NRC staff concludes that an environmental 

justice assessment area with an 80-km (50-mi) radius would be appropriate. As such, New 

Mexico and Texas and each county with some land area within the 80-km (50-mi) radius of the 

proposed IIFP site (i.e., centroid of Section 27) are appropriate areas for comparative analysis. 

A minority or low-income community may be considered as either a population of individuals 

living in geographic proximity to one another or a dispersed/transient population of individuals 

(e.g., migrant workers) where either type of group experiences common conditions of 

environmental exposure (NRC, 2003). NUREG-1748 defines minority categories as: American 

Indian or Alaskan Native, Asian, Native Hawaiian or other Pacific Islander, African American 

(not of Hispanic or Latino origin), some other race, and Hispanic or Latino ethnicity (of any race) 

(NRC, 2003). The 2000 Census introduced a multiracial category. Anyone who identifies 

themselves as white and a minority is counted as that minority group. Individuals that identify 

themselves as more than one minority are counted in a "two or more races" group (NRC, 2003). 

Low-income is defined as being below the poverty level as defined by the U.S. Census Bureau 

(NRC, 2003). 

The NRC-recommended area for evaluating census data is the census block group, which is 

delineated by the United States Census Bureau and is the smallest area unit for which race and 

poverty data are available (NRC, 2003). The NRC staff used ESRI ArcGIS® 9.3 software which 

accessed the 2000 decennial census, to identify block groups with low-income or minority 

populations within 80 km (50 mi) of the proposed IIFP site. NRC staff included a block group if 

any part of its fell within 80 km (50 mi) of the proposed site; 96 block groups were identified as 

being within, or partially within the 80-km (50-mi) radius. 

NRC guidance indicates that a significant minority or low-income population exists if at least one 

of these conditions exists: 
 3-67 

The minority or low-income population of the block group is more than 50 percent of the entire 

block group population. 

The minority or low-income population percentage of the block group is significantly greater 

(typically at least 20 percentage points) than the minority or low-income population percentage 

in the geographic areas chosen for comparative analysis. 

3.9.1.2.2 Minority Populations 

Using the U.S. Census Bureau (USCB) 2000 census data, NRC staff calculated (1) the 

percentage of each block group’s population represented by each minority category for each of 

the 96 block groups within the 80 km (50-mi) radius, (2) the percentage that each minority 

category represented of the entire populations of New Mexico and Texas, and (3) the 

percentage that each minority category represented of each of the counties that has some land 

within the 80-km (50-mi) radius of the proposed site. If the percentage of any minority in any 

block group exceeded 50 percent of the block group’s total population or exceeded the 

minority’s corresponding county or state percentages by more than 20 percent, then that block 

group was identified as having a significant minority population. 

Table 3-23 identifies the number of block groups that met the 50 percent criterion or the morethan-20-percent criterion (some block groups may meet both criteria) for their corresponding 

state and/or county. If a block group met one or both of the criterion for either the state or the 

county, it was not double-counted. Of the 96 census block groups within the 80-km (50-mi) 

radius, 16 have a significant percentage of minority residents. Thirty-two block groups have a 

significant percentage of Hispanic ethnicity residents. Figures 3-22 through 3-24 provide 

graphical representations of the data presented in Table 3-23. 

Seasonal agricultural (migrant) workers may make up a portion of the minority population within 

the 80-km (50-mi) radius. Although migrant worker population counts are not available from the 

USCB, the U.S. Department of Agriculture has collected information on farms that employ 

migrant labor. The number of farms that employ migrant laborers in each county which falls 

wholly or partially within the 80-km (50-mi) radius are: in New Mexico Lea County (9), Eddy 

County (12), and Chaves County (19) and in Texas Loving County (1), Winkler County (2), 

Andrews County (2), Gaines County (27), Yoakum County (9), Terry County (26), and Cochran 

County (15 ) (USDA, 2007). The number of these farms which fall wholly or partially within the 

80-km (50-mi) radius is not known. 

There are no Federally recognized Native American reservations within the 80-km (50-mi) 

radius of the proposed IIFP site (NPS, Undated). 

3.9.1.2.3 Low-Income Populations 

The NRC guidance defines low-income households based on statistical poverty thresholds 

(NRC, 2003). 

Using the USCB 2000 census data, NRC staff calculated the percentage of each block group’s 

population represented by low-income households for each of the 96 block groups within the 

80 km (50-mi) radius, and the percentage of low-income households in New Mexico and Texas 

and in each of the counties that had some land within the 80-km (50-mi) radius of the site. If the 

percentage of any low-income block group exceeded 50 percent of the block group’s total 

population or exceeded the corresponding county or State low-income percentages by more 
 3-68 

 
 3-69 

 
 3-70 

 
 3-71 

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

 Significant Minority or Low-Income Populations (Meeting 50 Percent 

 Criteria or Exceeding Respective County or State Percentages by 20 

 Percent) 

County 

Name 

Number 

of Block 

Groups 

African 

American 

American 

Indian or 

Alaskan 

Native Asian 

Native 

Hawaiian 

or Other 

Pacific 

Islander 

Some 

Other 

Race 

Two 

or 

More 

Races 

Hispanic 

Ethnicity 

LowIncome 

Households 

Chaves 2 0 0 0 0 0 0 1 0 

Eddy 3 0 0 0 0 0 0 1 0 

Lea 64 1 0 0 0 14 0 24 10 

Andrews 3 0 0 0 0 0 0 0 0 

Cochran 1 0 0 0 0 0 0 0 0 

Gaines 13 0 0 0 0 0 0 3 0 

Loving 1 0 0 0 0 0 0 0 0 

Terry 1 0 0 0 0 0 0 0 0 

Winkler 1 0 0 0 0 0 0 0 0 

Yoakum 7 0 0 0 0 1 0 3 0 

Total 96 1 0 0 0 15 0 32 10 

State/County 

African 

American 

(%) 

American 

Indian or 

Alaskan 

Native 

(%) 

Asian 

(%) 

Native 

Hawaiian 

or Other 

Pacific 

Islander 

(%) 

Some 

Other 

Race 

(%) 

Two 

or 

More 

Races 

(%) 

Hispanic 

Ethnicity 

(%) 

LowIncome 

Households 

(%) 

New Mexico (State) 1.89 9.54 1.06 0.08 17.04 3.65 42.08 16.78 

Chaves County 1.97 1.13 0.53 0.06 21.25 3.12 43.83 19.12 

Eddy County 1.56 1.25 0.45 0.09 17.67 2.64 38.76 16.72 

Lea County 4.37 0.99 0.39 0.04 23.81 3.27 39.65 19.90 

Texas (State) 11.53 0.57 2.70 0.07 11.69 2.47 31.99 13.98 

Andrews County 1.65 0.88 0.71 0.02 16.79 2.87 40.00 16.74 

Cochran County 4.53 0.83 0.21 0.05 27.35 2.55 44.13 21.67 

Gaines County 2.28 0.76 0.15 0.01 14.17 2.35 35.77 19.08 

Loving County 0.00 0.00 0.00 0.00 8.96 1.49 10.45 0.00 

Terry County 5.00 0.53 0.22 0.02 14.28 3.40 44.09 20.53 

Winkler County 1.85 0.45 0.20 0.00 20.35 2.34 44.00 18.58 

Yoakum County 1.39 0.71 0.12 0.01 25.48 1.65 45.93 18.20 

Source: USCB, 2000a; USCB, 2000b; USCB, 2000c; USCB, 2000d; USCB, 2000e; USCB, 2000f; 

than 20 percent, then that block group was identified as having a significant low-income 

population. Again, if the block group met one or both criteria, for either the state or county, it 

was not double-counted. 

Table 3-23 lists the number of block groups in each county within the 80-km (50-mi) radius that 

meets the 50 percent criterion or the more than 20 percent criterion for its corresponding State 

or county. Ten census block groups within the 80-km (50-mi) radius have a significant 

percentage of low-income households. Figure 3-25 locates the low-income block groups. 
 3-72 

 
 3-73 

3.9.2 Employment and Income 

3.9.2.1 Employment 

Table 3-24 summarizes employment trends in the ROI from 2001 to 2008. From 2001 to 2008, 

growth in employment in the ROI was greater than population growth. The number of jobs in 

the ROI grew from 54,649 (29,463 for Lea County plus 25,186 for Eddy County) in 2001(BEA, 

2011a; BEA, 2011b) to 68,314 in 2008 (BEA, 2010), an increase of 25 percent. The ROI 

population increased from 105,562 to 110,903 (59,129 for Lea County plus 51,774 for Eddy 

County) (USCB, 2010c), an increase of 5 percent. Within the ROI, 2008 employment was 

dominated by jobs in mining (20.6 percent), government and government enterprises 

(10.4 percent), retail trade (10.1 percent), and construction (8.3 percent). With the exception of 

employment in farming, a sector that represents less than 0.5 percent of all jobs in the ROI, the 

number of jobs in all industrial sectors grew from 2001 to 2008 (BEA, 2010). A major employer 

in the ROI is the DOE’s Waste Isolation Pilot Plant, in Eddy County. Nearly 600 individuals are 

employed at the facility (ECP, 2008). From 2001 to 2008, the ROI unemployment rate 

decreased from 4.6 to 3.0 percent. However, from 2008 to June of 2010, the rate increased 

from 3.0 to 7.0 percent. 

Table 3-25 presents information about labor statistics in the ROI, and for comparison, New 

Mexico. The size of the ROI labor force grew from 47,199 to 57,708 (22.3 percent) between 

2001 and 2008, but shrank in 2009 to 57,590 and declined again in 2010, to 56,945 

(BLS, 2010a). The unemployment rate in the ROI has consistently remained below the 

unemployment rate in the State. As a point of comparison, the unemployment rate in the United 

States in June 2010 was 9.6 percent (BLS, 2010b). 

3.9.2.2 Income 

Table 3-26 presents income statistics for the ROI counties, their major population centers, and 

New Mexico. In 2008, various measures of income in Eddy County were higher and the rates of 

poverty in Eddy County lower than in New Mexico. With the exception of median household 

income, the various measures of income in Lea County were lower and the rates of poverty 

higher in Lea County than in New Mexico. In 2008, the poverty threshold ranged from $10,326 

to $47,915, depending on family characteristics. Families and individuals residing in Lea 

County were more likely to be living below the poverty level than those living in Eddy County. 

3.9.3 Taxes 

3.9.3.1 Income Taxes 

Corporate Income Taxes 

New Mexico imposes a corporate income tax on the total net income (including New Mexico and 

non-New Mexico income) of every domestic and foreign corporation doing business in or from 

the State, or which has income from property or employment within the State. The percentage 

of New Mexico income is then applied to the gross tax. For corporations with a total net income 

exceeding $1,000,000 annually, corporate income tax is $56,000 plus 7.6 percent of net income 

over $1,000,000 (NMTRD, 2010a). 

New Mexico also levies a corporate franchise tax of $50 per year (NMTRD, 2010a). 
3-74 

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

Lea 

County 

2001a

Lea 

County 

2008b

Lea 

County, 

Percent 

Change, 

2001 to 

2008 

Eddy 

County 

2001c

Eddy 

County 

2008b

Eddy 

County, 

Percent 

Change, 

2001 to 

2008 

ROI 

Jobs 

2008 

ROI, 

Percent 

Change in 

Jobs, 2001 

to 2008 

Total Employment 29,463 37,622 27.7% 25,186 30,692 21.9% 68,314 25.0% 

Farm Employment 1,026 725 -29.3% 975 798 -18.2% 1,523 -23.9% Nonfarm Employment 28,437 36,897 29.7% 24,211 29,894 23.5% 66,791 26.9% Private Employment 24,622 33,176 34.7% 20,604 26,007 26.2% 59,183 30.9% Forestry, fishing, and related activities 108 101 -6.5% 163 177 8.6% 278 2.6% Mining 5,484 8,339 52.1% 3,042 4,585 50.7% 12,924 51.6% Utilities 247 489 98.0% 134 145 8.2% 634 66.4% Construction 2,131 3,460 62.4% 1,506 2,597 72.4% 6,057 66.5% Manufacturing 428 805 88.1% 897 922 2.8% 1,727 30.3% Wholesale Trade 1,199 1,255 4.7% 555 669 20.5% 1,924 9.7% Retail Trade 3,371 3,393 0.7% 2,972 3,126 5.2% 6,519 2.8% Transportation and Warehousing 996 1,588 59.4% 972 1,097 12.9% 2,685 36.4% Information 251 382 52.2% 345 309 -10.4% 691 15.9% Finance and Insurance 722 879 21.7% 701 909 29.7% 1,788 25.7% Real Estate and Rental and Leasing 779 1,130 45.1% 645 890 38.0% 2,020 41.9% Professional, Scientific, and Technical Services 603 1,019 69.0% 715 1,315 83.9% 2,334 77.1% Management of Companies and Enterprises 121 137 13.2% 54 219 305.6% 356 103.4% Administrative and Waste Services 1,446 2,039 41.0% 1,563 1,924 23.1% 3,963 31.7% Educational Services (D) (D) NA 97 118 21.6% NA NA Health Care and Social Assistance (D) (D) NA 2,450 2,835 15.7% NA NA 
3-75 

Table 3-24. Employment in ROI, by Industry, 2001 to 2008 (Continued) 

Lea 

County 

2001a

Lea 

County 

2008b

Lea County, 

Percent 

Change, 

2001 to 2008 

Eddy 

County 

2001c

Eddy 

County 

2008b

Eddy 

County, 

Percent 

Change, 

2001 to 2008

ROI 

Jobs 

2008 

ROI, 

Percent 

Change in 

Jobs, 2001 

to 2008 

Arts, Entertainment, and Recreation 219 605 176.3% 208 207 -0.5% 812 90.2% Accommodation and Food Services 1,685 2,200 30.6% 1,898 2,175 14.6% 4,375 22.1% Other Services, except Public Administration 1,652 1,921 16.3% 1,687 1,788 6.0% 3,709 11.1% Government and Government Enterprises 3,815 3,721 -2.5% 3,607 3,887 7.8% 7,608 2.5% Federal, Civilian 119 105 -11.8% 488 764 56.6% 869 43.2% Military 178 160 -10.1% 165 139 -15.8% 299 -12.8% State and Local 3,518 3,456 -1.8% 2,954 2,984 1.0% 6,440 -0.5% State Government 286 289 1.0% 741 750 1.2% 1,039 1.2% Local Government 3,232 3,167 -2.0% 2,213 2,234 0.9% 5,401 -0.8% 

Source: aBEA, 2010 bBEA, 2011b cBEA, 2011a 

NA Not Applicable (D) Information not shown (by BEA) to avoid disclosure of confidential information, but estimates for this item are included in the totals 
 3-76 

Table 3-25. Labor Statistics, ROI and New Mexico, 2001 to 2010 

Lea County Eddy County ROI New Mexico 

2001 (annualized) Labor Force 23,702 23,497 47,199 863,682 

2008 (annualized) Labor Force 29,895 27,813 57,708 961,259 

2009 (annualized) Labor Force 28,890 28,700 57,590 955,904 

2010 (June) Labor Force 28,103 28,842 56,945 962,423 

Percent Change 2001 to 2008 26.1% 18.4% 22.3% 11.3% 

Percent Change, 2001 to 2010 18.6% 22.7% 20.6% 11.4% 

2001 Unemployment Rate 4.3% 5.0% 4.6% 4.9% 

2008 Unemployment Rate 2.9% 3.1% 3.0% 4.5% 

2009 Unemployment Rate 7.6% 5.5% 6.6% 7.2% 

June, 2010 Unemployment Rate 8.0% 6.1% 7.0% 8.5% 

Source: BLS, 2010a 

Table 3-26. Income Statistics, ROI Counties and Population Centers, and New Mexico, 

2008a

Lea County Eddy County New Mexico 

Median Household Income $43,638 $45,858 $43,202 

Median Family Income $47,853 $57,658 $51,724 

Per Capita Income $20,319 $25,151 $22,781 

Families below Poverty level, percent 15.7 10.2 13.7 

Individuals below Poverty Level, percent 18.9 14.4 17.9 

Source: USCB, 2010b 

a

All dollar values are expressed in 2008 inflation-adjusted dollars 

Individual Income Taxes 

New Mexico imposes an individual income tax on the net income of every resident and 

nonresident employed or engaged in business in or from the State or deriving any income from 

any property or employment within the State. The rates vary depending upon filing status and 

income. 

The top tax bracket is 4.9 percent (NMTRD, 2010b).

3.9.3.2 Sales Tax/Gross Receipts Tax 

New Mexico is one of a minority of states that has a gross receipts tax structure instead of a 

sales tax structure. Gross receipts are the total amount of money or value of other 

considerations received from (NMTRD, 2011): 

• Selling property in New Mexico 

• Leasing or licensing property used in New Mexico 

• Granting a right to use a franchise used in New Mexico 
 3-77 

• Performing services in New Mexico 

• Selling research and development services performed outside New Mexico, the 

product of which is initially used in New Mexico 

Although the gross receipts tax is imposed on businesses, it is common for a business to pass 

the gross receipts tax on to the purchaser either by separately stating it on the invoice or by 

combining the tax with the selling price (NMTRD, 2011). 

The gross receipts tax rate varies throughout the state from 5.125 percent to 8.6875 percent, 

depending on the location of the business. It varies because the total rate combines rates 

imposed by the state, counties, and, if applicable, municipalities where the businesses are 

located. The business pays the total gross receipts tax to the state, which then distributes the 

counties' and municipalities' portions to them (NMTRD, 2011). 

The current gross receipts taxes in Lea and Eddy Counties are presented in Table 3-27. 

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

Lea County Ratesa Eddy County Rates 

Eunice 6.8125% Artesia 7.1875% 

Hobbs 6.8125% Carlsbad 7.4375% 

Jal 6.8125% Hope 6.6250% 

Lovington 6.8750% Loving 6.8125% 

Lovington Industrial Park 5.5% Remainder of County 5.75% 

Tatum 6.8125% -- -- 

Remainder of County 5.5% -- -- 

Source: NMTRD, 2011 

a

 Rates include State, county, and municipal gross receipts taxes, combined 

3.9.3.3 Property Taxes 

Four governmental entities in New Mexico are authorized to tax: the state, counties, 

municipalities, and school districts (NRC, 2005). Property assessment rates are 33.3 percent of 

appraised values (NRC, 2005; Eddy County, 2007). The tax applied to the assessed property 

value is a combination of state, county, municipal, and school district levies (NRC, 2005). The 

Lea County tax rate for nonresidential property outside the city limits of Hobbs is $24.949 per 

$1,000 of net taxable value of a property (Lea County, 2009). Rates for nonresidential 

properties are higher within the city limits of Hobbs. Residential property tax rates are lower for 

properties outside of Hobbs, and higher for those within Hobbs. 

New Mexico and its local governments offer industrial revenue bonds (IRBs) as a way to 

encourage company relocations and expansions that provide jobs and economic opportunities 

for residents and communities. IRBs allow projects to qualify for certain tax incentives, including 

a property tax exemption on most real and personal property constituting a project’s property, 

and possible exemptions from gross receipts tax and use tax related to the acquisition of 

equipment and other personal property for use in the business to be conducted at the project 

(City of Albuquerque, 2011). International Isotopes, the parent corporation of IIFP, has an IRB 

agreement with Lea County, New Mexico (IIFP, 2011). As a result, IIFP is generally exempt 

from property taxes. However, the school district and the New Mexico Junior College are not 
 3-78 

part of this IRB agreement. Table 3-28 contains annual property tax revenue data for the local 

entities that would have the authority to levy a property tax on the proposed IIFP facilities. 

Table 3-28. IIFP Annual Property Tax Information 

Property Taxing Entity 

Total Annual 

Tax Revenues 

Estimated IIFP 

Facility in Lieu of 

Property Tax 

Payment 

IIFP Facility 

Estimated in Lieu of 

Property Tax 

Payment as Percent 

of Total Annual Tax 

Revenues 

Hobbs Municipal School District $71,126,000a $78,300 - $123,300 <1% 

New Mexico Junior College $37,201,924b $139,200 - $219,200 <1% 

Sources: 

a

NCES, 2008 

b

NCES, 2009 

3.9.4 Housing 

Table 3-29 summarizes housing data for Lea County, Eddy County and the largest city within 

each county, Hobbs and Carlsbad, respectively. A variety of types, prices, and settings 

comprise the housing inventory in the socioeconomic ROI. In 2008 there were 46,971 housing 

units in Lea and Eddy Counties (USCB, 2010b). The two largest population centers in the 

counties, Hobbs and Carlsbad, had approximately half of the total ROI housing inventory 

(USCB, 2010b). Within the ROI, approximately 12.4 percent (5,823 units) of the units were 

vacant (USCB, 2010b). Of the 41,148 occupied units, 29,021 were owner-occupied 

(70.5 percent) and 12,127 (29.5 percent) were renter-occupied (USCB, 2010c). The median 

value of an owner-occupied unit was $82,200 in Lea County and $85,600 in Eddy County 

(USCB, 2010b). For comparison, the median value of an owner-occupied house in New Mexico 

was $154,900 in 2008 (USCB, 2010b). 

In 2008, the median monthly rent was $661 in New Mexico and slightly less in both Lea and 

Eddy Counties (USCB, 2010b). Mobile homes accounted for 16.9 percent of the housing in Lea 

County and 14.0 percent of the housing in Eddy County (USCB, 2010e). Mobile homes made 

up 16.7 percent of the housing inventory in New Mexico (USCB, 2010e). The housing inventory 

in the ROI grew by 1.1 percent from 2008 to 2009, while the growth in the ROI’s population was 

0.2 percent (USCB, 2010a; USCB, 2010d). 

Table 3-29. Housing Characteristics in ROI Counties and Population Centers, 2008 

County/ 

Population 

Center 

Housin

g Units 

2008a

Occupied 

Units, 

2008a

OwnerOccupied 

Units, 

2008a

Renteroccupied, 

2008a

Vacant 

Housing 

Units, 

2008a

Percent 

Units Vacant 

of All Units, 

2008a

Mobile 

Homes, 

2008b

Lea County 24,495 21,653 14,912 6,741 2,842 11.6% 4,134 

Hobbs 12,299 10,854 6,998 3,856 1,445 11.7% 1,201 

Eddy County 22,476 19,495 14,109 5,386 2,981 13.3% 3,142 

Carlsbad 11,565 10,073 6,954 3,119 1,492 12.9% 556 

ROI Total 46,971 41,148 29,021 12,127 5,823 12.4% 7,276 

Source: 

a

USCB, 2010b 

b

USCB, 2010f 
 3-79 

3.9.5 Public Utilities 

3.9.5.1 Major Public Water Suppliers 

EPA lists two major public water suppliers in Lea County and three major public water suppliers 

in Eddy County (EPA, 2010b). Major public water systems are those that serve more than 

3,300 people. Table 3-30 presents water production and use statistics for these suppliers. 

Most of the major water suppliers in the ROI have excess capacity. 

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

Water System Namea

County 

Serveda

Population 

Serveda

Primary 

Water Source 

Typea

Average 

Daily Use 

(MGD)b

Maximum 

Capacity 

(MGD)b

Hobbs Municipal Water Supply Lea 33,000 Groundwater 7.0 N/A 

Lovington Municipal Water 

Supply Lea 9,643 Groundwater 2.5 6 

Artesia Municipal Water System Eddy 14,000 Groundwater 2.3 8.64 

Carlsbad Municipal Water 

System Eddy 27,000 Groundwater 3.8 28.8 

Otis Mutual Domestic Water 

Consumer’s Association Eddy 5,000 Groundwater 1.0 NA 

Source: 

a

EPA, 2010b 

b

NMED, 2010b 

MGD = million gallons per day 

3.9.5.2 Major Public Wastewater Treatment Facilities 

The New Mexico Environment Department (NMED) lists four major public wastewater treatment 

facilities in Lea and Eddy Counties (NMED, 2010c). Major wastewater treatment facilities are 

those that serve more than 3,000 people. Table 3-31 presents wastewater treatment production 

and capacity statistics for these facilities. All of the major wastewater treatment facilities in the 

ROI have excess capacity. 

Table 3-31. Major Wastewater Treatment Facilities in ROIa

Facility Nameb

2009 Population 

Servedb

Average Daily 

Production 

(MGD) 

Maximum 

Permitted 

Capacity (MGD)b

City of Artesia 11,208 1.3c 3.0 

City of Carlsbad 26,352 2.5d 8.5 

City of Hobbs 31,151 3.4e 7.2 

City of Lovington 10,206 0.8f 2.7 

Source: 

a

Includes permitted, municipal wastewater treatment plants serving at least 3,000 persons. 

b

NMED, 2010c 

c

Artesia, 2010 

d

Carlsbad, 2010 

e

Hobbs, 2010 

f ovington, 2010 
 3-80 

3.9.6 Community Services 

3.9.6.1 Education 

Table 3-32 summarizes information about public school districts and schools in the ROI. Lea 

County has 5 public school districts, with 36 schools for early childhood education (Age 3) 

through Grade 12. The total enrollment in the county public schools was 12,588 students in 

2008 (NCES, 2010a). There are also three private schools in the county with a total 2008 

enrollment of 111 students (NCES, 2010b). In addition, there are two colleges in the county, 

both in Hobbs. New Mexico Junior College had a 2009 enrollment of 2,300 and University of 

the Southwest had an enrollment of 528, with an undergraduate enrollment of 317 

(NCES, 2010c). 

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

County Schools 

Number of 

Schools in 

District 

Number of 

Students 

Lea County 

Eunice Municipal Schools 3 589 

Hobbs Municipal Schools 17 8,038 

Jal Public Schools 3 405 

Lovington Public Schools 10 3,247 

Tatum Municipal Schools 3 309 

Eddy County 

Carlsbad Municipal Schools 15 3,581 

Artesia Public Schools 10 6,058 

Loving Municipal Schools 3 620 

Source: NCES, 2010a 

Eddy County has 28 schools in 3 public school districts with a 2008 enrollment of 10,259 

students (NCES, 2010a). There is also a private school in Carlsbad with a 2008 enrollment of 

68 students (NCES, 2010b). New Mexico State University has a campus in Carlsbad with an 

enrollment of 2,050 (NCES, 2010c). 

3.9.6.2 Fire Protection 

In 2010, there were 468 active career and volunteer firefighters in the ROI (USFA, 2010). 

Twenty fire departments, operating out of 37 fire stations, are in the ROI (USFA, 2010). The 

proposed IIFP site would be within the jurisdiction of the City of Hobbs Fire Department 

(HFD, 2010), which is staffed with 70 career firefighters (USFA, 2010). Lea County and Eddy 

County have mutual aid agreements among all the municipal and independent fire departments 

to assist with additional response services (HFD, 2010; LPD, 2010). Table 3-33 provides 

information about fire protection in the ROI. 

Table 3-33. Fire Protection in the ROI, 2010 

County 

2009 County 

Populationa

Active 

Firefighters 

2010b

Ratio of Residents 

to Active 

Firefighters, 2010 

Number of Fire 

Stations, 2010b

Lea 60,232 176 342 9 

Eddy 52,706 292 181 28 

ROI Total 112,938 468 241 37 

Sources: 

a

USCB, 2010a; bUSFA, 2010 
 3-81 

3.9.6.3 Law Enforcement 

In 2009, there were 89 county and 196 municipal law enforcement officers serving the two ROI 

counties (FBI, 2009a; FBI, 2009b; LPD, 2010). Law enforcement services in the ROI are 

provided by the Lea County and Eddy County Sheriff Departments and the Artesia, Carlsbad, 

Eunice, Hobbs, Jal, Lovington, and Tatum municipal police departments (FBI, 2009a; FBI, 

2009b). Hope and Loving also maintain police departments (LPD, 2010). The Lea County 

Sheriff’s Department has jurisdiction in the unincorporated portion of Lea County, including the 

proposed site (HFD, 2010; LPD, 2010). The New Mexico State Police could provide a second 

level of response to any sheriff or police department via existing mutual aid agreements (HFD, 

2010; LPD, 2010). Table 3-34 provides information about law enforcement in the ROI. 

3.9.6.4 Hospitals and Physicians 

Lea County has two general medical and surgical hospitals. The Lea Regional Medical Center 

in Hobbs is the closest hospital to the proposed site. It has 214 staffed beds (AHA, 2007). 

Nor-Lea General Hospital, in Lovington, has 12 staffed beds (AHA, 2007). Eddy County also 

has two general medical and surgical hospitals. The Carlsbad Medical Center has 127 staffed 

beds and the Artesia General Hospital, in Artesia, has 20 staffed beds (AHA, 2007). The ROI 

has 146 practicing physicians; 69 physicians in Lea County representing 24 specialties and 

77 physicians representing 25 specialties in Eddy County (AMA, 2010). Both Lea County and 

Eddy County are considered to be medically underserved areas (HRSA, Undated). 

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

County/Citya,e

Population 

2009a,e

Law Enforcement 

Officers 

2009b,c

Ratio of residentsto-Law Enforcement 

Officers, 2009 

Lea County -- 43 -- 

Eunice 2,809 7 -- 

Hobbs 30,838 70 -- 

Jal 2,074 5 -- 

Lovington 10,108 23 -- 

Tatum 767 3 -- 

Lea County Totals 60,232 151 399 

Eddy Countyb -- 46 -- 

Artesia 11,338 33 -- 

Carlsbad 26,259 50 -- 

Hoped 109 1d -- 

Lovingd 1,366 4d -- 

Eddy County Totals 52,706 134 393 

Sources: 

a

USCB, 2010a 

b

FBI, 2009a 

c

FBI, 2009b 

d

LPD, 2010 

e

USCB, 2010d 
 3-82 

3.10 Traffic and Transportation 

3.10.1 Roadways 

Figure 3-26 shows the major highways near the proposed IIFP site. The site is approximately 

1.6 km (1 mi) north of US 62/180 and immediately east of NM 483, in close proximity to the 

intersection of the two roadways. 

From the east, US 62/180 crosses into New Mexico from Texas approximately 29 km (18 mi) 

from the IIFP site, runs through the City of Hobbs, intersects NM 483 at the IIFP site, and 

continues to Carlsbad, NM. Near the proposed IIFP site, US 62/180 is called Carlsbad Highway 

and is a 4-lane divided highway that provides access to the proposed site from the east and 

west. 

NM 483 is a 2-lane north-south highway that connects Lovington, New Mexico to US 62/180. 

East of the proposed site north-south roadways NM 8 and NM 18 provide access to US 62/180 

from Eunice, New Mexico and several unincorporated areas. NM 132 provides access to US 

62/180 in Hobbs from points in Texas. NM 529 is an east-west roadway that intersects 

US62/180 just west of the proposed IIFP site (Figure 3-26). 

Table 3-35 provides annual average daily traffic (AADT) data for the roadways in the vicinity of 

the proposed IIFP site (Figure 3-26). These roadways are used as trucking routes. The 

numbers in the left column correspond to the numbered locations on Figure 3-26. 

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

 Roadway Location AADT Year 

1 US 62/180 NM 8 Junction 7,868a 2008 

2 NM 483 US 62/180 Junction 955b 2008 

3 NM 132 US 18/NM 218 Junction 4,604b 2008 

4 NM 8 0.256-mi South of US 62/180 1,302b 2008 

5 NM 18 US 62/180 Junction 12,407a 2007 

6 NM 176 NM 8 Junction 2,124a 2008 

7 NM 529 West of US 62/180 Junction 2,393b 2008 

Source: NMDOT, 2009 

a

The AADT was derived from recent coverage counts. 

b

The AADT was derived using an Annual Growth Factor, generalized from coverage counts within the traffic segment 

and updated with loop and growth factors. 

3.10.2 Railroads 

The Texas-New Mexico Railroad is an active rail line through Hobbs, New Mexico, 

approximately 16.2 km (10 mi) east of the proposed IIFP site. It is a shortline railroad operating 

between Monahans, Texas and Lovington, New Mexico. The rail line is predominantly used for 

freight transport associated with the oil and gas industry, and typical freight includes chemicals, 

minerals, construction aggregate, industrial waste, and scrap. There is a freight dock and 

warehouse in the Hobbs area. Train frequency is daily six days per week (IPH, 2010). 
 3-83 

 
 3-84 

3.10.3 Airports 

The Lea County Regional (Hobbs) Airport is approximately 13 km (8 mi) from the proposed IIFP 

site just northwest of the Hobbs city limits. The airport currently supports only general aviation, 

but may support domestic flights in the future (AIRNAV, 2010). Two additional airports are in 

Lea County: The Lea County-Zip Franklin Memorial Airport is 5 km (3 mi) west of Lovington 

(approximately 26 km [16 mi] from the IIFP site) and the Lea County-Jal Airport is 6 km (3.7 mi) 

northeast of Jal (approximately 64 km [40 mi] from the IIFP site). These airports support 

general aviation operations (AIRNAV, 2010). 

3.11 Noise 

The definition of noise is “unwanted or disturbing sound.” Sound measurements are described 

in terms of frequencies and intensities. The decibel (dB) is used to describe the sound pressure 

level. The A-scale on a sound level meter best approximates the audible frequency response of 

the human ear, and is commonly used in noise measurements. Sound pressure levels 

measured on the A-scale of a sound meter are abbreviated dB(A). In noise measurements, 

sound pressure levels are typically averaged over a given length of time, because 

instantaneous levels can vary widely. 

The intensity of sound decreases with increasing distance from the source. Typically, 

sound levels for a point source will decrease by 6 dB(A) for each doubling of distance. This 

may vary depending on the terrain, topographical features, and frequency of the noise 

source.

Generally, sound level changes of 3 dB(A) are barely perceptible, while a change of 5 dB(A) is 

readily noticeable by most people. A 10 dB(A) increase is usually perceived as a doubling of 

loudness, and conversely, noise is perceived to be reduced by one-half when a sound level is 

reduced by 10 dB(A). 

Sound levels can vary for indoor and outdoor noise sources. For example, a jet flying overhead 

at 1,000’ will produce a sound level of 100 dB(A), the same as an inside subway train. A typical 

outdoor commercial area is equivalent to a normal speech conversation indoors, at 65 dB(A), 

and a quiet rural nighttime environment will mimic an empty concert hall, at 25 dB(A). 

3.11.1 Noise Level Standards 

Noise level standards are established by Federal agencies including the U.S. Department of 

Housing and Urban Development (HUD) (24 CFR 51), the Environmental Protection Agency 

(EPA, 1974), Federal Highway Administration (23 CFR 772), and the Occupational Safety and 

Health Administration (OSHA) (29 CFR 1910). 

Neither the city of Hobbs, Lea County, nor New Mexico have ordinances or regulations 

governing noise. There are no Native American Tribes within 10 km (6 mi) of the proposed site. 

Therefore, the facility is not subject to state, tribal, or local noise ordinances. 

The EPA has defined a goal of 55 dB(A) for average day-night sound levels in outdoor spaces 

(EPA 1974). OSHA standards prescribe the maximum noise levels that employees can be 

exposed to within a facility. For an 8-hour work period, sound levels must remain below 

90dB(A) or noise abatement measures must be taken, in order to comply with OSHA [29 CFR 
 3-85 

1910.95(b)(2)]. HUD guidelines are that noise levels at 65 dB(A) or below are acceptable in a 

residential setting in normal situations. 

3.11.2 Noise Receptors in the Vicinity of the Proposed Facility 

The determination of noise impacts is based on the relationship between the ambient noise 

levels and the established noise abatement criteria for the project area. Noise sensitive areas 

are created to represent common noise environments within the same activity category, and are 

represented by receptors, which represent a discrete or representative location within the noise 

sensitive area. Activity categories include land uses such as residences, hotels, motels, active 

sport areas, schools, places of worship, hospitals, parks and others. No noise sensitive areas 

are within 10 km (6 mi) of the site, based on a review of aerial photographs. 

The nearest commercial facilities are Xcel Energy’s Cunningham Generating Station, 

approximately 1.6 km (1 mi) west of the proposed site, Xcel Energy’s Maddox Generating 

Station approximately 3.7 km (2.3 mi) east of the proposed site, and the Colorado Energy 

Station approximately 2.4 km (1.5 mi) northeast of the proposed site. The nearest residence is 

approximately 2.6 km (1.6 mi) northwest of the site. No recreational facilities are within 10 km 

(6 mi) of the proposed site. 

3.11.3 Noise in the Vicinity of the Proposed Facility 

Noise sources in the vicinity of the site include ambient noise from the natural setting, highway 

noise from NM 483, and occasional noise associated with the overhead and underground 

utilities. The noise from the proposed facility would be associated with construction and 

operation activities and associated employee traffic. During operations, intermittent noise could 

be expected from delivery/disposal of the depleted uranium cylinders and other materials, 

commuting workers’ vehicles, and operating equipment such as forklifts. Noise levels near the 

closed-loop cooling towers could be relatively high, but otherwise, most noise sources would be 

within buildings and would not be audible outside. Baseline ambient noise levels are the basis 

for comparison with predicted noise levels from construction and operation. It is typical in this 

type of topography and setting for background ambient noise levels to be between 50 and 

60 dB(A). 

Noise levels at uranium deconversion facilities in Paducah, KY and Piketon, OH would be 

comparable. DOE reported estimated or actual noise levels for those facilities (during 

operation) to range from 40 to 46 dB(A) at the closest receptors, which are residences 

approximately 1.6 km (1 m) from the proposed facility; similar to the distance to sensitive 

receptors at the proposed site (DOE, 2004a; DOE 2004b). 

3.12 Public and Occupational Health 

This section describes the natural and manmade sources of radiation and chemicals and the 

levels of exposure that may occur in the vicinity of the proposed IIFP facility. 

3.12.1 Background Radiological Exposure 

Figure 3-27 depicts the major sources of background radiation in the United States. As shown 

on Figure 3-27, humans are exposed to ionizing radiation from both natural and manmade 

sources. In the United States, each source contributes on average approximately one-half of an 

individual’s total annual radiation dose. The total annual exposure to individuals from both 
 3-86 

natural and manmade sources of radioactivity is approximately 6.2 millisieverts (620 millirem) 

(NCRP, 2009). 

A major proportion of natural radiation comes from naturally occurring airborne sources such as 

radon and thoron (an isotope of radon). The proposed IIFP site is in an area characterized by 

radon concentrations of 2 to 4 picocuries per liter (pCi/L) and is defined as of moderate radon 

potential. Moderate radon potential indicates that one-third to one-half of the structures have 

more than 0.148 becquerel per liter (Bq/L) or 4 pCi/L of indoor radon. In May 2004, direct 

background radiation was measured by the NMED Radiation Control Bureau to be 8 to 10 

microrad per hour, which corresponds to 0.70 to 0.88 millisieverts (mSv) (70 to 88 millirem 

[mrem]) per year. The measured range falls within the average annual direct background 

radiation for the United States (NRC, 2005). Additionally cosmic radiation, which primarily 

consists of positively charged ions from protons to larger nuclei from sources outside our solar 

system, is continuously penetrating the earth’s atmosphere, adding to the overall amount of 

natural background exposure each individual receives. As shown on Figure 3-27, the total 

contribution from natural background radiation to each individual is approximately 3.1 mSv 

(310 mrem) (NCRP, 2009). 

Manmade sources include x-rays for medical purposes and consumer products such as smoke 

detectors. The National Council on Radiation Protection and Measurements (NCRP) released a 

report, Ionizing Radiation Exposure of the Population of the United States, (NCRP Report No. 

160; NCRP 2009) in 2009 that updated the findings of the previously issued NCRP Report No. 

93 (NCRP, 1987). The 2009 NCRP report found significant increases in radiation exposures 

related to medical procedures and treatments. The approximate doses to individuals for 

medical procedures such as x-rays comprise approximately 48 percent of the total dose 

received by individuals living in the United States (NCRP, 2009). Natural sources include 

cosmic sources, radionuclides within a person’s body, radionuclides in soils, and radon and 

thoron inhalation. 

DOE established radiological monitoring programs in southeastern New Mexico prior to the 

Waste Isolation Pilot Plant project to determine the level of background radiation. DOE 

estimated an annual dose in southeastern New Mexico of approximately 0.65 mSv (65 millirem) 

from atmospheric particulate matter, ambient radiation, soil, surface water and sediment, 

groundwater, and biota (NRC, 2005). These doses are within expected ranges and do not 

indicate any unexpected environmental concentrations in the area. Based on natural and 

manmade sources, residents living near the proposed IIFP facility could be expected to receive, 

on average, an annual dose of approximately 6.2 mSv (620 millirem). 

3.12.2 Background Chemical Characteristics 

The 16-ha (40-ac) area that would contain the proposed facility is undeveloped land. There is 

no known past activity on this land that would make its background chemical characteristics 

different than other undeveloped land. No site-specific chemical data are available. 
 3-87 

Figure 3-27. Major Sources and Levels In The Vicinity of the Proposed FEP/DUP 

Background Radiation Exposure 

Source: data are from NCRP, 2009. Data for this table have been used with permission of the National Council on 

Radiation Protection and Measurements, (http://NCRPpublications.org).

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library/levels74/levels74.htm. Accessed on December 13, 2010. ADAMS Accession No. 

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 4-1 

4.0 ENVIRONMENTAL IMPACTS 

This chapter describes the potential environmental impacts associated with the construction, 

operation, and decommissioning of the proposed IIFP facility. Section 4.1 addresses both 

construction and operations impacts from the proposed action. Plant decommissioning at the 

termination of the license is included as part of the proposed action. Cumulative impacts of the 

proposed action and past, present, and reasonably foreseeable future actions are presented in 

Section 4.2. The no-action alternative is discussed in Section 4.3. 

4.1 Proposed Action 

As defined in Chapter 2 of this EIS, the proposed action is to construct, operate, and 

decommission a chemical plant for the deconversion of commercially generated DUF6

inventories into depleted uranium oxide and other deconversion products. 

The impacts discussions are organized by the subject areas described in Chapter 3, 

“Description of the Affected Environment.” NRC staff significance criteria, SMALL, 

MODERATE, and LARGE, are used throughout the analyses. These are defined as follows 

(NRC, 2003): 

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

neither destabilize, nor noticeably alter any, important attribute of the resource. 

MODERATE: The environmental effects would be sufficient to noticeably alter, but not 

destabilize, important attributes of the resource. 

LARGE: The environmental effects would be clearly noticeable and are sufficient to destabilize 

important attributes of the resource. 

Section 4.1.1 addresses environmental impacts of construction and Section 4.1.2 addresses 

environmental impacts of operations. 

4.1.1 Environmental Impacts of Construction 

The impacts of construction on each of the major resource areas described in Chapter 3 are 

presented in this Section. Impacts of preconstruction activities (defined and identified in 

Chapter 2) are evaluated as cumulative impacts in Section 4.2. 

4.1.1.1 Land Use 

Impacts on land use result from commitment of the land for the proposed use and therefore, its 

potential exclusion from other possible uses. Land use impacts occur when the presence of a 

project would limit possible future land uses near the proposed project. For example, land use 

impacts could occur if the project restricts future access to mineral resources. 

The current land uses on the proposed 259-ha (640-ac) site are cattle grazing, and access to 

and maintenance of utility rights-of-way and monitoring wells. The proposed site is not subject 

to local or county zoning, land use planning, or associated review process requirements, and 

there are no potential conflicts of land use plans, policies, or controls (Appendix A). The 

conversion of 16 ha (40 ac) of the 259-ha (640-ac) site from its current land use to the 
 4-2 

proposed facility without disturbing the remaining 240 ha (600 ac) would not conflict with any 

existing Federal, State, local, or Tribal land uses or restrict current or planned mineral resources 

exploitation (Appendix A). 

Construction of the proposed IIFP facility would modify the current land use by restricting cattle 

grazing on the entire 259-ha (640-ac) site. Currently, approximately 93 percent of land in Lea 

County is used as range land for grazing (approximately 1.0-million ha [2.6-million ac]). 

Restricting grazing on the 259-ha (640-ac) site would result in a loss of 0.02 percent of the land 

available for grazing. The proposed facility footprint was selected by IIFP to avoid, to the extent 

possible, existing utility rights-of-way so that the change in land use would not limit access to or 

maintenance of the rights-of-way. In addition, it is not likely that any of Xcel Energy’s 

Cunningham Station’s monitoring wells (CU-6, CU-8, and CU-9) in Section 27 (the proposed 

IIFP site) would be affected by the construction of the facility or the associated infrastructure 

such as the access road. NRC staff expects the remainder of the proposed IIFP site 

(Section 27) to be left in its present condition, largely undeveloped for the duration of the 

facility’s operation and decommissioning. 

Consequently, the NRC staff finds that the impacts to land use from the construction of the 

facility within the 259-ha (640-ac) site would be SMALL, due to the abundance of other nearby 

grazing land and the ability to continue to access utility rights-of-way. 

4.1.1.2 Historic and Cultural Resources 

This section describes the potential environmental impacts on historic and cultural resources 

resulting from construction of the proposed IIFP facility. As Chapter 3 states, historic and 

cultural resources include archaeological sites, historic structures, and places of cultural 

importance to groups for maintaining their heritage. Cultural resources are nonrenewable; that 

is, once altered, the information contained in cultural resources cannot be recovered. NRC staff 

identified separate Areas of Potential Effect (APEs) for archaeology and architecture; and for 

construction versus operations. For construction impacts, the APE for archaeology is 

considered to include the 16-ha (40-ac) IIFP facility, approach road, and parking lot where 

disturbance would occur. For construction impacts, the APE for historic architectural resources, 

would include the IIFP facility (limits of disturbance), and any areas where noise or construction 

activity would be heard or visible. 

NRC staff identified no historic properties, districts, resources or significant culturally important 

or archaeological sites within the cultural resources APE during files research at the New 

Mexico State Historic Preservation Office (NM SHPO), and tribal consultation. The field survey 

conducted by IIFP’s archaeological consultant also identified no significant cultural resources 

although it found three isolated artifact occurrences – a brown chert San Jose projectile point 

fragment, a gray quartzite hammerstone, and three glass vessel fragments. The artifacts were 

recorded with the SHPO, but are not National Register-eligible as determined by the 

archaeological consultant for the State Land Office. 

As discussed in Section 3.3.4, on October 14, 2010, the New Mexico Trust Land Archaeologist 

in the office of the State of New Mexico Commissioner of Public Lands recommended a finding 

of no effect to historic properties, districts, resources or significant historic/precontact 

archaeological sites because the cultural resource survey found no significant cultural resources 

in the proposed IIFP site, and no historic properties have been identified within the APE. The 

NM SHPO concurred with this determination on October 25, 2010 (Appendix B). 
 4-3 

NRC staff also consulted with Native American Tribes which were identified from a list 

maintained by the NM SHPO, consistent with the NHPA Section 106. The NRC staff received 

three responses (Appendix B). On July 13, 2010, the Ysleta del Sur Pueblo stated that the 

Pueblo believes the project will not adversely affect traditional, religious, or culturally significant 

sites, but requested consultation should human remains or artifacts regulated by the Native 

American Graves Protection and Repatriation Act be discovered. On June 15, 2011, the Tribal 

Historic Preservation Officer for the Comanche Tribe noted that he had no comments on the 

project. On July 13, 2011, the Shawnee Tribe’s Tribal Historic Preservation Department 

concurred that no known historic properties would be impacted by the project, but also 

requested consultation if archaeological materials are encountered during construction or 

operation of the facility. 

Based on the history of the region, its lack of permanent surface water, and the results of 

previous investigations, no significant archaeological, cultural, or historic resources are present 

on the site. Therefore, the NRC staff finds that impacts to historic properties, districts, 

resources or significant historic/precontact archaeological sites during construction would be 

SMALL. 

4.1.1.3 Visual Resources 

As discussed in Section 3.4, the scenic value of the proposed IIFP site is low (“least valued”) 

and is further diminished by the presence, within 5 km (3 mi), of four industrial facilities, three of 

which are visible from the proposed site. Consequently, the NRC staff concludes that the 

impacts to visual resources during construction would be SMALL. 

4.1.1.4 Climatology, Meteorology, and Air Quality 

4.1.1.4.1 Greenhouse Gases 

This section presents an assessment of the effect of construction of the proposed IIFP facility on 

the concentration of CO2 and other greenhouse gases in the atmosphere. 

During construction, air emissions would come from (1) construction vehicles and equipment, 

(2) personal vehicles of the construction workforce, (3) delivery vehicles bringing materials and 

equipment to the proposed site, and (4) vehicles transporting construction-related wastes from 

the proposed site to area landfills and treatment/disposal facilities. 

NRC staff used NONROAD (EPA, 2005) and MOVES (EPA, 2009a) computer models to 

calculate the estimated emissions for construction vehicles and equipment at 1,320 metric tons 

(1,455 tons) of CO2 equivalent emissions (Table 4-1). During construction, an estimated 

140 workers would commute to and from the proposed site with an assumed average (roundtrip) distance of 64 km (40 mi) daily for 250 days per year (IIFP, 2011b). This is based on the 

assumption that the workforce would live in the nearby population centers of Hobbs, Lovington, 

and Carlsbad, New Mexico. A weighted average of the distance to each population center and 

the 2000 population was used to determine average daily trip distance (IIFP, 2011a). Over the 

12-month construction period, the workforce commuting distance would be 2,253,082 km 

(1,400,000 mi). It was also estimated that over the course of the construction period, there 

would be 20 truck deliveries each day each traveling 64 km (40 mi). The EPA MOVES (EPA, 

2009a) was used to calculate estimated CO2 equivalents from all anticipated construction traffic 

as 790 metric tons (871 tons) (Table 4-2). 
 4-4 

Finally, onsite storage and dispensing of fuels during construction would result in minor 

greenhouse gas emissions; however, because neither the specific volume nor the chemical 

speciation’s of these evaporative losses are known, resulting greenhouse gas emissions have 

not been estimated. 

Total CO2 emissions expected during the 12-month construction period are 2,110 metric tons 

(2,326 tons); 1,320 metric tons (1,455 tons) from construction equipment and 790 metric tons 

(871 tons) from workforce commuting and deliveries. Using calendar year 2000 as a reference 

point (the latest year for which New Mexico greenhouse gas emission data are available), and 

as shown in Table 3-1, total net CO2 emissions for New Mexico for the year 2000 were 

62 million metric tons (68 million tons) of CO2 equivalents. For the United States for that same 

year, total net CO2 emissions were 5,977 million metric tons (6,588 million tons) (EPA, 2010a). 

By comparison, during the 12 months of construction, the proposed IIFP facility CO2 emissions 

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

output and 0.00004 percent of the projected nationwide CO2 emissions for the same period. 

Therefore, the NRC staff concludes that impacts from the construction of the proposed IIFP 

facility from the emissions of CO2 and other greenhouse gases would be SMALL. 

Table 4-1. CO2 Emissions from Construction Equipment 

Activity Annual CO2 Emissions 

(ton) (MT) 

Construction Equipment 1,455 1,320 

MT = metric ton 

Table 4-2. Emissions from Workforce Commuting and Delivery Activities 

During Construction 

Activity 

Total Distances for 12 months Annual CO2 Emissions 

(mi) (km) (ton) (MT) 

Commuting traffic (workforce) 1,400,000 2,300,000 660 599 

Delivery Truck traffic 200,000 320,000 211 191 

Total for workforce commuting 

and deliveries 1,600,000 2,600,000 871 790 

MT = metric ton 

4.1.1.4.2 Air Quality 

Air quality impacts from the operation of construction equipment during facility construction were 

evaluated based on the construction schedules and parameters provided by IIFP. 

Impacts to ambient air resources would occur from the construction of the proposed IIFP facility. 

As discussed in more detail below, the impacts would not be significant. Because the proposed 

IIFP site is located in an air quality control region that is designated as attainment with Federal 

and state ambient air quality standards, a General Conformity evaluation is not required. 

Construction of the proposed project would produce criteria pollutants (i.e., CO, NO2, PM10, 

PM2.5, SO2, lead, and volatile organic compounds (VOCs), an ozone precursor) and hazardous 
 4-5 

air pollutants (HAPs) emissions from construction equipment, delivery vehicles, commuter 

vehicles, and onsite refueling activities. Particulate emissions in the form of fugitive dust from 

soil transfers, land grading, and vehicle and equipment travel on unpaved roads would also be 

generated. 

The NRC staff used emission factors to estimate annual emissions from the construction of the 

proposed IIFP facility. Emission factors for highway vehicles (i.e., worker commute vehicles and 

delivery vehicles) were determined using the EPA MOVES Model (EPA, 2009a). Emission 

factors for non-road vehicles (including construction engines and equipment) were determined 

using the EPA NONROAD model (EPA, 2005). Emission factors for all other sources 

associated with construction were obtained from the EPA document AP-42, “Compilation of Air 

Pollutant Emission Factors” (EPA, 1995a). 

Emissions from each type of non-road equipment are a function of equipment-specific factors, 

including engine horsepower, load factor, and hours of operation. IIFP estimated that the 

construction project would be completed in approximately 12 months based on the assumption 

that construction would occur 10-hrs per day, 5 days per week, and would involve conventional 

construction equipment (e.g., dozers, graders, excavators, dump trucks, lifts). IIFP compiled a 

list of construction equipment that identifies for each month of construction, the quantity and 

average monthly hours of operation for each piece of equipment (See Table 4-3). 

Emissions from highway vehicles (i.e., worker commute vehicles and delivery vehicles) are a 

function of the vehicle-specific factors, including type of vehicle and age, fuel type, and vehicle 

miles traveled. The NRC staff used Lea County, New Mexico-specific default values for vehicle 

type, age, and fuel type to determine highway vehicle emission factors. IIFP estimated that over 

the 12-month construction period, 140 workers would commute to and from the proposed site 

an average daily trip distance of 64 km (40 mi) for 250 days each year; and delivery trucks 

would make 20 delivery trips per day (at an average round trip distance of 64 km [40 mi]) to 

transport materials and equipment and remove wastes (IIFP, 2011a). 

Fugitive dust generated during land clearing and soil transfer operations is dependent on a 

number of factors including silt and moisture content of the soil, wind speed, and disturbed area. 

To estimate fugitive dust emissions, IIFP used the EPA emission factor of 1.2 tons/acre/month 

of activity (EPA, 1995a). This emission factor represents total suspended particulates 

(i.e., particles less than 30 microns in diameter). IIFP assumed that the emission factor would 

drop to 0.3 tons/acre/month after the first month of construction, when the majority of earth 

moving activities would be complete. Multiplication factors of 0.15 and 0.075 were used to 

adjust the emission factor for PM10 and PM2.5, respectively. IIFP also assumed that water would 

be applied to disturbed areas. This would reduce fugitive dust emissions by about 50 percent 

(IIFP, 2011a). 

Small quantities of VOCs and HAPs emissions would be released from the refueling and onsite 

maintenance of construction equipment. Diesel fuel would be stored on site during construction 

and would be hand pumped into construction equipment and support vehicles. Annual VOCs 

and HAPs fugitive emissions are a function of diesel fuel consumption. 
4-6 

Table 4-3. Construction Equipment and Hours of Operation by Type and Month Equipment Max HP 

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 

No. Hr No. hr No. hr No. hr No. hr No. hr No. hr No. hr No. hr No. hr No. hr No. hr 

Tractor/ backhoe 150 2 160 1 80 1 80 1 80 1 80 1 80 1 80 1 80 1 80 1 80 1 80 1 80 Grader 400 1 160 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Excavator 500 1 160 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Dump Truck 300 2 160 2 160 2 160 1 100 1 100 1 100 1 100 1 100 1 100 1 100 1 100 1 100 Dozer 400 1 160 0 0 0 0 0 0 0 0 1 160 1 160 0 0 0 0 0 0 0 0 0 0 Air Compressor 325 1 80 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 Concrete Pump 125 0 0 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 Crane 175 0 0 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 1 160 Fuel Truck 250 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 Water Truck 250 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 1 50 Forklifts 200 1 50 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 Flatbed, 2-ton 200 1 80 1 80 1 80 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 Generator 33 0 0 1 80 1 80 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 2 160 Welder 50 1 30 2 60 2 60 5 160 5 160 5 160 5 160 3 160 3 160 3 160 3 160 3 160 Source: IIFP, 2011a No. = number
 4-7 

The estimated maximum annual pollutant emissions from construction activities are presented 

in Table 4-4. Actual construction emissions are expected to be less, because conservative 

assumptions used in the modeling of construction activities tend to overestimate impacts. The 

applicant’s environmental report described Best Management Practices (BMPs) they would use 

to reduce impacts to various resources at the proposed IIFP site, including those to minimize 

the impacts of construction activities on air quality. These BMPs are described in Chapter 5, 

Mitigation Measures and Commitments. 

Table 4-4. Estimated Maximum Annual Emissions from Construction of the IIFP 

Facility 

Source 

CO 

metric 

tons 

(tons) 

NO2 

metric 

tons 

(tons) 

PM2.5 

metric 

tons 

(tons) 

PM10 

metric 

tons 

(tons) 

SO2 

metric 

tons 

(tons) 

VOC 

metric 

tons 

(tons) 

HAP 

metric 

tons 

(tons) 

Construction 

Equipment 

4.00 8.55 0.639 0.660 0.268 0.778 ----- 

(4.41) (9.43) (0.705) (0.727) (0.295) (0.858) ----- 

Delivery 

Vehicles 

2.05 0.926 0.0394 0.0476 0.00224 0.174 0.174 

(2.26) (1.02) (0.0434) (0.0524) (0.00247) (0.192) (0.192) 

Personal 

Vehicles 

10.9 1.46 0.0266 0.0494 0.0116 1.03 1.03 

(12.1) (1.61) (0.0293 (0.0545) (0.0128) (1.14) (1.14) 

Fugitive 

Emissions ----- ----- 3.67 7.35 ----- 0.00161 0.0016 

(4.05) (8.10) (0.00177) (0.00177) 

Total 17.7 10.9 4.38 8.11 0.282 1.99 1.21 

18.7 (12.1) (4.83) (8.93) 0.31 (2.19) (1.33) 

Source: See Appendix C 

CO = carbon monoxide 

NO2 = nitrogen dioxide 

PM2.5 = particulate matter less than 2.5 microns in diameter 

PM10 = particulate matter less than 10 microns in diameter 

SO2 – sulfur dioxide 

VOC = volatile organic compounds 

HAP = hazardous air pollutants 

To estimate the impact to local air quality, the NRC staff compared the anticipated criteria 

pollutant and VOCs emissions from the proposed IIFP construction activities to baseline 

emissions from Lea County, New Mexico. As shown in Table 4-5, emissions from the proposed 

construction activities at the IIFP site would represent a very small portion of the annual criteria 

pollutant emissions in Lea County. 

NRC staff used EPA’s SCREEN3 model (EPA 1995b) to estimate the maximum concentrations 

of pollutants at the proposed IIFP site property line that would be associated with construction 

activities. As shown in Table 4-6, the estimated incremental increases in ambient background 

concentrations due to the proposed construction activities would be above the National NAAQS 

for NO2, PM2.5, and PM10 emissions. HAPs and VOCs are not included in Table 4-6 because 

there are no regulatory metrics for comparison (HAPs and VOCs emissions are regulated by 

source controls and permit requirements). 
 4-8 

Table 4-5. Comparison of Maximum Annual Emissions from Construction of the IIFP 

Facility to Lea County Baseline Conditions 

Source 

CO 

metric 

tons (tons) 

NO2 

metric 

tons (tons) 

PM2.5

metric 

tons (tons) 

PM10

metric 

tons (tons) 

SO2

metric 

tons (tons) 

VOC 

metric 

tons (tons) 

Site Construction 17.0 

(18.70) 

10.90 

(12.10) 

4.38 

(4.83) 

8.11 

(8.93) 

0.28 

(0.31) 

1.99 

(2.19) 

Lea County 

Baseline (a) 

21,244 

(23,417) 

27,119 

(29,894) 

2,892 

(3,188) 

25,048 

(27,611) 

7,334 

(8,084) 

4,436 

(4,890) 

Net Increase 

over Baseline 

0.080% 0.040% 0.151% 0.032% 0.004% 0.045% 

Source: EPA, 2009b 

Source: See Appendix C 

CO = carbon monoxide 

NO2 = nitrogen dioxide 

PM2.5 = particulate matter less than 2.5 microns in diameter 

PM10 = particulate matter less than 10 microns in diameter 

SO2 – sulfur dioxide 

VOC = volatile organic compounds 

HAP = hazardous air pollutants 

Table 4-6. Comparison of Predicted Maximum Downwind Concentrations Due to 

Construction Activities to NAAQS 

Pollutant 

Averaging 

Time 

NAAQS 

μg/m3

Incremental 

Concentration 

Increase 

μg/m3

 

Incremental 

Concentration Increase 

as Percentage of 

NAAQS 

CO 1-hr 

8-hr 

10,000 

40,000 

116 

81.3 

1.2% 

0.20% 

NO2 1-hr 

Annual 

100 

188 

269 

26.9 

269% 

14% 

PM2.5 24-hr 

Annual 

35 

15 

142 

35.5 

406% 

237% 

PM10 24-hr 150 277 185% 

SO2 1-hr 

3-hr 

200 

1,300 

8.5 

7.7 

4.3% 

0.6% 

Source: See Appendix C 

As discussed above, the estimated emissions during construction of the proposed IIFP facility 

represent a very small fraction of the current emissions in Lea County. Because conservative 

assumptions that tend to overestimate impacts were used to produce these estimates, actual 

emissions from the construction activities are expected to be lower. Pollutant emissions from 

construction activities have the potential to change the existing ambient air quality in the vicinity 

of the proposed IIFP facility. Overall, the construction impacts would be localized and shortterm. Therefore, the NRC staff concludes that the air quality impacts resulting from the 

construction of the proposed IIFP facility would be MODERATE for NO2, PM2.5, and PM10

emissions and SMALL for CO, and SO2 emissions. BMPs identified by the applicant to use 

during construction to reduce impacts to air quality are described in Chapter 5, Mitigation 
 4-9 

Measures and Commitments. The NRC staff finds that the BMPs committed to by IIFP for the 

proposed facility would be sufficient to maintain impacts as MODERATE to SMALL. 

4.1.1.5 Geology, Minerals, and Soil 

Section 3.6 describes the geology, minerals, and soils at the proposed IIFP site. Alluvium 

and/or caliche would be removed during site preparation. If the materials are of the appropriate 

quality they would be used for roads or facility foundations at the site. The existing caliche pit 

described in Section 3.6.3 could be a source of caliche for site roads. Impact to topography and 

bedrock would be limited to clearing and excavating areas for facility and road construction. 

These impacts would be largely limited to the 16-ha (40-ac) facility, with the exception of the 

roadway construction that would extend beyond the facility, through the 259-ha (640-ac) site, to 

NM 483. 

The proposed IIFP site has been explored for oil and gas and caliche. The site has very limited 

leasable, locatable, or marketable mineral resources. Therefore, the proposed IIFP construction 

activities would not result in loss of mineral resources. 

As discussed in Section 3.6.2, the site is in an area of limited seismic and volcanic activity 

(Crone and Wheeler, 2000; Machette et al. 2000; Yarger, 2009), and the statistical probability of 

risk of earthquake damage is very low. Because excavation depth is limited to near-surface 

geology, construction activities are not expected to cause seismic or fault-related impacts. 

Soil erosion due to stormwater runoff and wind erosion must be managed during construction. 

As described in Section 3.6.4, the proposed site does not contain any prime farmland; therefore, 

prime farmland would not be impacted. During construction, BMPs would be employed to limit 

soil loss and mitigate any impacts. These would include: 

• Soil stabilization (e.g. temporary and permanent seeding), 

• Structural controls (e.g. hay bales and sediment fences), and 

• Management practices (e.g. construction sequencing, materials delivery sequencing, 

and physical delineation of disturbed areas). 

Construction excavation would be limited to near-surface geology at the 16-ha (40-ac) facility, 

and would result in minimal loss of mineral resources. BMPs identified in the applicant’s 

environmental report would be used to limit soil loss. Therefore, the NRC staff finds that the 

BMPs committed to by IIFP would be sufficient to ensure that construction impacts of the 

proposed IIFP facility to geology, minerals, and soil would be SMALL. 

4.1.1.6 Water Resources 

This section discusses the potential impacts of construction of the proposed IIFP facility on 

water resources. 

4.1.1.6.1 Groundwater 

As discussed in Section 3.7.1.2, the site is within the Lea County underground water basin 

(UWB). The Ogallala aquifer is the primary water supply source in the Lea County UWB, and is 

proposed as the water supply source for the proposed IIFP project. The aquifer is encountered 

at a depth of approximately 9.1 m (30 ft) beneath the proposed site (GL Environmental, 2010). 
 4-10 

Excavation through the dense caliche at the site could be required for sewer systems, roads, 

pads, and building foundations. Excavation depths are not expected to exceed the depth to 

groundwater (GL Environmental, 2010; IIFP, 2009a). 

4.1.1.6.1.1 Groundwater Use 

As discussed in Section 3.7.1.2, all the groundwater wells in the site vicinity obtain water from 

the Ogallala aquifer. The closest domestic groundwater supply well is (L-07469) approximately 

1.6 km (1 mi) northwest of the proposed site (IIFP, 2011a). The well depth is 48.8 m (160 ft) 

and the depth to water is 21.3 m (70 ft) (NMOSE, 2010). 

No municipal water line runs near the proposed site. The construction activities for the facility 

would require relatively low volumes of water. Up to two groundwater production wells would be 

installed in the Ogallala aquifer to supply all the water for the proposed facility. One of these 

production wells would be installed on the site by Lea County prior to the property transfer. This 

well would be designed to meet the production needs for both proposed Phase 1 and 2 

operations. This well would be drilled to a depth estimated to be between 61 to 76.2 m (200 to 

250 ft) below ground surface with an estimated pumping capacity of 1,325 L/min (350 gpm). A 

second production well may be needed during IIFP operations for emergency preparedness 

purposes. This well, if required, would be installed by IIFP during construction. If the second 

production well is installed, it would be located to minimize interference with the first production 

well (INIS, 2011). All new monitoring and production wells installed at the site would be 

installed in accordance with the New Mexico Office of the State Engineer and Lea County Water 

Users Association regulations. 

IIFP states that during construction, water use is projected to equal 3,600 L/day (960 gpd) on 

average, and 12,500 L/day (3,300 gpd) maximum (IIFP, 2011a). Groundwater may be used 

during construction for personal use, construction activities, and dust suppression. 

Groundwater pumped from the site well would be a consumptive loss because the groundwater 

would either be consumed or evaporated. For more information on groundwater appropriations 

and use restrictions refer to Section 4.1.2.6.1. 

As discussed in Section 3.7.1.2.1, because current pumping is in excess of the Ogallala’s 

recharge rate, the aquifer has experienced significant drawdown in the last several decades. In 

2009, the New Mexico Office of the State Engineer (NM OSE) prepared guidelines on the 

procedures for processing water rights applications filed with the Lea County UWB. The NM 

OSE developed administrative guidelines in order to promote the orderly development of water 

resources in the Lea County UWB, while meeting statutory obligations regarding existing water 

rights, availability of unappropriated water, conservation of water with the State, and public 

welfare of the State through a 40-year planning period beginning on January 1, 2005 and 

ending on January 1, 2045. 

On March 10, 2009, the NM OSE issued an order closing the Lea County UWB to the filing of 

groundwater applications (NMOSE, 2009a). In 1999, in order to meet the projected 

groundwater demands of Lea County, 138 applications were filed by the Lea County Water 

Users Association to appropriate 6,389 ha-m (51,797 ac-ft) per year of groundwater, which was 

essentially all the unappropriated groundwater in the Lea County UWB (Leadshill-Herkenhoff 

et al., 2000). 

A portion of the applications to appropriate groundwater, totaling 4,215.2 ha-m (34,173 ac-ft) per 

year, have been assigned to Lea County during (at least) the 40-year planning period to allow 
 4-11 

the County to hold the subject water rights unused until the rights can be put to beneficial use at 

projects currently under construction, select future projects, and homes and businesses in 

unincorporated areas. The proposed IIFP site has been included in Lea County’s 40-Year 

Water Development Plan as an area of proposed development where up to 21.6 ha-m 

(175 ac-ft) per year of the Lea County’s water rights would be put to beneficial use. The 

estimated quantity of additional groundwater that Lea County would need by the end of the 

40-yr planning period for all projects that currently exist, are being constructed, or have a high 

likelihood of being constructed in the near future is 1,173.5 ha-m (9,514 ac-ft) per year 

(Leadshill-Herkenhoff et al., 2000). 

Groundwater rights for the facility would be obtained from the Lea County unallocated water 

rights under State Engineer Office Water Right File No. L-04719-A for industrial water use. The 

proposed facility would obtain a joint Lea County and New Mexico Office of State Engineer 

(NM OSE) Water Rights Agreement for 6.2 ha-m (50 ac-ft) per year (far less than the 21.6 ha-m 

[175 ac-ft] per year estimation in the Lea County Water Development Plan). The site would use 

approximately 0.5 percent of the estimated annual 40-year planning period groundwater 

demand of 9,514 ac-ft per year for Lea County, and only 0.15 percent of the 4,215.2 ha-m 

(34,173 ac-ft) per year of unappropriated water rights that have been assigned to Lea County. 

The proposed site production well(s) could be the sole source of water during construction; or 

the applicant could use water from tanker trucks. Groundwater from onsite wells, or tankers 

filled from the Hobbs city water system, would be required during Phase 1 construction, mostly 

for dust suppression, fill compaction, and concrete formation. Unlike preconstruction, where 

water is assumed to be brought in on tanker trucks, IIFP may have operating wells at some 

point during construction. This water is not anticipated to be recycled and reused like plant 

process water during operations (discussed in Section 4.1.2.6.1), however the volumes required 

during construction would be less than a third of the volumes required during operations. 

Regardless if water comes from onsite wells or from the Hobbs municipal system via tanker 

trucks, the water use is accounted for in, and consistent with, Lea County’s water use plan. 

Therefore, the NRC staff finds that groundwater use impacts during construction would be 

SMALL. 

4.1.1.6.1.2 Groundwater Quality 

The Ogallala aquifer beneath the site is unconfined, and is recharged by natural precipitation 

that percolates to the groundwater table. As a consequence, any contaminants (e.g., diesel 

fuel, hydraulic fluid, antifreeze, or lubricants) spilled during construction and not controlled by 

spill control measures could affect the unconfined aquifer, although migration of contaminants 

would be slowed by the approximately 9.1-m (30-ft) thick indurated caliche layer that overlies 

the aquifer at the site (GL Environmental, 2010). 

Any spills of diesel fuel, hydraulic fluid, antifreeze, or lubricants during construction would be 

cleaned up quickly in accordance with the proposed facility’s Spill Prevention Control and 

Countermeasure Plan, to prevent the contaminant from entering the groundwater. 

All construction activities would comply with the site’s National Pollutant Discharge Elimination 

System (NPDES) General Permit to discharge stormwater associated with construction and the 

associated stormwater pollution prevention plan. Surface water flow from rain events would be 

directed to the site’s proposed catch basins. 
 4-12 

During construction activities, portable sanitary facilities would be used until a permanent 

sanitary waste treatment facility is functional. The waste collected from these temporary 

facilities would be disposed of offsite by a licensed sanitary waste disposal contractor. 

No process waste effluent will be generated during this construction phase. 

Therefore, the NRC staff finds that impacts to groundwater quality due to construction-related 

activities would be SMALL. 

4.1.1.6.2 Surface Water 

As discussed in Section 3.7.2, no permanent surface water, including jurisdictional waters, is 

present on the proposed IIFP site. Therefore, the NRC staff finds that impacts to surface water 

quality or quantity due to construction-related activities would be SMALL. 

4.1.1.7 Ecological Resources 

This section discusses the potential impacts of construction of the proposed IIFP facility on 

ecological resources. Most of the potential ecological disturbances due to habitat loss from land 

clearing of the proposed IIFP site would occur during preconstruction, and thus is evaluated as 

a cumulative impact. Other potential ecological disturbances could include: noise and vibrations 

from heavy equipment and traffic, fugitive dust, and the presence of construction personnel. 

Approximately 16 ha (40 ac) of land would be affected by construction, which represents less 

than 10 percent of the total 259 ha (640 ac) site. Leaving a majority of the site undisturbed 

would allow mobile resident wildlife within the disturbed areas an opportunity to relocate to the 

undisturbed areas. These undisturbed areas are expected to be left undisturbed for the life of 

the proposed facility. Some wildlife may suffer stresses or mortality during construction. 

Human encounters with some wildlife could increase due to loss of habitat. No construction 

facilities or equipment would be 61 m (200 ft) high or taller, so no aviation safety lights will be 

required (FAA, 1992). Security lighting will be directed downward, and construction will not 

require night shifts so night-migrating and nocturnal animals would not be affected. 

As described in Section 3.7.2, there are no wetlands or permanent stream systems, and 

therefore no riparian habitat within the facility footprint. 

As described in Section 3.8, no Federal or state-listed threatened or endangered species are 

likely to be found on the site as their preferred habitats are not found on the site. No unique or 

critical habitats occur on the site. No threatened or endangered species are known from the site 

or in the vicinity. No commercially or recreationally important species use the habitat at the site 

exclusively. 

Maintenance practices such as the use of chemical herbicides, roadway maintenance, and 

clearing practices could be employed during construction. Land clearing would destroy the 

Western Great Plains Shortgrass Prairie and Apacherian-Chihuahuan Mesquite Upland Scrub 

vegetation communities within the 16 ha (40 ac) facility footprint. However, neither of these 

vegetation communities provides unique habitat in the area and the impacted area of 16 ha 

(40 ac) constitutes a small fraction of these vegetation communities in the vicinity of the 

proposed IIFP site (see Figure 3-19). Therefore, the NRC staff finds that the loss of 16 ha 

(40 acres) of either habitat type would have a SMALL impact on native vegetation in the vicinity 

of proposed action. 
 4-13 

During construction, the presence of humans, the presence of construction equipment and 

associated noise and vibrations, and general construction activities could result in animals 

currently using the property, such as birds, foxes and other small mammals, to avoid the 

construction area. Many other species, such as rodents, and some reptiles, are small, have 

limited mobility, occur in habitats that provide concealment, or spend at least a portion of their 

lives underground. During site clearing and grading activities, it is likely that some individuals of 

these species will not survive the construction activities. Rodents and larger mammals and 

reptiles may be killed along access roads by vehicles moving to and from the site. There are 

many square miles of undeveloped land surrounding the IIFP site (i.e., Section 27) which have 

native vegetation and habitats suitable for native species. As discussed in Section 3.8.3 the 

species of wildlife present or that could be present are typical of those found in the habitat in the 

surrounding area. Because the area surrounding the proposed IIFP site is largely undeveloped 

(see Section 3.2), there is sufficient suitable habitat in the vicinity of the project to support 

displaced animals. Therefore the NRC staff finds that impacts to ecological resources from 

construction of the proposed facility would be SMALL. 

4.1.1.8 Socioeconomic Resources and Environmental Justice 

This section analyzes the potential social and economic (socioeconomic) impacts associated 

with construction of the proposed IIFP facility. As discussed in Section 3.9, most socioeconomic 

impacts would occur within a two-county area (Lea and Eddy Counties, New Mexico), where the 

majority of the construction workforce would live and spend their wages. These two counties 

comprise the socioeconomic Region of Interest (ROI) in these analyses which are based on 

IIFP’s estimate of a peak of 140 construction workers (IIFP, 2011a). Construction would begin 

in 2012 and be completed in 2013. Wage and salary spending would have a small positive 

economic benefit in the ROI, and expenditures associated with materials, equipment, and 

supplies would produce local and State tax revenue. The migration of workers and their families 

into the area would slightly increase the population of the ROI and affect housing availability and 

community services such as education, fire protection, law enforcement, medical resources, and 

the availability of public utilities. 

The major factor influencing socioeconomic impacts of construction is the number of 

construction workers who would relocate to the area with their families. An NRC staff study, 

Migration and Residential Location of Workers at Nuclear Power Plant Construction Sites 

(BMI, 1981) evaluated behaviors and characteristics of construction workers at nuclear power 

plant construction sites. It provides a methodology for estimating in-migrating workforce sizes 

and residential distribution patterns at nuclear power plant construction sites. There is no 

evidence that the fundamental nuclear construction workforce characteristics and behaviors 

have changed appreciably since the study’s publication. The proposed IIFP facility is a nuclear 

fuel cycle facility, and, as such would require construction methods, quality control, and safety 

procedures similar to those used for constructing nuclear power plants. Therefore, the current 

analysis assumed that the construction behaviors and characteristics identified in the BMI study 

would be a fair representation of the expected IIFP construction workforce, and therefore the 

worker migration patterns and family characteristics described in the BMI study remain valid 

assumptions. The BMI study indicates the following construction worker characteristics: 

• Between 15-35 percent of the construction workforce would migrate into the ROI. 

• Approximately 70 percent of in-migrating construction workers are likely to bring families 

(this may be an overestimate for a construction job with a duration of one year, however, 

to be conservative, the NRC staff maintained this assumption). 
 4-14 

• Average family size of a construction worker is 3.25 persons. 

• Average number of school-aged children per construction worker family is 0.8. 

• Approximately 50 percent of the in-migrating construction workforce will remain in the 

ROI following construction. 

IIFP anticipates the peak number of construction workers would be 140. In 2008, construction 

and mining employment provided more than 28 percent of all non-farm employment in the ROI. 

They are two of the largest employment sectors in the ROI. Because of the presence of 

workers with construction experience, the NRC staff estimates that 80 percent of the total 

construction workforce would already reside within the ROI and 20 percent would migrate into 

the ROI. An estimate of 20 percent in-migrants is within the range of the in-migrating 

construction workforce identified in the BMI study when there is already an existing, viable 

construction workforce within the ROI. Table 4-7 depicts workforce in-migration, family, and 

workforce retention characteristics based on the BMI study and the maximum workforce for the 

construction of the proposed IIFP facility. These projections are used throughout this analysis. 

4.1.1.8.1 Population 

As presented in Section 3.9.1.2, the population within the ROI was 112,938 persons in 2009. 

Construction of the proposed IIFP facility would directly employ a maximum of 140 people, of 

which 80 percent would be ROI residents. The other 20 percent (28 workers) would migrate 

into the socioeconomic ROI (Table 4-7). Of the 28 employees that would migrate into the ROI, 

70 percent (20 workers) would bring their families (Table 4-7). Eight construction workers would 

not bring families. Using an average family size of 3.25 from the BMI study, the total 

construction workforce in-migration would result in 72 new residents (Table 4-7) in the twocounty ROI. An increase of 72 residents would result in a 0.06 percent increase in the ROI 

population. 

4.1.1.8.2 Employment and Income 

Workers already residing in the ROI would fill 80 percent of the construction jobs or 112 jobs 

(see Table 4-7). These workers represent 0.2 percent of the June 2010 labor force within the 

ROI. If all 112 of the jobs were filled by unemployed workers, the unemployment rate in the ROI 

would decrease by 0.2 percent. The remaining 28 jobs would be filled by workers migrating into 

the ROI (Table 4-7). The in-migrating workers would increase the labor force by 0.05 percent. 

The U.S. Department of Commerce Bureau of Economic Analysis (BEA), Economic and 

Statistics Division uses an economic model called RIMS II, which incorporates buying and 

selling linkages among regional industries and uses a multiplier specific to an industry to 

estimate the economic impact within the region. The multiplier is the number of times the final 

increase in consumption exceeds the initial dollar spent. In this analysis, the NRC staff uses the 

multiplier for the construction industry in the ROI to estimate the number of indirect jobs that 

would result from the in-migration associated with the construction of the proposed IIFP facility. 

Indirect jobs are often non-technical and non-professional positions in the retail and service 

sectors. The 12 indirect jobs that would be created (Table 4-8) would likely be filled by ROI 

residents. If all 12 jobs were filled by unemployed workers, those workers would represent 

0.3 percent of the unemployed labor force in June 2010. 
 4-15 

Table 4-7. Assumptions for Workforce Characterization during Peak Construction 

Period 

Workforce characterization 

Peak number of workers on site during construction 1 140 

Workforce migration 

Percent of construction workers migrating into ROI 2 20% 

Total number of construction workers migrating into ROI during construction peak 3 28 

Families 

Percent of construction workers who bring families 2 70% 

Percent of construction workers who do not bring families 3 30% 

Average construction worker family size (worker, spouse, children) 2 3.25 

Number of construction workers who would move into ROI and bring families 20 

Post-construction workforce retention 

Number of construction workers who would move into ROI and would not bring families 8 

Number of construction worker family members who would move into ROI 44 

Total number of workers and family members migrating into ROI (new population in ROI) 72 

School-age children 

Number of school-age children per family 2 0.8 

Number of school-age children in ROI 16 

Percent of in-migrating workers that would leave ROI, post-construction 2 50% 

Number of in-migrating workers that would leave ROI, post-construction 14 

Total number of in-migrating workers and family members that would leave ROI, postconstruction 36 

Number of school-age children of in-migrating workers that would leave ROI, postconstruction 8 

Source: 

1 IIFP, 2011a 

2 BMI, 1981 

3 See Appendix D 

Note: there are slight variations in the calculations due to rounding, 

Table 4-8. Direct and Indirect Employment 

Construction workforce peak (Table 4-7) 140 

Number of construction workers who migrate into ROI (20 percent of 

construction workforce peak) (Table 4-7) 

28 

Employment multiplier for construction in ROI (BEA, 2010) 0.4324 

Indirect jobs resulting from in-migrating construction workers 

(i.e., 28x0.4324=12) 

12 

Expenditures for goods and services to support construction activities would occur both inside 

and outside the ROI. Approximately $70 million to $94 million in capital costs would be spent 

for construction (IIFP, 2009a). Also, construction workers would spend a portion of their 
 4-16 

earnings on goods and services within the ROI. Construction worker wages are estimated to 

average $32,700 annually (IIFP, 2011a). 

The NRC staff finds that due to the size of the available workforce in the ROI, the effect of 

construction on employment and income within the ROI would be SMALL and beneficial. 

4.1.1.8.3 Taxes 

Construction-related activities, purchases, and workforce expenditures would generate several 

types of taxes, including individual income taxes, gross receipts taxes, and property taxes. 

Increased tax collections are viewed as a benefit to the State of New Mexico, Lea County, the 

Hobbs Municipal School District, the New Mexico Junior College, the communities in Lea 

County, and other locales where plant-related spending would occur. 

Income Taxes 

New Mexico imposes a tax on the net income of every resident and nonresident employed or 

engaged in business in or from the State or deriving any income from any property or 

employment within the State. The rates vary depending upon filing status and income 

(Section 3.9.3). Construction wages would be taxed as income and the NRC staff finds that 

those tax payments would have a SMALL, beneficial impact. 

IIFP would not pay corporate income tax during construction. 

Gross Receipts Taxes 

New Mexico has a gross receipts tax structure instead of a sales tax structure. Like sales taxes, 

gross receipts taxes are generated by the purchase of goods and services. The gross receipts 

tax rate varies throughout the state from 5.125 percent to 8.6875 (Section 3.9.3). 

IIFP estimates (in 2009 dollars) that construction capital costs would be between $70 million 

and $94 million. Some portion of those expenditures would occur within the ROI and adjacent 

counties. The expenditures would generate gross receipts tax revenues for both the counties 

and New Mexico (IIFP, 2009a). The NRC staff finds that these revenues would be SMALL and 

beneficial. Because IIFP would have an industrial revenue bond with Lea County, some 

expenditure would be exempt from gross receipts taxes. 

Regional spending on goods and services by the construction workforce would generate gross 

receipts tax revenues for Lea County and Eddy County municipalities, the two counties, New 

Mexico, and other locales where spending occurs. The NRC staff finds that this increase in 

gross receipt taxes would create a SMALL, beneficial impact. 

Property Taxes 

Property taxes in Lea County are derived using property assessment values (33.3 percent of 

appraised values) and the tax rates of the taxing entities. The annual payment in lieu of tax 

(PILT) to the Hobbs Municipal School District is based on a tax rate of $7.60 per $1,000 of 

assessed value (IIFP, 2011a). The annual PILT to the New Mexico Junior College is based on 

a tax rate of $4.30 per $1,000 of assessed value (IIFP, 2011a). Based on the estimated 

assessed value of the IIFP land and attachments to the land and on the equipment and 

materials, the estimated PILTs during the construction would be $261,000 in 2012 and 
 4-17 

$293,400 in 2013 (IIFP, 2011a). According to Table 3-28, the Hobbs Municipal School District’s 

total 2007-2008 revenues were about $71 million and the New Mexico Junior College’s total 

2008-2009 revenues were about $37 million. Therefore, the NRC staff finds that the property 

tax impact of construction would be SMALL (less than 1 percent of the school revenues in all 

cases) but nonetheless, beneficial. 

4.1.1.8.4 Housing 

In 2008, 5,823 vacant housing units were within the ROI (Section 3.9.4). Construction would 

result in an influx of approximately 28 construction workers (Table 4-7), all of whom would need 

housing. Housing the 28 in-migrating construction workers would require 0.5 percent of the 

vacant housing units within the ROI. The in-migrating workers would not adversely affect the 

existing housing inventory. In addition, the ROI has temporary housing in hotel/motel rooms 

available for short-term leasing and areas available for trailers and recreational vehicles that 

some workers may elect to live in. 

Because the existing vacant housing inventory would be sufficient to accommodate the 

expected population increase associated with the proposed IIFP construction project, the NRC 

staff finds that the impact of construction on housing would be SMALL. 

4.1.1.8.5 Public Utilities 

Public Water 

All onsite potable, process, and fire water needed during the construction of the IIFP facility 

would be provided by one or two wells installed in the Ogallala aquifer (IIFP, 2009a). During 

construction, 72 people (Table 4-7) would relocate to the ROI and likely find housing within an 

area that is served by a public water utility. The major public water suppliers in the ROI serve 

88,643 people (Table 3-30) and most have excess capacity. The in-migration during 

construction would result in a 0.08 percent increase in people who rely on the ROI’s public 

water supply. The NRC staff finds that the impact of construction on public water supplies 

would be SMALL, because the excess capacity of water suppliers in the ROI is sufficient to 

support the in-migrating workforce. The construction site would not be connected to a public 

water supply. 

Public Wastewater 

There would be no onsite disposal of any solid or liquid waste during construction of the IIFP 

facility. The proposed IIFP site would not be connected to any public wastewater or sewage 

system (IIFP, 2011a). All wastes generated during construction, including sanitary wastes, 

would be shipped offsite for disposal. During construction, 72 people (Table 4-7) would relocate 

to the ROI and likely find housing within areas that are served by a public wastewater system. 

The major public wastewater treatment facilities in the ROI serve approximately 78,917 people 

(Table 3-31) and all have excess capacity. Construction in-migration would result in a 

0.09 percent increase in people who rely on the ROI’s public wastewater systems. Therefore, 

the NRC staff concludes that the impact of construction on public wastewater would be SMALL. 
 4-18 

4.1.1.8.6 Community Services 

Education 

In 2008, there were 8 public school districts, containing 64 schools, educating 22,847 students 

in the ROI (Section 3.9.6.1). Construction would result in an influx of approximately 28 

construction workers, 20 of whom would bring their families (Table 4-7). Each in-migrating 

family is estimated to have 0.8 school-aged children (Table 4-7); therefore, 16 children could 

require public school during construction (Table 4-7). The new student enrollment resulting 

from construction would represent an increase of 0.07 percent in the 2008 enrollment in the 

ROI. The increase in public school enrollment would be less than 1 percent of total enrollment 

and would be essentially undetectable. Therefore, the NRC staff concludes that the impact of 

construction on education would be SMALL. 

Fire Protection 

The in migrating workforce would increase the population in the ROI less than 0.1 percent 

(Section 4.1.1.8.1) and would result in filling 0.5 percent of the available housing. Therefore, 

there would not be a detectable increase in the demand for fire protection. Existing fire 

protection personnel, facilities, and equipment would be sufficient to support the population 

increase. Therefore, the NRC staff concludes that the impact of construction would be SMALL. 

Law Enforcement 

The in migrating workforce would increase the ROI population less than 0.1 percent 

(Section 4.1.1.8.1) and would not change the ability of existing law enforcement services to 

meet the needs of the population. Existing law enforcement personnel, facilities, and equipment 

would be sufficient to support the population increase; therefore, the NRC staff concludes that 

the impact of construction of the proposed IIFP facility would be SMALL. 

Hospitals and Physicians 

An ROI population increase of less than 0.1 percent (Section 4.1.1.8.1) would not measurably 

increase the demand for hospital and physician services. Therefore, the NRC staff concludes 

that the impact of construction on hospitals and physician services would be SMALL. 

4.1.1.8.7 Environmental Justice 

Environmental Justice refers to a Federal executive order that directs all Federal agencies, 

including the NRC, to identify and address disproportionately high and adverse human health 

and environmental effects on minority or low-income populations. Section 3.9.1.2 defines and 

identifies the minority and low-income populations within the 80-km (50-mi) radius of the 

proposed IIFP site. There are 96 block groups that fall completely or partially within the 80-km 

(50-mi) radius of the proposed site. Of the 96 block groups, 1 has a significant African 

American population, 15 have significant “some other race” populations, 32 have significant 

Hispanic populations, and 10 have significant low-income populations. The locations of these 

block groups are shown on Figures 3-22, 3-23, 3-24 and 3-25. The following discussion 

summarizes project impacts on the general population and addresses whether or not minority 

and low-income populations would experience disproportionately high and adverse impacts. 

The primary resource areas that could be affected by construction are soil, groundwater quality, 

groundwater quantity, air quality, ecology, and socioeconomics. 
 4-19 

• Land Use – The primary land use on the proposed IIFP site is cattle grazing. Less than 

10 percent of the 259-ha (640-ac) site area would be disturbed during construction, and 

cattle grazing would not be permitted on the site. Construction would not conflict with 

any existing Federal, State, local, or Indian Tribe land use plans, or planned 

development in the area. The NRC staff finds that the land use impacts resulting from 

construction and conversion from agricultural (grazing) land use to industrial use would 

be SMALL due to the abundance of other nearby grazing land (Section 4.1.1.1 Land 

Use). 

• Soils – The largest potential for impacts on soils during construction would result from 

clearing and grading, which loosens soil and increases the potential for erosion by wind 

and water. BMPs would be implemented during construction to limit soil loss. The NRC 

staff finds that the construction impacts on soils would be SMALL and confined to the 

site (Section 4.1.1.5 Geology, Minerals, and Soils). 

• Groundwater quality – Groundwater beneath the proposed IIFP site is unconfined and 

recharged by natural precipitation, therefore, uncontrolled spills during construction 

could temporarily and locally affect the aquifer. However, a site-specific Spill Prevention 

Control and Countermeasure Plan would be developed with procedures to manage 

spills. Therefore, the NRC staff finds that impacts on groundwater quality would be 

SMALL, localized, and temporary (Section 4.1.1.6 Water Resources). 

• Groundwater quantity – No municipal water line runs near the proposed IIFP facility. 

Water brought in tanker trucks from Hobbs, or one or two wells onsite would supply all of 

the water for the construction activities. Average and peak site water requirements for 

construction are expected to be approximately 6.05 L/min (1.6 gpm) and 20.5 L/min 

(5.42 gpm), respectively. Because the IIFP site is not located in a critical management 

area (CMA, the legal drawdown limit for any wells on the property would be on average 

0.06 m/yr (0.20 ft/yr). It is unlikely that the two wells would ever exceed the Lea County 

Underground Water Basin drawdown limit (Section 4.1.2.6 Water Resources). 

Therefore, the NRC staff finds that impacts to groundwater quantity would be SMALL. 

• Air quality – Section 4.1.1.4 reports that site boundary concentrations of some criteria air 

pollutants would be higher than the NAAQS. Therefore, the NRC staff finds that Phase 

1 construction impacts to air quality would be SMALL to MODERATE and localized. 

• Ecology – Approximately 16 ha (40 ac) of land would be disturbed, which represents 

less than 10 percent of the total 259 ha (640 ac) site. Construction would destroy or 

displace local wildlife. No impacts to rare or unique habitats, threatened or endangered 

species, or commercially or recreationally valuable species would result from 

construction. The NRC staff finds that potential impacts to ecological resources during 

construction would be SMALL and localized (Section 4.1.1.7 Ecological Resources), 

based on the small area that would be impacted, compared to the available comparable 

habitat within the region. 

• Socioeconomics – Construction would require a maximum of 140 workers, 28 of whom 

would migrate into the ROI, 20 of whom would bring families. The potential in-migrating 

population would increase the population within the ROI by 0.1 percent. The NRC staff 

concludes that this small increase in the population within the ROI would have a SMALL 

impact on employment, taxes, housing, community services, and public utilities (Section 

4.1.1.8 Socioeconomics). 

The NRC staff concludes that the impacts of construction on each of these resource areas 

would be SMALL (SMALL to MODERATE for air quality) and localized. Furthermore, the 
 4-20 

nearest minority or low-income population meeting the NRC definition is 22.5 km (14 mi) from 

the proposed site. Therefore, because potential impacts to all resource area impacts would be 

SMALL or MODERATE and localized, and the identified minority and low-income populations 

are not in close proximity to the proposed site, the NRC staff finds that impacts would not be 

disproportionately high and adverse for any populations in the region, including minority or lowincome populations. 

4.1.1.9 Traffic and Transportation 

This section identifies the traffic and transportation impacts within the region during 

construction. The transportation mode for personnel, construction equipment, and materials 

deliveries would be exclusively by roadways to the proposed IIFP site. There are no plans to 

extend the railroad in Hobbs to transport goods or materials to the proposed site. Although 

routine rail freight and air freight is expected to be used for shipping materials or equipment to 

the region, this freight would be offloaded elsewhere and arrive at the site on trucks. 

The principal highway routes that would handle this traffic include NM 483, which borders the 

site to the west, and US 62/180, which provides an east-west route to the nearest population 

centers. All traffic would access the site via NM 483, and most traffic would use US 62/180 to 

NM 483 to access the site. Some portion of the workforce may access the site from the north, 

using NM 83 to access NM 483 north of the site. At the junction of NM 483 and US 62/180, 

traffic would go east to Hobbs, Eunice and other Lea County municipalities or southwest to 

Eddy County. After the intersection of NM 483 and US 62/180 traffic associated with the site 

would be increasingly dispersed. 

Peak construction would use 140 workers (IIFP, 2011b). Therefore, if each employee 

commutes alone, there would be an increase of 140 vehicles on NM 483. IIFP estimated 

20 delivery or waste disposal trucks each day, for an additional 40 additional trips during one 

construction shift. 

The Highway Capacity Manual 2000 (TRB 2000) indicates that the capacity of a two-lane 

highway is 1,700 passenger cars per hour for a single direction and 3,400 passenger cars per 

hour for both directions. The annual average daily traffic count (AADT) on NM 483, a two-lane 

highway, at the intersection of US 62/180 in 2008 was 955 vehicles per day (NMDOT, 2009). If 

all the vehicles on NM 483 in one day used the road in a single hour, and if the construction 

workforce used the road to access the site during that same hour, a maximum of 1,095 vehicles 

would be on the road. This is less than the design capacity of a two-lane highway. Traffic 

impacts on NM 483 due to 20 truck trips per shift would have a smaller impact than the scenario 

described here. The maximum construction traffic on US62/180, which is a four-lane highway, 

also would have a smaller impact that that of the scenario analyzed here. Therefore, the NRC 

staff concludes that impacts to traffic from construction would be SMALL. 

The potential for traffic accidents increases with increased traffic. Assuming that the majority of 

the workers and trucks would travel from Hobbs (a distance of 23.3 km [14.5 mi ]) and Lovington 

(24.9 km [15.5 mi]), and a small percentage would come from Carlsbad (80 km [50 mi]), the 

NRC staff estimates an average one-way commute distance of 32 km (20 mi). Delivery trucks 

would travel an average round trip distance of 80 km (50 mi). A 64-km (40-mi) daily commute 

by 140 commuting workers and an 80-km (50-mi) commute by 20 truck results in 10,600 km 

(6,600 mi) traveled each day for 250 work days per year during the peak construction period. In 

New Mexico in 2010, vehicle accidents resulted in 51.73 injuries and 1.73 fatal accidents per 

160 million vehicle-km (100 million vehicle-mi) (UNM, 2010). Based on these rates, statistically, 
 4-21 

there would be one injury (risk of less than 0.85 injury crashes per year) and no fatalities (risk of 

less than 0.03 fatal crashes per year) as a result of the construction traffic. 

Therefore, the NRC staff concludes that impacts to traffic due to construction would be 

temporary and SMALL. 

4.1.1.10 Noise 

As discussed in Section 3.11, noise from the construction of the proposed facility would be 

restricted to daylight hours, temporary, and attenuated with distance. Four industrial facilities 

are within 5 km (3.1 mi) of the site. The nearest residence is approximately 2.6 km (1.6 mi) 

northwest of the site and there are no recreational facilities within 8.0 km (5.0 mi) of the 

proposed site. Because the construction equipment noise will attenuate within a short distance 

of the proposed IIFP site, the nearest residence and other land uses would not be adversely 

affected by construction noise. The NRC staff finds that impacts due to noise would be SMALL, 

based on the distances to surrounding residences and recreational areas and the rate at which 

noise is attenuated with distance. 

4.1.1.11 Public and Occupational Health Impacts 

This section analyzes the potential impacts on public and occupational health from the proposed 

IIFP facility construction. The analysis is divided into two main sections: nonradiological 

impacts and radiological impacts. 

The proposed action involves a major construction activity with the potential for industrial 

accidents, material-handling accidents, and construction accidents that could result in temporary 

injuries, long-term injuries and/or disabilities, and fatalities. 

The number of potential fatal and nonfatal occupational injuries from construction of the 

proposed IIFP facility were estimated based on injury rate data from the U.S. Department of 

Labor’s Bureau of Labor Statistics. As shown in Table 4-9, six nonfatal injuries and less than 

one fatality are expected during construction. Additionally, because of the commitment that IIFP 

is making to a safe design basis for facilities and programs, its safety culture, and adherence to 

the Integrated Safety Management System program and procedures, the occupational injury 

rates during construction of the proposed IIFP facility could be better than the industry average. 

Therefore, the NRC staff concludes that impacts to human health from occupational injuries 

during construction would be SMALL. 

Table 4-9. Nonfatal/Fatal Occupational Injuries Projected for IIFP Facility Construction 

Category Injury Rate Expected Occurrences1

Nonfatal Injuries 4.3 injuries per 100 workers per year2 6.0 

Fatal Injuries 9.7 fatalities per 100,000 workers per year3 less than 1 (1.4 x 10-2) 1

 Expected occurrences are based on an average of 140 workers during the construction of the facility for 12 months 

(IIFP, 2011a). 

2

 The expected nonfatal injury rate (total recordable cases) is from BLS (2010a). 3

 The fatal injury rate is from BLS (2010b). 

In addition to the potential occupational injuries that could result during construction, impacts to 

the public from air pollutants have been considered. Air pollutants would be generated by the 

internal combustion engines used in heavy equipment. As discussed in Section 4.1.1.4, the 
 4-22 

estimated air quality impacts from the air emissions during construction for the proposed IIFP 

facility would not measurably change the existing ambient air quality in the vicinity of the 

proposed IIFP facility. As a result, the NRC staff finds that the impacts to human health from air 

pollutants would be SMALL. 

4.1.1.12 Waste Management 

Construction of the proposed IIFP facility would generate waste materials that would be 

collected and transported offsite for recycling or disposal. Refuse and construction debris 

typical of industrial construction projects would be the predominant wastes generated during the 

construction phase (IIFP, 2011a). IIFP conservatively assumes that small quantities of low level 

radioactive wastes are also expected to be generated during the construction phase. This is 

because IIFP plans to install previously-used process vessels and standard unit operations 

equipment shipped from the decommissioned Sequoyah uranium conversion facility in Gore, 

Oklahoma, to the proposed IIFP facility (IIFP, 2011a; IIFP, 2011b). Because this equipment has 

been used for processing of radioactive materials, refuse and construction debris from its 

transport and installation could be disposed of as LLW as a precaution. 

The anticipated construction wastes include paper, plastic, cardboard, packaging materials, 

wood scraps, metal scraps, roofing and insulation scraps, masonry and ceramic materials, and 

empty paint and coating containers. Small quantities of organic solvent-based residuals 

remaining from application of specialty paints, architectural coatings, sealants, and adhesives, 

and wastes from certain other materials that are used for construction may be required to be 

managed as hazardous waste. The specific compositions and quantities for these construction 

waste types would depend on the final facility design (IIFP, 2011a). Tables 4-10 through 4-12 

provide the estimated annual quantities of solid, hazardous, and LLW currently anticipated by 

IIFP to be generated during construction, respectively. 

The general design/build contractor selected for the proposed IIFP facility would have 

responsibility for the day-to-day supervision of onsite waste collection and storage and for 

arranging for removal of these wastes from the IIFP site. Good work practices would be used to 

collect and sort the wastes for recycling or disposal (e.g., using designated roll-off containers 

and collection areas for different types of wastes). Solid (nonhazardous, nonradioactive) wastes 

would be transported offsite to an approved local landfill. Hazardous waste generated 

throughout the construction phase would be temporarily stored onsite and then shipped to an 

offsite facility appropriate for handling the waste composition, in accordance with established 

recycling and hazardous waste management programs. Any radiological waste would be 

shipped offsite to licensed LLW disposal facilities (IIFP, 2011a). The management of 

stormwater at the proposed IIFP facility is discussed in Section 4.1.1.6. 

The proposed IIFP facility would be located in the New Mexico Environment Department 

(NMED) district comprising Chaves, Eddy, Lincoln, and Lea Counties. At present disposal 

rates, the remaining disposal life of the three permitted solid waste landfills (Roswell Municipal 

Landfill, Sand Point Landfill, and Lea County Landfill) in that district ranges from 16 years to 

63 years (NMED, 2009). This district also has an “industrial waste only” landfill, Lea Land, Inc. 

Industrial Landfill, with an anticipated remaining disposal life of more than 100 years (NMED, 

2009). Nonhazardous wastes from the proposed IIFP facility would likely be transported to the 

Lea County landfill for disposal. The landfill accepts residential, commercial, private and public 

waste material from generators within a 161-km (100-mi) radius. The landfill is operated by the 

Solid Waste Authority of Lea County under NMED Permit # Stormwater Management
 4-23 

Table 4-10. Solid Waste Generation - Construction 

Waste Type Estimated Annual Amount 

Air filters (vehicle) 23 – 45 kg 

(50 – 100 lbs) 

Cardboard / packing 140 – 230 kg 

(300 – 500 lbs) 

Fiber drums 140 – 230 kg 

(300 – 500 lbs) 

Total 300 – 500 kg 

(650 – 1,100 lbs) 

Source: IIFP, 2011a 

Table 4-11. Hazardous Waste Generation - Construction 

Waste Type Estimated Annual Amount 

Adhesives, resins, caulking residues 45 – 90 kg 

(100 – 200 lbs) 

Lead (batteries) 45 –110 kg 

(100 – 250 lbs) 

Oil filters 45 – 90 kg 

(100 – 200 lbs) 

Paints, thinners, solvents, organic residues 45 – 230 kg 

(100 – 500 lbs) 

Pesticides 45 – 68 kg 

(100 – 150 lbs) 

Petroleum products, oils, lubricants residues 45 – 230 kg 

(100 – 500 lbs) 

Total 270 – 820 kg 

(600 – 1,800 lbs) 

Source: IIFP, 2011a 

Table 4-12. Low Level Radioactive Waste Generation - Construction 

Material Estimated Annual Amount 

Scrap metal 1,800 – 2,700 kg 

(4,000 – 6,000 lbs) 

Spent blasting sand 45 kg 

(100 lbs) 

Wood trash (pallets) 450 – 680 kg 

(1,000 – 1,500 lbs) 

Total 2,300 – 3,400 kg 

(5,100 – 7,600 lbs) 

Source: IIFP, 2011a 

(SWM) -13030. The Lea County landfill receives approximately 74,800 metric tons 

(82,500 tons) annually (NMED, 2009). Nonhazardous waste generated from the proposed IIFP 

construction activities would result in a negligible increase (less than 0.5 metric ton or 

0.0007 percent) in the waste that the Lea County landfill receives annually from all other 

sources. Therefore, the NRC staff finds that the solid waste management impacts resulting 

from construction of the IIFP facility would be SMALL. 
 4-24 

Hazardous wastes generated during construction would be packaged and shipped offsite to 

licensed hazardous waste treatment and disposal facilities in accordance with Federal and State 

regulations (IIFP, 2011a). The projected annual hazardous waste generation would likely 

classify the proposed IIFP facility as small quantity generator (over 100 kg/mo [220 lb/mo] but 

less than 1,000 kg/mo [2,200 lb/mo]) during construction. Hazardous waste generators in New 

Mexico accounted for 978,000 metric tons (1,079,000 tons) of hazardous waste in 2009, with all 

but 3,700 metric tons (4,084 tons) originating at one facility operated by the Navajo Refining 

Company (EPA, 2010b). Less than 0.9 metric tons (1 ton) per year of hazardous wastes would 

be expected from construction of the proposed IIFP facility. The IIFP facility would, during 

construction, be one of the smaller hazardous waste generators in New Mexico and would 

contribute less than 0.00009 percent to the overall hazardous waste generated in the State. 

Therefore, the NRC staff concludes that the quantity of construction-generated hazardous waste 

material would result in SMALL impacts that could be managed effectively. 

Radiological waste generated during construction, due to the use of previously-used radiological 

processing equipment, would be shipped offsite to licensed LLW disposal facilities (IIFP, 

2011a). As shown in Table 4-12, up to 3.4 metric tons (3.8 tons) per year of LLW could be sent 

for disposal. That corresponds to approximately 22.5 drums per year. This LLW volume 

represents 0.008 percent of the annual commercial waste volume currently received at the 

EnergySolutions facility in Clive, Utah (NRC, 2010). All LLW generated will be Class A wastes 

as defined by 10 CFR 61.55 (IIFP, 2009a). The Clive facility accepts the majority of the United 

States’ Class A LLW (as detailed in 10 C.F.R. § 61.55, Waste Classification, enforced by NRC) 

and is estimated to have capacity to accept this waste at current volume levels for more than 

20 years (GAO, 2004). Thus, the NRC staff finds that the quantity of construction-generated 

LLW would result in SMALL impacts to LLW disposal capacity. 

4.1.2 Environmental Impacts of Operation 

The impacts of operations of the facility described in Chapter 2 on each of the major resource 

areas described in Chapter 3 (Affected Environment) are presented in this section. Impacts of 

the proposed Phase 2 facility activities identified in Chapter 2 are evaluated as cumulative 

impacts in Section 4.2. 

4.1.2.1 Land Use 

This section describes the potential impacts on land use during operation of the proposed IIFP 

facility. 

During operations the primary current land use at the site, which is cattle grazing, would be 

eliminated by a fence surrounding the entire 259-ha (640-ac) site. Except for the 16-ha (40-ac) 

facility footprint, the remainder of the site (240 ha or 600 ac) would be remain undeveloped for 

the duration of the license. Operation of the proposed IIFP facility would be consistent with the 

industrial nature of land in the vicinity which supports four energy production facilities (Xcel 

Energy’s Cunningham Station and Maddox Station, Colorado Energy Station, and the DCP 

Midstream Linam Ranch Plant). The proposed IIFP facility and retention of the remaining 

portion of the site as undeveloped land would not conflict with any existing Federal, State, local, 

or Native American tribal land use plans. The use of land for the facility would not interfere with 

any planned development in the area (Appendix A). The facility’s location within Section 27 was 

selected to avoid, to the extent possible, utility rights-of-way, and operation of the facility will not 

prohibit access to the rights-of-way for maintenance. None of the Cunningham Station’s 

monitoring wells in Section 27 would be affected by the operation of the facility 
 4-25 

(GL Environmental, 2010). Because many square miles around the facility have similar habitat, 

and because the industrial nature of the facility would be consistent with local land use, the NRC 

staff concludes that land use impacts associated with operation of the proposed facility would be 

SMALL. 

4.1.2.2 Historic and Cultural Resources 

This section describes the potential environmental impacts on historic and cultural resources 

resulting from operation of the proposed IIFP facility. Impacts to historic or cultural resources 

would most likely occur during ground-disturbing activities associated with construction. 

Therefore, because operations would not require additional land disturbance, the NRC staff 

concludes that any impacts to historic properties, districts, resources or significant 

historic/precontact archaeological sites during facility operation would be SMALL. 

4.1.2.3 Visual Resources 

This section discusses the potential visual and scenic impacts that could result from operation of 

the proposed IIFP facility. Visual impacts could occur as a result of tall or massive structures 

being imposed on a landscape, or if plumes visible from a long distance were emitted from a 

facility. 

The tallest proposed building would be 21.3 m (70 ft) high and emission stacks would be less 

than 30.5 m (100 ft) tall (IIFP, 2009a); well under the 61-m (200-ft) threshold that requires lights 

for aviation safety (FAA, 1992). The facility will not be visible from any recreational or historic 

facilities, and will not degrade the existing viewscape which includes four other industrial 

facilities. In addition, security lighting would be directed downward to minimize light pollution 

(IIFP, 2009a), therefore, the NRC staff concludes that impacts to visual resources would be 

SMALL. 

4.1.2.4 Climate, Meteorology and Air Quality 

4.1.2.4.1 Greenhouse Gases 

This section presents an assessment of the effect operation of the proposed IIFP facility could 

have on the concentrations of CO2 and other greenhouse gases in the atmosphere. 

During operation, greenhouse gas emissions would result from workforce commuting, deliveries 

of feedstock and consumable materials to the proposed facility, return of empty feedstock 

containers to their points of origin, transfer of wastes to designated offsite disposal facilities and 

operation of a gas-fired boiler. An incidental amount of greenhouse gas emissions would result 

from the onsite storage and dispensing of fossil fuels to support operations, but is not evaluated 

here. 

A workforce of 140 is assumed to commute a round-trip distance of 64 km (40 mi), assuming 

250 round trips per year and taking no credit for carpooling or busing. Annually, the workforce 

would commute approximately 2,200,000 km (1,400,000 mi). 

Deliveries and returns of DUF6 cylinders and waste shipments are estimated at 2,650 round 

trips per year. Thus, an average of approximately 10 truck round trips would occur daily during 

a 5-day work week. The DUF6 feed materials for the facility would be transported by 

18-wheeled trucks via highway only and are expected to come from several facilities across the 
 4-26 

country: the URENCO USA facility approximately 53 km (33 mi) away; Global Laser 

Enrichment 2,600 km (1,616 mi) away; and the Eagle Rock Enrichment Facility approximately 

1,796 km (1,116 mi) away. Waste from the IIFP facility would likely be transported to one of 

several disposal facilities. One low-level waste disposal facility is the EnergySolutions facility in 

Clive, Utah approximately 1,572 km (977 mi) from the IIFP site. Hazardous and mixed low-level 

radioactive wastes could be disposed at Waste Control Specialists which is approximately 

61 km (38 mi) from the IIFP facility. Because it is difficult to anticipate the proportion of 

shipments among the DUF6 feed materials suppliers and waste disposal sites, an average of the 

distances to the five facilities was used to establish a conservative scenario with respect to 

GHG emissions. An average roundtrip distance of 2,433 km (1,512 mi) was assumed. The 

resulting annual travel distance is 6,447,450 km (4,006,800 mi). Table 4-13 shows the 

estimated total transportation-related CO2 emission associated with proposed IIFP facility 

operations. The total CO2 emissions expected during IIFP facility operations from commuting of 

the operational workforce, deliveries of feedstock to the proposed facility, return of empty 

feedstock containers to their points of origin and delivery of operational wastes to designated 

offsite disposal facilities are 4,433 metric tons (4,886 tons) per year. NRC staff estimated these 

levels based on modeling summarized and presented in Appendix C (Air Emissions) of this EIS. 

Table 4-13. Annual Transportation-Related CO2 Emissions During IIFP Facility 

Operations 

Activity 

Total 

Workers 

RT Distance Working 

Days/ 

Year 

Total Distances per 

Year 

Annual CO2

Emissions 

(mi) (km) (mi) (km) (ton) (MT) 

Commuting 

traffic 

140 40 64 250 1,400,000 2,300,000 660 599 

Operational 

deliveries and 

waste removal 

shipments 

N/A 1,512 2,433 N/A 4,000,000 6,400,000 4,226 3,833 

Subtotal of CO2

emissions as a 

result of 

transportation 

related impacts 

from IIFP facility 

operations 

_ _ _ _ _ _ 4,886 4,433 

The proposed IIFP facility would also require a gas-fired boiler (the facility would install two 

boilers for redundancy, but only one at a time would operate). The estimated emissions of CO2

equivalents from the boilers are 1,345 metric tons (1,483 tons) per year (IIFP, 2009a). 

Therefore, the total CO2 emissions expected from facility operations are 5,778 metric tons 

(6,369 tons) per year. 

Using calendar year 2000 as a reference point (the latest year for which New Mexico GHG 

emission data are available), and as shown in Table 3-1, total net CO2 emissions for New 

Mexico for the year 2000 were 62 million metric tons (68 million tons) of CO2 equivalents. For 

the United States for that same year, total net CO2 emissions were 5,977 million metric tons 

(6,588 million tons) (EPA, 2010a). By comparison, during any typical year of IIFP facility 

operation, CO2 emissions are projected to be 5,778 metric tons (6,369 tons), approximately 
 4-27 

0.009 percent of the New Mexico statewide output or 0.0001 percent of the nationwide 

emissions for calendar year 2000. Therefore, the NRC staff concludes that impacts from the 

operation of the proposed IIFP facility from the emissions of CO2 and other greenhouse gases 

would be SMALL. 

4.1.2.4.2 Air Quality 

Air quality would be affected during operation of the proposed uranium deconversion facility. As 

discussed in more detail below, the impact levels would not be significant. 

4.1.2.4.2.1 Criteria Pollutant Emissions 

Operation of the proposed project would produce criteria pollutant (i.e., CO, NO2, PM10, PM 2.5, 

SO2, and VOC, an ozone precursor) emissions from natural-gas fired boilers, an emergency 

diesel generator, a fire-water pump, a hydrogen generator, and commuter/delivery vehicles. 

IIFP used emission factors obtained from the EPA document AP-42, “Compilation of Air 

Pollutant Emission Factors” (EPA, 1995a) to estimate emissions from the natural gas boilers, 

emergency diesel generator, and fire water pump. Emissions from each equipment type are a 

function of equipment-specific factors, including engine horsepower, load factor, and hours of 

operation. During operations one boiler would operate continuously, providing 3000 pounds of 

steam per hour for the heating and autoclave feed systems. The diesel generator and fire water 

pump are assumed to be operated for emergency and testing purposes only (IIFP, 2011c). IIFP 

used equipment manufacturer data to estimate emissions from the hydrogen generator. 

Operation of the hydrogen generator would be on demand (IIFP, 2011a). Title V of the 1990 

Clean Air Act Amendments requires facilities defined as "major stationary sources" to obtain a 

Title V operating permit. A major stationary source is any facility that has the potential to emit 

more than 100 tons of any criteria pollutant per year. As shown in Table 4-14, emissions 

resulting from operations at the proposed IIFP facility would be well below the 100 tons per year 

threshold. Therefore, the proposed project would not require a Title V operating permit. 

NRC staff used emission factors to estimate annual criteria pollutant emissions from highway 

vehicles (i.e., worker commute vehicles and delivery vehicles). The emission factors were 

determined using the EPA MOVES Model (EPA, 2009a). Emissions from highway vehicles 

(i.e., worker commute vehicles and delivery and waste transport vehicles) are a function of the 

vehicle-specific factors, including type of vehicle and age, fuel type, and vehicle miles traveled. 

NRC staff used Lea County, New Mexico-specific default values for vehicle type, age, and fuel 

type to determine highway vehicle emission factors. IIFP estimates that during operations 

140 workers would commute to and from the proposed site, an average daily trip distance of 

64 km (40 mi), for 250 days each year. Delivery and waste transport trucks (presumed to be 

diesel-fueled, long-haul semi-trailer trucks averaging 10 mpg) would make on average, 10 trips 

per day (at an average round-trip distance of 2,433 km [1,512 mi]) to transport materials and 

remove wastes. Table 4-15 shows the estimated annual emissions as a result of a commuting 

workforce and material transport. 

To estimate the impact to local air quality, NRC staff compared the total anticipated direct 

(facility) and indirect (highway vehicle) criteria pollutant and VOC emissions from the proposed 

IIFP facility to baseline emissions from Lea County, New Mexico. As shown in Table 4-16, 

emissions from the proposed project would represent a very small portion of the annual criteria 
 4-28 

Table 4-14 Estimated Maximum Annual Criteria Pollutant Emissions from Phase 1 

Operation of the IIFP Facility 

Source 

CO 

metric tons 

(tons) 

NO2 

metric tons

(tons) 

PM2.5 

metric tons

(tons) 

PM10 

metric tons

(tons) 

SO2 

metric tons 

(tons) 

VOC 

metric tons

(tons) 

Boilers 0.93 1.09 0.08 0.08 0.01 0.06 

(1.03) (1.20) (0.09) (0.09) (0.01) (0.07) 

Generators 0.032 0.149 0.011 0.011 0.010 0.00308 

(0.035) (0.164) (0.012) (0.012) (0.011) (0.00340) 

Firewater 

Pump 

0.003 0.013 8.98 x 10-4 9.0 x 10-4 8.4 x 10-4 2.63 x 10-4

(0.003) (0.014) (9.9 x 10-4) (9.9 x 10-4) (9.3 x 10-4) (2.90 x 10-4)

Hydrogen 

Generator 

0.21 0.02 0 0 0 0 

(0.23) (0.02) 0 0 0 0 

Total 1.18 1.27 0.093 0.093 0.020 0.067 

(1.30) (1.40) (0.103) (0.103) (0.022) (0.074) 

Source: IIFP, 2011b 

Table 4-15. Estimated Maximum Annual Criteria Pollutant Emissions from Highway 

Vehicles during Phase 1 Operation of the IIFP Facility 

Source 

CO 

metric tons 

(tons) 

NO2 

metric tons

(tons) 

PM2.5 

metric tons

(tons) 

PM10 

metric tons

(tons) 

SO2 

metric tons 

(tons) 

VOC 

metric tons

(tons) 

Commuter 

Vehicles 

10.9 1.46 0.0266 0.0495 0.0116 1.03 

(12.1) (1.61) 0.(0293) 0.(0545) (0.0128) (1.14) 

Delivery 

Vehicles 

41.0 18.6 0.789 0.953 0.0449 3.50 

(45.2) (20.5) (0.870) (1.05) (0.0495) (3.85) 

Total 51.9 20.0 0.816 1.00 0.0565 4.53 

(57.3) (22.1) (0.899) (1.10) (0.0623) (4.99) 

Source: IIFP, 2011b 

Table 4-16. Comparison of Maximum Annual Emissions from Phase 1 Operations to 

Lea County Baseline Conditions 

Source 

CO 

metric tons 

(tons) 

NO2 

metric tons 

(tons) 

PM2.5

metric tons 

(tons) 

PM10

metric tons 

(tons) 

SO2

metric tons 

(tons) 

VOC 

metric tons 

(tons) 

Operations 53.1 21.3 0.908 1.09 0.0774 4.60 

(58.6) (23.5) (1.00) (1.21) (0.0853) (5.06) 

Lea County 

Baselinea

 

21,244 

(23,417) 

27,119 

(29,894) 

2,892 

(3,188) 

25,048 

(27,611) 

7,334 

(8,084) 

4,436 

(4,890) 

Net Increase 

over Baseline 

0.25% 0.079% 0.031% 0.0044% 0.0011% 0.10% 

a

 Source: EPA, 2009b 
 4-29 

pollutant emissions in Lea County. Because conservative assumptions that tend to 

overestimate impacts were used, actual emissions from operations would be less. 

IIFP used EPA’s SCREEN3 model (EPA, 1995b) to estimate the maximum concentrations of 

pollutants at the IIFP site property line that would be associated with operations. As shown in 

Table 4-17, the estimated incremental increases in ambient background concentrations due to 

the proposed operations would be below allowable PSD Class II increments and well below the 

National NAAQS. VOCs are not included in Table 4-17 because there are no regulatory metrics 

for comparison (VOC emissions are regulated by source controls and permit requirements). 

Table 4-17. Predicted Property Boundary Concentrations Due to Phase 1 Operations, 

NAAQS and Allowable Class II PSD Increments 

Pollutant 

Averaging 

Time 

NAAQS 

(μg/m3) 

Allowable 

Class II PSD 

Increment 

(μg/m3) 

Incremental 

Concentration 

Increase 

(μg/m3

) 

Incremental 

Concentration 

Increase as 

Percentage of 

NAAQS 

CO 1-hr 

8-hr 

10,000 

40,000 

NA 5.8 0.06% 

NA 4.1 0.010% 

NO2 Annual 100 25 0.059 0.6% 

PM2.5 24-hr 

Annual 

35 

15 

9 0.17 0.5% 

4 0.042 0.3% 

PM10 24-hr 150 8 0.17 0.11% 

SO2 1-hr 

3-hr 

200 

1,300 

NA 0.096 0.05% 

512 0.086 0.007% 

Source: IIFP, 2011a; EPA, 2009a 

4.1.2.4.2.2 Nonradioactive Process Effluents 

Radioactive and nonradioactive gaseous effluents would be generated during operation of the 

proposed IIFP facility (IIFP, 2011a). Radioactive gaseous effluents are addressed in 

Section 4.1.2.11. 

IIFP estimated annual nonradioactive process emissions for operation (IIFP, 2011a). 

Nonradioactive gaseous effluents would include HF, SiF4, BF3 CaF2, calcium hydroxide 

[Ca(OH2)], and B2O3. Gaseous effluents from the DU6 to DU4, SiF4 and BF3 processes 

(comprised mostly of nitrogen, air, some relatively low amounts of the product gases and other 

trace fluorides) would undergo treatment in the plant KOH scrubbing system to remove 

approximately 99.9 percent of the fluoride components before being released to the atmosphere 

via a monitored stack (IIFP, 2011a). The plant KOH scrubbing system is described in 

Section 2.1.6.4.1. 

The nonradioactive process annual emissions are shown in Table 4-18. The combined 

estimated annual fluoride releases, including HF (52.6 kg [116 lb]), SiF4 (3.7 kg [8.2 lb]), BF3

(64.1 kg [141 lb]), and CaF2 (3.55 kg [7.82 lb]), are 124 kg (273 lbs). The annual total 

expressed as an hourly rate is 0.014 kg/hr (0.031 lb/hr). This pound per hour rate is well below 

the New Mexico threshold of 0.167 lb/hr for fluoride emissions. 
 4-30 

Table 4-18. Annual Nonradioactive Gaseous Emissions from the Operation of the 

Proposed IIFP Facility 

Emission 

Estimated Releases Total Emissions 

Plant KOH 

Scrubbing System 

Stack 

DUF4 Dust Collector 

Stack 

FEP Dust Collector 

DUF4 Vacuum 

Transfer Dust 

Collector 

CaF2 Dust Collector 

Lime Silo Dust 

Collector B

O2 3 Silo 

Total Emission 

kg/yr (lb/yr) 

HF 3.03 

(6.69) 

41.54 

(91.59) 

0.35 

(0.77) 

7.77 

(17.13) - - - 52.6 

(116.18) 

SiF4

0.0 

(0.01) - 3.71 

(8.19) - - - - 3.7 

(8.20) 

BF3

1.28 

(2.83) - 62.48 

(137.75) - - - - 64 

(140.58) 

U - 0.03 

(0.07) 

0.03 

(0.06) 

0.25 

(0.55) - - - 0.31 

(0.68) 

CaF2 - - - - 3.55 

(7.82) - - 3.55 

(7.82) 

Ca(OH)2 - - - - - 60.78 

(134.00) - 60.78 

(134.00) 

B2O3 - - - - - - 4.93 

(10.87) 

4.93 

(10.87) 

Totals 4.50 

(9.93) 

41.58 

(91.66) 

66.57 

(146.77) 

8.02 

(17.68) 

3.55 

(7.82) 

60.78 

(134.00) 

4.93 

(10.87) 

189.75 

(418.33) 

Source: IIFP, 2011a. 

4.1.2.4.2.3 Summary 

As discussed above, the estimated criteria pollutant emissions for Phase 1 operation of the 

proposed IIFP facility represent a very small fraction of the current emissions in Lea County. 

Because conservative assumptions that tend to overestimate impacts were used, actual 

emissions from operations would be less. In addition, pollutant emissions, including 

nonradioactive process effluents, would not change the existing ambient air quality in the vicinity 

of the IIFP facility. The NRC staff, therefore, concludes that air quality impacts during operation 

of the proposed IIFP facility would be SMALL to MODERATE. 

4.1.2.5 Geology, Minerals, and Soil 

No impact to the underlying bedrock, mineral resources, or soil is expected during facility 

operations. As discussed in Section 3.6.2, the site is in an area of limited seismic and volcanic 

activity, therefore, the statistical probability of fault rupture near the site is very low and the NRC 

staff finds that any associated impact due to seismic activity would be SMALL. Additionally, 

operation of the proposed IIFP facility is not expected to cause seismic or fault-related impacts. 
 4-31 

Seismic risks to the facility would be mitigated by incorporation of seismic criteria in the facility 

design to prevent spills or releases to the environment (IIFP, 2009a). 

Consequently, the NRC staff concludes that impacts of operation of the proposed IIFP facility to 

geology, minerals, seismicity, and soils are expected to be SMALL, and that impacts to the 

facility from any seismic activity would be SMALL. 

4.1.2.6 Water Resources 

All facility water systems – for potable, process and fire protection water -- would use 

groundwater. Groundwater pumped from the site well(s) would be a consumptive use because 

the groundwater would either be consumed or evaporated. 

4.1.2.6.1 Groundwater Use 

As discussed in Section 4.1.1.6.1.1, groundwater would be supplied from up to two onsite 

production wells. These wells would meet an estimated operations demand from 7.9 L/min 

(2.1 gpm) to 11.8 L/min (3.1 gpm) (normal) up to 26.3 L/min (6.95 gpm) (maximum). The 

operation of the facility would require relatively low volumes of water because it would recycle 

process water and re-circulate cooling water. The project is projected to use less than 38,000 L 

(10,000 gal) of groundwater per day (IIFP, 2011a). 

As discussed in Section 3.7.1.2.1, because current pumping is in excess of the Ogallala’s 

recharge rate, the aquifer has experienced significant drawdown in the last several decades. In 

2009, the NM OSE prepared guidelines on the procedures for processing water rights 

applications filed with the Lea County UWB. The NM OSE developed administrative guidelines 

in order to promote the orderly development of water resources in the Lea County UWB, while 

meeting statutory obligations regarding existing water rights, availability of unappropriated 

water, conservation of water with the State, and public welfare of the State through a 40-year 

planning period beginning on January 1, 2005 and ending on January 1, 2045. 

On March 10, 2009, the NM OSE issued an order closing the Lea County UWB to the filing of 

groundwater applications (NMOSE, 2009a). In 1999, in order to meet the projected 

groundwater demands of Lea County, 138 applications were filed by the Lea County Water 

Users Association to appropriate 6,389 ha-m (51,797 ac-ft) per year of groundwater, which was 

essentially all the unappropriated groundwater in the Lea County UWB (Leadshill-Herkenhoff 

et al., 2000). 

A portion of the applications to appropriate groundwater, totaling 4,215.2 ha-m (34,173 ac-ft) 

per year, have been assigned to Lea County during (at least) the 40-year planning period to 

allow the County to hold the subject water rights unused until the rights can be put to beneficial 

use at projects currently under construction, select future projects, and homes and businesses 

in unincorporated areas. The proposed IIFP site has been included in Lea County’s 40-Year 

Water Development Plan as an area of proposed development where up to 21.6 ha-m (175 acft) per year of the Lea County’s water rights would be put to beneficial use. The estimated 

quantity of groundwater that Lea County would need by the end of the 40-year planning period 

for all projects that currently exist, are being constructed, or have a high likelihood of being 

constructed in the near future is 1,173.5 ha-m (9,514 ac-ft) per year (Leadshill-Herkenhoff et al., 

2000). 
 4-32 

Groundwater rights for the facility would be obtained from the Lea County unallocated water 

rights under State Engineer Office Water Right File No. L-04719-A, for industrial water use. The 

proposed facility would obtain a joint Lea County and New Mexico Office of State Engineer 

Water Rights Agreement for 6.2 ha-m (50 ac-ft) per year (far less than the 21.6 ha-m [175 ac-ft] 

per year estimation in the Lea County Water Development Plan). 

Operation of the proposed IIFP facility would use approximately 0.50 percent of the estimated 

additional annual 40-year planning period groundwater demand of 1,173.5 ha-m (9,514 ac-ft) 

per year for Lea County, and only 0.15 percent of the 4,215.2 ha-m (34,173 ac-ft) per year of 

unappropriated water rights that have been assigned to Lea County. 

As part of NM OSE’s guidelines on the procedures for processing water rights applications filed 

with the Lea County UWB, the basin was divided into blocks corresponding to township and 

range. No permits were granted to appropriate water in a block unless one-third or more of the 

original groundwater storage in the block would be available at the end of the 40-year period. 

Blocks with an estimated saturated thickness of 16.8 m (55 ft) or less by 2045 are designated a 

CMA. The proposed IIFP site is not located in a CMA. 

For wells installed in a non-CMA, the Lea County Water Users Association recommends a 

drawdown limit of 2.4 m (7.9 ft) over 40 years, or 0.06 m/yr (0.20 ft/yr). Groundwater model 

simulations run by the NM OSE Hydrology Bureau to provide estimated drawdowns for a range 

of pumping scenarios in different hydraulic conductivity zones indicates that using a high 

hydraulic conductivity value for the Ogallala aquifer of 12.5 to 18.3 m (41 to 60 ft) per day for a 

single well pumping 6.2 ha-m (50 ac-ft) per year in an area of the aquifer with a saturated 

thickness of 61 m (200 ft) results in an estimated drawdown of 0.11 m (0.36 ft) in 40 years 

(NMOSE, 2009b). Considering that (1) the permeability of the Ogallala aquifer is quite variable 

(ranging as low as 0.61 m [2 ft/day]), and (2) the two site wells would never independently pump 

6.2 ha-m (50 ac-ft) per year, a drawdown of 0.11 m (0.36 ft) in 40 years is very conservative. It 

is highly unlikely that the wells would ever exceed the Lea County Water Users Association 

drawdown limit of 2.4 m (8 ft) over 40 years. 

The NRC staff finds that adverse impacts on groundwater quantity (availability) due to pumping 

from the site’s potential of two production wells during operation would be SMALL based on the 

following findings: 

• The proposed IIFP site has been included in Lea County’s 40-Year Water Development 

Plan as an area of proposed development where up to 21.6 ha-m (175 ac-ft) of the Lea 

County’s water rights would be put to beneficial use. 

• Groundwater rights for the proposed facility would be obtained from the Lea County 

unallocated water rights under State Engineer Office Water Right File No. L-04719-A for 

industrial water use. The facility would obtain a joint Lea County and New Mexico Office 

of State Engineer Water Rights Agreement for 6.2 ha-m (50 ac-ft) per year (far less than 

the 21.6 ha-m [175 ac-ft] per year estimation in the Lea County Water Development 

Plan). 

• Operation of the proposed facility would use approximately 5 percent of the estimated 

annual 40-year planning period groundwater demand of 1,173.5 ha-m (9,514 ac-ft) per 

year for Lea County, and only 0.15 percent of the 4,215.2 ha-m (34,173 ac-ft) per year of 

unappropriated water rights that have been assigned to Lea County. 
 4-33 

• Based on comparing the site wells to the most conservative NM OSE groundwater 

model scenario, it is highly unlikely that the wells would ever exceed the Lea County 

Water Users Association drawdown limit of 2.4 m (8 ft) over 40 years. 

• The site production wells would be installed in accordance with all NM OSE and Lea 

County Water Users Association well permit regulations. 

4.1.2.6.2 Groundwater Quality 

During IIFP operation, stormwater from the site would be collected in two runoff 

retention/evaporation basins. In addition, stormwater discharges during facility operation would 

be controlled by a Stormwater Pollution Prevention Plan. All fluids that would otherwise be 

process effluents are treated and recycled or reused within the process. Therefore, it is 

expected that no process effluent will be discharged to surface waters or groundwater. Water 

discharged from the site sanitary waste treatment system would meet required concentrations of 

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

20 and a Groundwater Discharge Permit/Liquid Waste Permit (IIFP, 2011a). An application for 

the Groundwater Discharge Permit has been submitted by IIFP to the NMED Groundwater 

Quality Bureau, which has issued a conceptual groundwater monitoring plan that is subject to 

change as more information becomes available during the discharge permit application process. 

NMED will require that total dissolved solids, sulfate, chloride, nitrate as nitrogen, total Kjeldahl 

nitrogen, fluoride, and isotopic uranium be monitored quarterly (IIFP 2011a). 

Treated process water from the sanitary waste treatment system would be used for irrigation at 

the facility. Because of high evaporation rates, and the presence of the 9.1-m (30-ft) indurate 

caliche unit that underlies the site, the irrigation water is not expected to migrate to groundwater. 

There would be no onsite disposal of solid, hazardous, radioactive, or mixed waste at the 

proposed IIFP site. 

The existing groundwater monitoring program at the site would be supplemented with the 

installation of at least four additional monitoring wells. Three of these monitoring wells are 

proposed to be located hydraulically downgradient (south) from the DUF6 Cylinder Storage Pad, 

the Cylinder Pad Stormwater Retention Basin, and the Stormwater Retention/Evaporation 

Basin. The fourth monitoring well is proposed hydraulically upgradient (north) from the primary 

production facility, just within the site’s security fence (IIFP, 2011a). The wells would be 

installed per the requirements of the NMED and sampled quarterly. 

Any spills of chemicals, diesel fuel, or other contaminants during operations would be cleaned 

up quickly in accordance with the proposed facility’s Spill Prevention Control and 

Countermeasure Plan, to prevent a pathway for the contaminant to enter the groundwater, 

thereby mitigating impacts to groundwater such that any inadvertent releases would result in 

localized and temporary impacts. Due to limited liquid effluent discharge from the facility 

operations (which would be treated prior to discharge as necessary); the lack of groundwater in 

the caliche, sand and gravel layer above the Ogallala aquifer; the quarterly groundwater 

monitoring plan; permanent waste disposal off site; the proposed facility’s Spill Prevention 

Control and Countermeasure Plan; and the 9.1-m (30-ft) depth to groundwater 

(GL Environmental, 2010) at the proposed IIFP site, the NRC staff concludes that the impacts to 

groundwater quality from operations would be SMALL. 
 4-34 

4.1.2.6.3 Surface Water 

As discussed in Section 3.7.2, no permanent surface water or jurisdictional waters are present 

on the proposed IIFP site and, therefore, the operation of the proposed facility would not affect 

surface water. 

4.1.2.7 Ecological Resources 

No additional land beyond the approximately 16 ha (40 ac) footprint would be disturbed during 

operations. The remaining portion of the IIFP site is expected to be left undeveloped for the 

duration of the license. 

Maintenance practices such as the use of chemical herbicides and roadway maintenance would 

be implemented during plant operation (IIFP, 2009a). 

The tallest proposed building would be 21.3 m (70 ft) high and emission stacks would be less 

than 30.5 m (100 ft) tall (IIFP, 2009a); well under the 61 m (200 ft) threshold that requires lights 

for aviation safety (FAA, 1992). Security lighting and equipment would be directed downward to 

help to minimize light pollution and reduce the potential for adverse impacts to wildlife 

(IIFP, 2009a). This minimization of lights, which attract nocturnal insects and their predator 

species, and the low height of the structures, reduce the potential for adverse impacts on nightmigrating birds. 

No unique or critical habitats or threatened or endangered species occur on the site or in the 

vicinity. Commercially and recreationally important species would not be adversely affected by 

plant operations. The NRC staff finds that adverse impacts during operations to ecological 

resources would be SMALL. 

4.1.2.8 Socioeconomic Resources and Environmental Justice 

This section provides analyses of the socioeconomic impacts associated with operation of the 

proposed IIFP facility. Phase 1 operation would begin during the fourth quarter of 2013; after 

Phase 2 is completed, Phase 1 and Phase 2 operate concurrently. Wage and salary spending 

and expenditures associated with materials, equipment, and supplies would produce income 

and employment and local and State tax revenue, while the in migration of workers and their 

families into the area would affect the availability of housing, public utilities and community 

services such as education, fire protection, law enforcement and medical resources. 

Socioeconomic impacts of the proposed IIFP would occur within the two-county ROI (Lea and 

Eddy Counties, New Mexico), where the operations workforce will likely live and spend most of 

their incomes. 

These analyses are based on the peak number of workers (140) employed at the IIFP facility for 

Phase 1 operation (IIFP, 2011a). The location of the IIFP facility was selected in part because 

local colleges and universities have existing training programs in partnership with the nearby 

URENCO USA centrifuge facility. These institutions, particularly the New Mexico Junior 

College, have the capability and are committed to provide training to ensure a skilled nuclear 

workforce (IIFP, 2009a). The New Mexico Junior College Workforce Training Program is 

designed to offer training requested by area employers, including specialized training for the 

nuclear service industry. Enrollment in the Workforce Training Program has increased to over 

4,251 total trainees through 2009 (NMJC, 2011). Therefore, this analysis assumes that 

80 percent of the IIFP worker force would be filled by residents within the ROI. Table 4-19 
 4-35 

depicts the workforce in-migration, based on the assumption that 80 percent of the operation 

employees would be current ROI residents and that each in-migrating operation employee 

would move his family into the ROI. These projections are used throughout this analysis. 

Table 4-19. Assumptions for Workforce Characterization During Phase 1 Operation 

Workforce characterization 

Peak number of workers onsite during Phase 1 operation 1 140 

Workforce migration 

Percent of operation workforce migrating into ROI 20% 

Number of workers migrating into ROI during peak operation 2 28 

Families 

Percent of operation workers who bring families 2 100% 

Average New Mexico family size (2009) 3 3.23 

Number of operation workers who would move into ROI and bring families 2 28 

Number of In-migrating workers' family members 2 62 

Number of operation workers and family members migrating into ROI (new 

population in ROI) 2 90 

School-age children 

Number of school-age children per family 4 0.8 

Number of school-age children migrating into ROI 2 22 

Source: 

1

 IIFP, 2011a 

2

 For supporting analyses, see Appendix D 

3

 USCB, 2010a 

4

 BMI, 1981. This study is an analysis of nuclear construction workforces, however, it included information about 

nuclear plant non-construction workers [i.e., managers, engineers, supervisors, clerical, security, and medical 

personnel who were on the site during construction]. 

4.1.2.8.1 Population 

As shown in Section 3.9.1.2, the population within the ROI was 112,938 in 2009. The IIFP 

Phase 1 operation would employ 140 people, of which 80 percent would be current ROI 

residents. The other 20 percent of the operations workforce (28 workers) and their families 

would migrate into the ROI (see Table 4-19). Using the 2009 New Mexico average family size 

of 3.23, the in-migration would result in 90 new residents (Table 4-19). An increase of 90 

residents would result in less than a 0.1 percent increase in the 2009 population of the ROI. 

4.1.2.8.2 Employment and Income 

Approximately 80 percent, or 112, of the IIFP Phase 1 operation positions (140 x 0.8 = 112 jobs) 

would be filled by people currently residing in the ROI (Table 4-19). Those 112 workers would 

represent 0.2 percent of the June 2010 ROI labor force. If all 112 of these jobs were filled by 

unemployed workers in the ROI, the unemployment rate would decrease by 0.2 percent. 

Approximately 20 percent of the IIFP Phase 1 operation positions (28 jobs) would be filled by 

people migrating into the ROI from outside the region (Table 4-19). The in-migrating workers 

would represent 0.2 percent of the June 2010 labor force. 
 4-36 

The in-migration of 28 workers would create indirect jobs within the ROI because of the 

multiplier effect (described in Section 4.1.1.8.2). In this analysis, the NRC staff used the BEA 

direct effect employment multiplier for the “All Other Basic Inorganic Chemical Manufacturing” 

classification to estimate the number of indirect jobs that would be created as a result of the inmigration of the project-related workers. Table 4-20 provides information about direct and 

indirect employment for Phase 1 operation. Indirect jobs are often non-technical, nonprofessional positions in the retail and service sectors and would likely be filled by unemployed 

workers already residing in the ROI. The 51 indirect jobs represent 1.3 percent of the 

unemployed labor force in June 2010. 

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

Phase 1 operations workforce peak (Table 4-19) 140 

Number of Phase 1 operations workers who migrate into ROI (20 percent of 

operation workforce peak) (Table 4-19) 28 

Employment multiplier for Phase 1 operations workers (indirect portion only) 

(BEA, 2010) 1.8173 

Indirect jobs resulting from in-migrating Phase 1 operations workers (See 

Appendix D) 51 

The regional economy would benefit from the capital investment expenditures and recurring 

costs associated with the operation of the IIFP facility. IIFP has provided estimates for some of 

these costs. The payroll associated with Phase 1 would be between $7,900,000 and 

$9,100,000 annually (IIFP, 2009a). IIFP employees and indirect workers would spend earnings 

on goods and services with the ROI. Additional costs associated with operations include 

replacement capital; waste disposal; insurance premiums and taxes; utilities; and maintenance 

materials and supplies. These expenditures would range from $17,315,000 to $23,727,000 

annually. 

The NRC staff finds that due to the size of the available workforce in the ROI, the effect of IIFP 

Phase 1 operations on employment and income within the ROI would be SMALL and beneficial. 

4.1.2.8.3 Taxes 

Phase 1 operations-related wages and purchases would generate several types of taxes, 

including corporate income taxes, individual income taxes, gross receipts taxes, and property 

taxes. Increased tax collections are viewed as a benefit to the State of New Mexico, Lea and 

Eddy Counties, the Hobbs Municipal School District, the New Mexico Junior College, the 

communities in Lea and Eddy Counties, and other locales where plant-related spending would 

occur. 

Income and Gross Receipts Taxes 

IIFP has estimated the income and gross receipts tax impacts of Phase 1 operation in 

Table 4-21. The NRC staff finds that the increase in tax revenues to the State and county would 

be SMALL and beneficial. 
 4-37 

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

Lea County for the Phase 1 Operation Period, 2009 Dollarsa

New Mexico Lea County 

Gross Receipts Tax 

High Estimate $118,100,000 $8,800,000 

Low Estimate $87,100,000 $6,500,000 

NM Corporate Income Taxb

High Estimate $77,200,000 Nonec

Low Estimate $57,100,000 Nonec

Source: IIFP, 2011a 

a Tax values based on 2009 tax rates 

b Based on average annual earnings for the Phase 1 increment 

c Allocation would be made to the State of New Mexico 

In addition to IIFP’s corporate income and gross receipts tax payments, plant employees would 

pay State individual income and State and county gross receipts taxes. The NRC staff finds 

that these tax payments would have a SMALL, beneficial impact on New Mexico’s and the 

counties’ income tax revenues. Regional spending on goods and services by IIFP employees 

would generate gross receipts tax revenues for Lea and Eddy County municipalities, Lea and 

Eddy Counties, New Mexico, and other locales. The NRC staff finds that these additional tax 

revenues would create a SMALL, beneficial impact 

Property Taxes 

As stated in Sections 3.9.3, International Isotopes, Incorporated, the parent corporation of IIFP, 

has an IRB agreement with Lea County and is generally exempt from property taxes. However, 

two taxing entities are not part of the IRB agreement. For Phase 1 operation, IIFP would pay an 

amount in lieu of property tax to the Hobbs Municipal School District and to the New Mexico 

Junior College. Table 3-28 presents total revenue data for the Hobbs Municipal School District 

and the New Mexico Junior College, IIFP’s estimated average annual tax payments to those 

schools, and those payments as a percentage of the schools’ revenues. As shown in 

Table 3-28, the Hobbs Municipal School District’s total 2007-2008 revenues were about 

$71 million and the New Mexico Junior College’s total 2008-2009 revenues were about 

$37 million. IIFP’s payments would represent a very small percentage of the school district and 

college’s revenues. The NRC staff finds that the impact of the payment in lieu of taxes to each 

jurisdiction would be SMALL, and beneficial. 

Therefore, the NRC staff concludes that operation of the proposed IIFP facility would have a 

SMALL beneficial impact on tax revenues. 

4.1.2.8.4 Housing 

In 2008, about 46,971 housing units were in the ROI, and 5,823 of them were vacant 

(Section 3.9.4). The Phase 1 operation of the IIFP facility would result in an influx of 

approximately 28 workers (Table 4-19), all of whom would need housing. Housing the 28 

in-migrating workers would require 0.5 percent of the vacant housing units within the ROI. The 

in-migrating workers would not exhaust the existing housing inventory. 
 4-38 

Therefore, the NRC staff concludes that operation of the proposed IIFP facility on the existing 

housing inventory would be SMALL. 

4.1.2.8.5 Public Utilities 

Public Water 

All onsite potable, process, and fire water needed for the operation of the IIFP Phase 1 facility 

would be provided by no more than two wells installed in the Ogallala aquifer. The facility will 

not use public water (IIFP, 2011a). 

Phase 1 operation will result in 90 people migrating into the ROI (Section 4.1.2.8.1). These new 

residents would likely select housing within areas that rely on a public water supplier. The major 

public water suppliers serve approximately 88,643 people (Table 3-30) and most, if not all, have 

excess capacity. The 90 new residents would result in a 0.1 percent increase in customers who 

rely on the public water suppliers. The NRC staff finds that the impact of Phase 1 operations on 

public water supplies would be SMALL, because the excess capacity of water suppliers in the 

ROI is sufficient to support the in-migrating workforce. 

Public Wastewater 

The IIFP facility would not be connected to any public wastewater or sewage system (IIFP, 

2011a). The project will result in 90 people migrating into the ROI. These new residents would 

likely elect to reside within areas that rely on a public wastewater system. The major public 

wastewater treatment facilities serve approximately 78,917 people (Table 3-31) and have 

excess capacity. The 90 new residents would result in a 0.1 percent increase in customers who 

rely on the public wastewater systems. Therefore, because the increase in households is a 

small percentage of the existing public wastewater users, and the public wastewater facilities 

have excess capacity, the NRC staff concludes that impact of the proposed IIFP operation on 

public wastewater treatment systems would be SMALL. 

4.1.2.8.6 Community Services 

Education 

During the 2008 school year, there were 8 public school districts, containing 64 schools 

educating 22,847 students in the ROI (Section 3.9.6.1). The operation of the IIFP facility would 

result in an influx of approximately 28 employees and their families (Table 4-18). Each inmigrating family is estimated to have 0.8 school aged children (Table 4-18); therefore, 

22 additional children would be eligible for public school as a result of Phase 1 operation 

(Table 4-18). The new student enrollment would represent an increase of 0.1 percent of the 

2008 enrollment. Therefore, the NRC staff concludes that the impact of the proposed Phase 1 

operation on education would be SMALL. 

Fire Protection 

As discussed in Section 4.1.2.8.1, the population increase in the ROI associated with the 

operation of the IIFP Phase 1 facility would be less than 0.1 percent and would result in filling 

0.5 percent of the available housing. Therefore, there would not be a detectable increase in the 

demand for fire protection. Existing fire protection personnel, facilities, and equipment would be 
 4-39 

sufficient to support the population increase. Therefore, the NRC staff concludes that impact of 

operation of the proposed facility on fire protection would be SMALL. 

Law Enforcement 

The in migrating workforce would increase the ROI population less than 0.1 percent 

(Section 4.2.1.8) and would not affect the ability of existing law enforcement services to meet 

the needs of the population. Existing law enforcement personnel, facilities, and equipment 

would be sufficient to support the population increase; therefore, the NRC staff finds that the 

impact of Phase 1 operation of would be SMALL. 

Hospitals and Physicians 

An ROI population increase of less than 0.1 percent (Section 4.2.1.8) would not measurably 

increase the demand for hospital and physician services. The NRC staff finds that the impact of 

operation on hospitals and physician services would be SMALL. 

4.1.2.8.7 Environmental Justice 

The primary environmental resources that could be affected by the operation of the proposed 

IIFP facility are soil, groundwater quality, groundwater quantity, air quality, ecology, 

socioeconomics and human health. Section 3.9.1.2 defines and identifies the minority and lowincome populations within the 80 km (50-mi) radius of the proposed IIFP facility. There are 

96 block groups that fall completely or partially within the 80 km (50-mi) radius. Of the 96 block 

groups, one has a significant African American population, 15 have significant “Some Other 

Races” populations, 32 have significant Hispanic populations, and 10 have significant lowincome populations. Figures 3-22, 3-23, 3-24 and 3-25 locate these block groups. The 

following is a summary of the impacts on the resources area and addresses whether minority or 

low-income populations would experience disproportionately high and adverse impacts from the 

IIFP Phase 1 operation: 

• Land Use – The NRC staff finds that operation of the facility would not affect land use 

beyond those impacts attributed to construction. Accordingly, the NRC staff finds that 

impacts to land use would be SMALL. 

• Soils – The NRC staff finds that impact to soils during IIFP operation would be SMALL. 

• Groundwater quality – During IIFP operation, stormwater from the site would be 

collected in two runoff retention/evaporation basins. No wastes from facility process 

systems would be discharged to stormwater. Furthermore, any stormwater discharges 

would be controlled by a Stormwater Pollution Prevention Plan. Treated process water 

would be used for irrigation at the facility but is not expected to migrate to groundwater. 

The NRC staff finds that effects to groundwater quality would be SMALL, localized, and 

temporary. 

• Groundwater quantity – No municipal water line runs near the proposed IIFP facility. No 

more than two groundwater wells would supply all of the water for the facility. The 

operation of the facility would require relatively low volumes of water because it would 

recycle process water and re-circulate cooling water; groundwater use is estimated to be 

less than 37,854 (10,000 gal) per day. The proposed IIFP site has been included in Lea 

County’s 40 Year Water Development Plan and would use approximately 5 percent of 

the estimates 40-year planning period demand. The NRC staff finds that it is highly 
 4-40 

unlikely that the two wells would ever exceed the Lea County UWB drawdown limit. The 

NRC staff finds that impacts to groundwater quantity during operation would be SMALL. 

• Air quality - The estimated criteria pollutant emissions from Phase 1 operation represent 

a very small fraction of the current emissions in Lea County. Pollutant emissions, 

including nonradioactive process effluents, would not change the existing ambient air 

quality in the vicinity of the IIFP facility. The NRC staff finds that the air quality impacts 

would be SMALL to MODERATE. 

• Public and Occupational Health - Operation of the IIFP facility would require shipment of 

DUF6 cylinders to and from the facility and hazardous, mixed and LLW to disposal 

facilities. The transportation risk associated with IIFP transportation operations is 0.03 

additional latent cancer fatalities (LCF) per year. The NRC staff finds that impacts from 

the proposed action on Public and Occupational health would be SMALL. 

• Ecology – More than 90 percent of the IIFP site would be undisturbed by operations, no 

threatened or endangered species or critical or unique habitats occur on the site, and the 

site does not provide extensive habitat for any commercial or recreational species. 

Therefore, the NRC staff finds that operation of the IIFP facility would have a SMALL 

effect on ecological resources. 

• Socioeconomics – Phase 1 IIFP operations would employ 140 employees, 28 of whom 

would migrate into the ROI with their families. The in-migrating workers and their 

families would increase the population within the ROI by 0.1 percent. The NRC staff 

concludes that these workers and their families would have a SMALL effect on housing, 

community services, and public utilities and a SMALL and beneficial effect on 

employment and taxes. 

The NRC staff finds that the impacts of IIFP operation on the resources evaluated would be 

SMALL for most resources and SMALL to MODERATE for air quality and in some cases, 

beneficial. Furthermore, the nearest minority or low-income population is 22.5 km (14 mi) from 

the proposed facility. Therefore, because all resource area impacts are SMALL and the 

identified minority and low income populations are not in close proximity to the proposed site, 

the NRC staff finds that impacts would not be considered disproportionately high and adverse 

impacts to any population, including low-income or minority populations. 

4.1.2.9 Traffic and Transportation 

4.1.2.9.1 Traffic 

Operations impacts would occur from commuting personnel and the transport of nonradiological 

and radiological materials to and from the proposed IIFP site. The impacts from each are 

discussed below. 

The principal highway routes that would handle this traffic include NM 483, which borders the 

site to the west, and US 62/180, which provides an east-west route to the nearest population 

centers. All traffic would access the site via NM 483, and most traffic would use US 62/180 to 

NM 483 to access the site. Some portion of the workforce may access the site from the north, 

using NM 83 to access NM 483 north of the site. At the junction of NM 483 and US 62/180, 

traffic would go east to Hobbs, Eunice and other Lea County municipalities or southwest to 

Eddy County. After the intersection of NM 483 and US 62/180 traffic associated with the site 

would be increasingly dispersed. 
 4-41 

IIFP operations would use 140 workers working three shifts per day (IIFP, 2011a) or 47 people 

per shift. Therefore, if each employee commutes alone, there would be an increase of 

94 vehicles (47 ending a shift plus 47 starting a shift) on NM 483 for each shift change. 

Additionally, IIFP estimated 10 delivery or waste disposal trucks each day. 

The Highway Capacity Manual 2000 (TRB 2000) indicates that the capacity of a two-lane 

highway is 1,700 passenger cars per hour for a single direction and 3,400 passenger cars per 

hour for both directions. The AADT on NM 483, a two-lane highway, at Arkansas Junction in 

2008 was 955 vehicles per day (NMDOT, 2009). If all the vehicles on NM 483 in one day used 

the road in a single hour, including the anticipated 10 truck trips per day (IIFP, 2011a), and if 

two operations workforce shifts used the road to the site during that same hour, a maximum of 

1,059 vehicles would be on the road. This is less than the design capacity of a two-lane 

highway. The impact of traffic increases due to facility operations on US 62/180, which is a 

four-lane highway, would be smaller than the impact on NM 483. Therefore, the NRC staff 

concludes that impacts to traffic from operations would be SMALL. 

Using the same assumptions for operations as for construction, 140 operation employees would 

commute approximately 2,300,000 km (1,400,000 mi) per year of facility operation. The New 

Mexico 2010 vehicle accident rates result in 51.73 injuries and 1.73 fatal accidents per 

160 million vehicle km (100 million vehicle mi) traveled (UNM, 2010). Based on these rates, 

statistically there would be one injury (risk of less than 0.7 injury crashes) per year and no 

fatalities (risk of less than 0.02 fatal crashes) per year due to the Phase 1 operations traffic. 

The transportation of nonradiological materials would include the delivery of routine supplies 

and equipment and the removal of nonradiological wastes (including hazardous wastes). The 

transport of hazardous waste is subject to EPA and DOT regulations. Nonradiological deliveries 

and waste removal would require an estimated 1,950 truck round-trips per year, or 

approximately 8 round-trips per day (IIFP, 2011a). As with the commuter traffic, the NRC staff 

finds that this increase in traffic volume would have a SMALL impact on the current traffic and 

the carrying capacity of the affected roads would not be challenged. 

Assuming a round-trip distance of 113 km (70 mi), the round-trip distance to the furthest 

nonradiological waste disposal facility likely to be used by IIFP, these trucks would travel 

approximately 220,480 km (137,000 mi) per year of operation, therefore, no injuries (risk <0.07), 

and no fatalities (risk <0.002) would be expected per year of Phase 1 operation. The NRC staff 

concludes that impacts from accidents involving the shipment of nonradiological materials would 

be SMALL. 

4.1.2.9.2 Incident-free Radiological Transportation 

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

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

facilities, DUO2 to waste disposal facilities, and other process and miscellaneous LLW to waste 

disposal facilities. Data for the analysis came from IIFP (IIFP 2011a; IIFP, 2011b) unless 

specified otherwise. More detail on the analysis can be found in Appendix E. 

Full DUF6 Cylinders: The NRC staff selected all current or proposed U.S. commercial 

enrichment facilities as representative origins for shipments of DUF6. These are (1) URENCO 

USA, just east of Eunice, New Mexico, (2) the GE-Hitachi Global Laser Enrichment Facility 

north of Wilmington, North Carolina, and (3) the AREVA Eagle Rock Enrichment Facility west of 

Idaho Falls, Idaho. The cylinders would be shipped one per 18-wheel truck. The radiation dose 
 4-42 

rate at 1 m (3.28 ft) from a cylinder is 0.0046 mSv per hour (0.46 mrem per hour) (Biwer et al., 

2001). There would be 293 shipments per year of full DUF6 cylinders for Phase 1 operations. 

Empty DUF6 Cylinders: Although it is possible that some cylinders would not be shipped back 

to their origin, NRC staff has assumed, for purposes of analysis, that all cylinders would be 

returned. In the event that cylinders are not returned, they could be disposed empty as LLW or 

filled with DUO2 and disposed as LLW. The returned cylinders would have a heel of less than 

23 kg (50 lb) and, thus, contain radioactive material. The cylinders are conservatively assumed 

to be shipped one per truck, consistent with IIFP data; however, two per truck is a likely 

scenario. Radiation dose rates from empty cylinders are slightly higher than from full cylinders 

due to the concentration of uranium daughter products and loss of self-shielding. The estimated 

radiation dose rate 1 m (3.28 ft) from an empty cylinder is 0.01 mSv per hour (1 mrem per hour). 

Conservatively, there would be 293 shipments per year of empty cylinders. 

DUO2 Waste: The DUO2 is assumed to be waste and not sold. It would be packaged into 

55-gallon drums and loaded 40 per truck (subject to weight limitations). Shipment destinations 

selected for analysis are the EnergySolutions Clive, Utah facility and the WCS facility on the 

Texas-New Mexico border west of Andrews, Texas (immediately east of the URENCO USA 

facility). Less probable destinations, such as the U.S. Ecology Washington disposal facility on 

the Hanford Site near Richland, Washington and the Nevada National Security Site, are 

represented by these analyses. The radiation dose rate 1 m (3.28 ft) from a drum would be 

approximately 6 x 10-4 mSv per hour (0.06 mrem per hour). IIFP estimates that there would be 

as many as 155 DUO2 waste shipments per year. 

Process and Miscellaneous LLW: This volume of LLW would be small compared to the DUO2

waste. The radioactivity in most of this waste would likely be less concentrated than the DUO2

waste. There would be 31 shipments per year, each with 40 55-gal drums. The dose rate is 

conservatively selected to be the same as the DUO2 shipments, 6 x 10-4 mSv per hour 

(0.06 mrem per hour). 

NRC staff used the TRAGIS (Johnson and Michelhaugh, 2003) transportation routing computer 

modeling code and the RADTRAN5 (Neuhauser and Kanipe, 2003) transportation risk 

assessment computer modeling code to calculate radiological impacts (collective dose) to 

members of the public living near the transportation route, drivers and passengers sharing the 

highways, persons at fueling or rest stops, the truck drivers, and package handlers. Results of 

that analysis are provided in Table 4-22. 

Assuming a scenario in which DUF6 shipped from the enrichment facility results in the greatest 

collective dose and DUO2 waste shipped to the disposal facility results in the greatest collective 

dose, and summing for all receptors (Appendix E), one arrives at 0.18 person-sievert per year 

(18 person-rem per year). This is for receipt and return of cylinders to the GLE facility in 

Wilmington, North Carolina and disposal of low-level waste at the EnergySolutions Clive, Utah 

facility. Multiplying the collective dose by the Interagency Steering Committee on Radiation 

Standards conversion factor of 6 × 10-4 latent cancer fatalities (LCFs) per person-rem (ISCORS, 

2002), estimates the transportation-related latent cancer fatalities for one year of incident-free 

exposure as 0.01 LCF. 

The Centers for Disease Control and Prevention (CDC, 2010) estimated the age-adjusted 

cancer death rate in the U.S. was 178.4 deaths per 100,000 people in 2007. Similarly, 

23.2 percent (23,200 per 100,000) of all deaths in the U.S. in 2007 were cancer related. 

Although these results are from two different studies and difficult to compare, both studies show 
4-43 

Table 4-22. Annual Collective Doses to Various Receptors from Radiological Transportation 

Description 

General Public Drivers and Passengers Persons at Stops Truck Drivers Package Handlers 

PersonSv Person- Rem Person- Sv Person- Rem Person- Sv Person- Rem Person- Sv Person- Rem Person- Sv Person- Rem 

Full DUF6 cylinders 

from URENCO USA 

2.3 x 10-5 2.3 x 10-3 2.6 x 10-4 0.02.6 a a 4.3 x 10-4 0.043 3.9 x 10-3 0.39 

Full DUF6 cylinders 

from GLE Facility 

6.8 x 10-3 0.68 0.07 4.7 0.075 7.5 0.029 2.9 3.9 x 10-3 0.39 

Full DUF6 cylinders 

from AREVA Eagle Rock 

3.9 x 10-3 0.39 0.039 3.9 0.075 7.5 0.026 2.6 3.9 x 10-3 0.3 

Empty DUF6 cylinders 

to URENCO 

5.1 x 10-5 5.1 x 10-3 5.6 x 10-4 0.056 a a 9.3 x 10-4 0.093 8.4 x 10-3 0.84 

Empty DUF6 cylinders 

to GLE Facility 

0.015 1.5 0.10 10 0.16 16 0.06.3 6.3 8.4 x 10-3 0.84 

Empty DUF6 cylinders 

to AREVA Eagle Rock 

8.5 x 10-3 0.85 0.084 8.4 0.16 16 0.056 5.6 8.4 x 10-3 0.84 

DUO2 and 

Miscellaneous LLW to EnergySolutions

3.0 x 10-4 0.03 3.3 x 10-3 0.33 5.3 x 10-3 0.53 2.0 x 10-3 0.20 5.8 x 10-3 0.5 

DUO2 and 

Miscellaneous LLW to Waste Control Specialists 

2.0 x 10-6 2.0 x 10-4 2.1 x 10-5 2.1 x 10-3 a a 3.6 x 10-5 3.6 x 10-3 5.8 x 10-3 0.5 

Source: See Appendix E a A stop was not assumed because the route was short 
 4-44 

10 CFR 20 Exposure Limits

The NRC exposure limits place 

annual restrictions on the total 

dose equivalent exposure (1 mSv 

[100 mrem]), which includes 

external plus internal radiation 

exposures, and the dose 

equivalent rate (0.02 mSv [2 

mrem]) in any 1 hour in 

unrestricted areas that are 

accessible by members of the 

public who are not employees, but 

who may be present during the 

year at the facility. 

Source: 10 CFR 20.1301 

that cancer fatalities are significant in normal life. Given these cancer fatality rates, the addition 

of 0.01 LCF from the proposed action is considered by NRC staff to be a SMALL impact. While 

mitigation measures are not required, IIFP would be required by NRC regulation 10 CFR 20 to 

maintain all radiation doses As Low As Reasonably Achievable (ALARA). 

Estimates of radiological exposure to the workforce and public from facility operations other than 

radiological transport are discussed in Section 4.1.2.12. 

4.1.2.10 Noise Impacts 

As discussed in Section 3.11, noise from the operation of the proposed facility would be 

minimal, occur mostly inside the buildings, and be attenuated by distance. The proposed facility 

is in a relatively remote location, surrounded by other industrial facilities, and far from lands 

uses that could be adversely affected by increases in noise levels. Noise at the nearest 

residences and recreational areas would not increase due to operation of the proposed IIFP 

facility. Therefore, the NRC staff concludes that impacts from noise of operations would be 

SMALL. 

4.1.2.11 Public and Occupational Health Impacts 

Normal operations at the proposed IIFP facility have the potential to impact the health of 

workers and the public due to exposures from permitted chemical and radiological gaseous 

emissions and liquid effluents. Additionally, workers could be impacted from direct radiation 

exposures and occupational hazards. This section discusses these potential impacts. Although 

normal operations at the proposed IIFP facility create the potential for radiological and 

nonradiological impacts, plant design would incorporate features to minimize gaseous and liquid 

effluent releases and to keep them well below regulatory limits. These features include the 

following (IIFP, 2011a): 

• DUF6 cylinders would be moved only when cool and when DUF6 is in solid form, which 

minimizes the risk of inadvertent release due to mishandling. 

• Process off-gas from DUF6 purification and other 

operations would be solidified to reclaim as much 

DUF6 as possible. Remaining gases pass through 

high-efficiency filters and chemical absorbers, which 

remove HF and uranium compounds. 

• Liquid and solid waste handling systems and 

techniques would be used to control wastes and 

effluent concentrations. 

• Gaseous emissions would pass through pre-filters, 

high efficiency filters, and carbon filters, all of which 

greatly reduce the radioactivity in the final 

discharged emission to very low concentrations. 

• Uranium-bearing liquid waste would be routed to the 

Decontamination Building for removal of uranium 

and the treated water would be evaporated or 

reused in the Decontamination Building. 
 4-45 

• Effluent paths would be monitored and sampled to assure compliance with regulatory 

discharge limits. 

Radiological Impacts 

The general public could be impacted by radiation and radioactive material from the IIFP facility 

via controlled releases of gas associated with the uranium process lines during routine 

operations and from decontamination and maintenance of equipment, or direct radiation 

exposure associated with transportation and storage of DUF6 cylinders and wastes. 

The radiation exposure limits for the general public have been established by the NRC in 

10 CFR 20. Routine operations would be conducted to ensure that public exposure at off-site 

locations would be within these limits. Annual exposure to the public would be maintained 

\ALARA through effluent controls and monitoring. 

The potential radiological impacts to the public from operations at the proposed IIFP facility are 

those associated with chronic exposure to low levels of radiation and not the immediate health 

effects associated with acute radiation exposure. The major sources of potential radiation 

exposure (chronic or acute) are the gaseous discharges from the plant scrubber systems for the 

DUF4 and fluorine extraction processes and the dust collector scrubber system. It is estimated 

that the total amount of uranium released to the air from the proposed IIFP facility would be less 

than 0.5 kg (1.1 lb) per year. Due to the low volume of contaminated liquid waste anticipated by 

the applicant, no liquid effluent discharges are expected to contain radiological waste. 

Therefore, there would be no dose pathway and no significant radiological impact to the public 

or the environment from liquid effluent discharges. The radiological impacts associated with 

direct radiation from indoor operations are not expected to be a significant contributor to dose to 

the public because the low-energy gamma-rays associated with the uranium would be absorbed 

almost completely by the process lines, equipment, cylinders, and building structures (IIFP, 

2011a). Routine radiological gaseous releases from the proposed IIFP facility are listed in 

Table 4-23. 

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

Radionuclide DUF6 to DUF4 Stack SiF4 and BF3 Production Stack 

kBq/yr Ci/yr kBq/yr Ci/yr 

Estimated Releases 

234U 461 1.25 x 10-5

 42.2 1.14 x 10-6

235U 44.5 1.20 x 10-6

 4.08 1.10 x 10-7 238U 3,500 9.46 x 10-5 321 8.66 x 10-6

Total 4,005.5 1.08 x 10-4 367.3 9.91 x 10-6

Bounding Releases 

234U 922 2.49 x 10-5

 84.5 2.28 x 10-6

235U 89.1 2.41 x 10-6

 8.16 2.21 x 10-7

238U 7,000 1.89 x 10-4 641 1.73 x 10-5

Total 8,010 2.16 x 10-4 734 1.98 x 10-5

Source: IIFP, 2011a 

kBq = kilobecquerel (2.7 X 10-7 curies) 
 4-46 

Committed Effective Dose 

Equivalent (CEDE)

Committed effective dose 

equivalent is the sum of the 

products of the weighting factors 

applicable to each of the body 

organs or tissues that are 

irradiated and the committed dose 

equivalent to these organs or 

tissues. 

Source: 10 CFR 20.1003. 

Total Effective Dose Equivalent 

(TEDE)

Total effective dose equivalent is 

the sum of the effective dose 

equivalent or the deep-dose 

equivalent (for external 

exposures) and the committed 

effective dose equivalent (for 

internal exposures).

Source: 10 CFR 20.1003. 

There are three primary exposure pathways associated with plant effluent: inhalation; direct 

radiation due to deposited radioactivity on the ground surface (“ground plane exposure”); and 

ingestion of contaminated food products. Of these three exposure pathways, inhalation 

exposures are expected to be the predominant pathways at site boundary locations and also at 

off-site locations that are relatively close to the site boundary. Because airborne concentrations 

decrease with the distance from the discharge point, for gaseous releases from the proposed 

IIFP facility, the highest off-site airborne concentrations (and, hence, the greatest radiological 

impacts) are expected at locations near the site boundary. Beyond those locations, the 

concentrations of airborne radioactive material would decrease continuously because of 

dispersion of the material and depletion processes. 

The critical populations for determining dose impacts include the resident nearest to the 

proposed IIFP facility (at the northwest boundary) and the maximally exposed individual (MEI). 

The MEI is a hypothetical person living at the point of highest projected total uranium 

concentrations. The impact due to gaseous releases was evaluated for the dose from the three 

primary exposure pathways identified above. Because there is no pathway for contamination of 

drinking water, no radiological contamination of drinking water was considered in the analysis. 

The analysis included dose equivalent assessments for four age groups (i.e., adults, teens, 

children, and infants) for these pathways. 

IIFP calculated doses using GENII (version 2.08), which 

is a dose assessment model developed for EPA for 

calculating radiation dose and risk from radionuclides 

released to the environment. Dose equivalents for the 

MEI and the nearest resident due to gaseous releases 

were calculated by pathway for the total body in adults, 

teens, children, and infants, and are presented in Tables 

4-24 and 4-25, respectively. For the MEI, the highest 

committed effective dose equivalent (CEDE) from the 

proposed IIFP facility emissions was calculated to be 

1.40 x 10-7 Sv (1.40 x 10-5 rem) per year. For the adult 

fulltime resident nearest to the facility, the highest CEDE 

from the IIFP facility was calculated to be 9.46 x 10-8 Sv 

(9.46 x 10-6 rem) per year. 

In its environmental report (IIFP, 2009a), IIFP calculated 

direct dose rates for the MEI and the nearest resident. 

These doses rates were extremely small (e.g., less than 

1.04 x 10-2 mSv per year [1.04 mrem per year]). The 

CEDE and the direct dose equivalent were totaled to 

determine the total effective dose equivalent (TEDE) for 

the MEI. The highest TEDE was determined to be 0.21 

mSv per year (20.8 mrem per year), which is 

approximately one-fifth of the NRC exposure limit of 1 

mSv (100 mrem). Doses for public receptors at other 

sites of interest (e.g., schools and hospitals) would be 

lower than those of the MEI because the airborne 

concentrations of uranium would be lower at these more distant locations. Therefore, NRC staff 

anticipates that radiological impacts to off-site receptors from routine combined effluent releases 

and direct radiation would to be SMALL. 
 4-47 

Table 4-24. Annual and Committed Dose Equivalents for Exposures to the MEI from 

Gaseous Effluents 

Source Units Adult EDE Teen EDE Child EDE Infant EDE 

Cloud Immersion 

Sv 5.77 x 10-16 5.77 x 10-16 5.77 x 10-16 5.77 x 10-16

rem 5.77 x 10-14 5.77 x 10-14 5.77 x 10-14 5.77 x 10-14

Inhalation 

Sv 3.06 x 10-8 3.67 x 10-8 6.19 x 10-8 1.30 x 10-7

rem 3.06 x 10-6 3.76 x 10-6 6.19 x 10-6 1.30 x 10-5

Ingestion 

Sv 1.30 x 10-9 1.96 x 10-9 2.35 x 10-9 9.79 x 10-9

rem 1.30 x 10-7 1.96 x 10-7 2.35 x 10-7 9.79 x 10-7

Ground Plane 

Exposure 

Sv 2.08 x 10-10 2.08 x 10-10 2.08 x 10-10 2.08 x 10-10

rem 2.08 x 10-8 2.08 x 10-8 2.08 x 10-8 2.08 x 10-8

Total Dose 

Sv 3.21 x 10-8 3.88 x 10-8 6.45 x 10-8 1.40 x 10-7

rem 3.21 x 10-6 3.88 x 10-6 6.45 x 10-6 1.40 x 10-5

Source: IIFP, 2011a 

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

Resident from Gaseous Effluents 

Source Units Adult EDE Teen EDE Child EDE Infant EDE 

Cloud Immersion 

Sv 4.40 x 10-17 4.40 x 10-17 4.40 x 10-17 4.40 x 10-17

rem 4.40 x 10-15 4.40 x 10-15 4.40 x 10-15 4.40 x 10-15

Inhalation 

Sv 2.20 x 10-8 2.65 x 10-8 4.44 x 10-8 9.38 x 10-6

rem 2.20 x 10-6 2.65 x 10-6 4.44 x 10-6 9.38 x 10-6

Ingestion 

Sv 9.91 x 10-11 1.49 x 10-10 1.79 x 10-10 7.43 x 10-10

rem 9.91 x 10-9 1.49 x 10-8 1.79 x 10-8 7.43 x 10-8

Ground Plane 

Exposure 

Sv 1.59 x 10-11 1.59 x 10-11 1.59 x 10-11 1.59 x 10-11

rem 1.59 x 10-9 1.59 x 10-9 1.59 x 10-9 1.59 x 10-9

Total Dose 

Sv 2.21 x 10-8 2.66 x 10-8 4.46 x 10-8 9.46 x 10-8

rem 2.21 x 10-6 2.66 x 10-6 4.46 x 10-6 9.46 x 10-6

Source: IIFP, 2011a 

Potential doses to the total population within an 80-km (50-mi) radius of the proposed IIFP 

facility were also determined. The local area population distribution was derived from U.S. 

Census Bureau 2000 data for counties in New Mexico and Texas (IIFP, 2011a) that fall all or in 

part within the 80-km (50-mi) radius of the proposed IIFP site. A standard 16-sector compass 

rose was centered on the IIFP site and divided into annular rings out to a distance of 80 km 

(50 mi) (see Figure 4-1). Using census data, significant population groups, typically towns or 

cities, within the 80-km (50-mi) area were identified in those sectors. Table 4-26 and Table 4-27 

present the total population doses expected in units of person-sieverts and person-rem, 
 4-48 

 
4-49 

Table 4-26. Collective Dose Equivalents to All Ages Population (person-Sv) (gas release pathways) 

Vector 0-1 mi 1-2 mi 2-3 mi 3-4 mi 4-5 mi 5-10 mi 10-20mi 20-30 mi 30-40 mi 40-50 mi Total 

E 0.00 0.00 0.00 0.00 0.00 0.00 1.82 x 10-4 4.03 x 10-6 9.53 x 10-6 5.15 x 10-6 2.01 x 10-4ENE 0.00 0.00 0.00 0.00 0.00 3.72 x 10-5 4.08 x 10-5 0.00 1.16 x 10-5 4.77 x 10-5 9.44 x 10-5NE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.25 x 10-6 3.25 x 10-6NNE 0.00 0.00 0.00 0.00 0.00 0.00 6.54 x 10-6 0.00 0.00 0.00 6.54 x 10-6N 0.00 0.00 0.00 0.00 0.00 0.00 9.55 x 10-5 3.56 x 10-6 3.56 x 10-6 0.00 1.03 x 10-4NNW 0.00 0.00 0.00 0.00 0.00 0.00 9.89 x 10-6 0.00 0.00 0.00 9.89 x 10-6NW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 WNW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 W 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 WSW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 SW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 SSW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 S 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.28 x 10-6 3.28 x 10-6SSE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 8.68 x 10-6 0.00 0.00 8.68 x 10-6SE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 ESE 0.00 0.00 0.00 0.00 0.00 0.00 4.43 x 10-6 0.00 0.00 6.05 x 10-7 5.03 x 10-6Ring 0.00 0.00 0.00 0.00 0.00 3.72 x 10-5 3.39 x 10-4 1.63 x 10-5 2.47 x 10-5 1.71 x 10-5 4.34 x 10-4Cumulative 0.00 0.00 0.00 0.00 0.00 3.72 x 10-5 3.76 x 10-4 3.92 x 10-4 4.17 x 10-4 4.34 x 10-4Source: IIFP, 2011a 
4-50 

Table 4-27. Collective Dose Equivalents to All Ages Population (person-rem) (gas release pathways). 

Vector 0-1 mi 1-2 mi 2-3 mi 3-4 mi 4-5 mi 5-10 mi 10-20 mi 20-30 mi 30-40 mi 40-50 mi Total 

E 0.00 0.00 0.00 0.00 0.00 0.00 0.0182 4.03 x 10-4 9.53 x 10-4 5.15 x 10-4 0.0201 ENE 0.00 0.00 0.00 0.00 0.00 3.72 x 10-3 4.08 x 10-3 0.00 1.16 x 10-3 4.77 x 10-4 9.44 x 10-3NE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.25 x 10-4 3.25 x 10-4NNE 0.00 0.00 0.00 0.00 0.00 0.00 6.54 x 10-4 0.00 0.00 0.00 6.54 x 10-4N 0.00 0.00 0.00 0.00 0.00 0.00 9.55 x 10-3 3.56 x 10-4 3.56 x 10-4 0.00 0.0103 NNW 0.00 0.00 0.00 0.00 0.00 0.00 9.89 x 10-4 0.00 0.00 0.00 9.89 x 10-4NW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 WNW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 W 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 WSW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 SW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 SSW 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 S 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.28 x 10-4 3.28 x 10-4SSE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 8.68 x 10-4 0.00 0.00 8.68 x 10-4SE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 ESE 0.00 0.00 0.00 0.00 0.00 0.00 4.43 x 10-4 0.00 0.00 6.05 x 10-7 5.03 x 10-4Ring 0.00 0.00 0.00 0.00 0.00 3.72 x 10-3 0.0339 1.63 x 10-3 2.47 x 10-3 1.71 x 10-3 0.0434 Cumulative 0.00 0.00 0.00 0.00 0.00 3.72 x 10-3 0.0376 0.0376 0.0417 0.0434 Source: IIFP, 2011a 
 4-51 

respectively. As shown on those tables, the total population dose would be 4.34 x 10-4 personSv/yr (4.34 x 10-2 person-rem/yr). Multiplying the total population dose by the Interagency 

Steering Committee on Radiation Standards conversion factor of 6 × 10-4 LCFs per person-rem 

(ISCORS, 2002), yields approximately 2.6 x 10-5 LCFs expected in the 80-km (50-mi) population 

for every for one year of operation of the IIFP facility. To put this population dose into 

perspective, based on statistics, the proposed IIFP facility would need to operate for 

approximately 38,400 years to produce 1 LCF in the 80-km (50-mi) population. Therefore, NRC 

staff anticipates that radiological impacts to the 80-km (50-mi) population would be SMALL. 

Workers at the IIFP plant would be subject to higher potential exposures than members of the 

public because they would be involved directly with handling uranium cylinders, uranium 

processes, and decontamination and maintenance of equipment. During routine operations, 

workers at the plant potentially could be exposed to radiation from uranium via inhalation of 

airborne particles and direct exposure to equipment and components containing uranic 

materials. The radiation protection program at the IIFP facility would require routine radiation 

surveys and air sampling to ensure that worker exposures are maintained ALARA. Exposuremonitoring techniques at the plant would include personal dosimeters worn by workers, 

personnel breathing zone air sampling, and annual whole-body counting. 

Potential doses to workers were estimated based on analyses conducted for similar DUF6

deconversion operations at the DOE Piketon (Portsmouth) Ohio and Paducah, Kentucky 

facilities. For those facilities, the TEDE for workers was conservatively estimated to be about 

0.75 mSv per year (75 mrem per year) for involved workers in the deconversion facility. The 

average TEDE for workers at the cylinder yards was estimated to range from 4.3 mSv per year 

(430 mrem per year) to 6.9 mSv per year (690 mrem per year) (DOE, 2004a; DOE, 2004b). 

These doses would be well below the regulatory limit of 50 mSv (5 rem) codified in 10 CFR 

20.1201. 

Annual radiation exposure for an employee would be controlled, monitored, and maintained 

ALARA through the Radiation Protection Program at the IIFP plant. The Radiation Protection 

Program would comply with all applicable NRC requirements established in 10 CFR 20, 

Subpart B. The radiation exposure of involved workers is estimated to be well within public 

health standards and the NRC staff finds that radiological impacts to facility workers would be 

SMALL. Section 4.1.2.9.2 discusses the potential impacts to workers associated with 

radiological transportation. 

Nonradiological Impacts 

Routine nonradiological gaseous fluoride effluents from the plant are listed in Table 4-28. For 

Phase 1 operations, approximately 52.7 kg/yr (116 lb/yr) of HF would be released from the IIFP 

process stacks. Additionally, approximately 64 kg (141 lb) of BF3 and 3.7 kg (8.2 lb) of SiF4

would be released through the stack annually. Emissions of regulated air pollutants would 

come predominately from the operating natural gas-fired boiler that would be used to provide 

steam for the plant heating and autoclave feed systems (the facility would have two boilers for 

redundancy, but only one would operate at any given time. Emission data estimated for the 

boiler indicates that it would not emit more than 13.2 metric tons (14.5 tons) per year of any 

regulated air pollutants. At 100 percent power, the boiler would emit 0.93 metric tons 

(1.03 tons) per year of CO, and 0.11 metric tons (0.12 tons) per year of NOx. IIFP would 

determine if the boilers would require an air quality permit from the State of New Mexico 

(IIFP, 2011a). 
 4-52 

Table 4-28. Estimated Annual Nonradiological Gaseous Fluoride Emissions 

Emission 

Estimated Releases 

DUF6 Dust Collector 

Stack 

SiF4 & BF3 

Dust Collector Stack 

SiF4 N/A 3.7 kg/yr 

(8.19 lb/yr) 

BF3 N/A 62.5 kg/yr 

(137.75 lb/yr) 

HF 49.3 kg/yr 

(108.72 lb/yr) 

0.3 kg/yr 

(0.77 lb/yr) 

Source: IIFP, 2011a 

Nonradiological effluents would not exceed criteria in 40 CFR 50, 59, 60, 61, 122, 129, or 141 

(IIFP, 2009a). The primary chemical hazard is HF. HF is a clear, colorless, corrosive, fuming 

liquid with a very acrid odor. A release can form dense white vapor clouds. Both liquid and 

vapor can cause severe burns to all parts of the body. Exposure to skin, eyes and inhalation or 

ingestion can cause severe health consequences, including death. 

The facility would not discharge any industrial effluents to natural surface waters or soil, and 

there is no plant facility tie-in to a public waste water treatment facility. All effluents would be 

contained on the IIFP site via collection tanks. No routine liquid effluent discharge is expected; 

therefore, there would be no public impact. 

The NRC staff finds that impacts from routine releases (Phase 1 operations) to the public would 

be SMALL. 

No worker exposures exceeding the OSHA Standards for Toxic and Hazardous Substances 

(29 CFR 1910, Subpart Z) are anticipated (IIFP, 2011a). Additionally, handling of all chemicals 

and wastes would be conducted in accordance with the site Environment, Health, and Safety 

Program which would conform to 29 CFR 1910 OSHA standards and specify the use of 

appropriate engineered controls, as well as personnel protective equipment, to minimize 

potential chemical exposures (IIFP, 2011a). 

In addition to the radiological hazards associated with uranium, workers may be potentially 

exposed to the chemical hazards associated with uranium. UF6 is hygroscopic (moisture 

absorbing) and, in contact with water, would chemically breakdown into UO2F2 and HF. When 

released to the atmosphere, gaseous UF6 combines with humidity to form a cloud of particulate 

UO2F2 and HF fumes. The reaction is very fast and is dependent on the availability of water 

vapor. Consequently, an inhalation of UF6 is typically an internal exposure to HF and UO2F2. In 

addition to the radiation dose, a worker would be subjected to two other primary toxic effects: 

the uranium in the uranyl complex acts as a heavy metal poison that can affect the kidneys, and 

the HF can cause acid bums to the skin and lungs if concentrated. Because of low specific 

activity values, the radiotoxicity of UF6 and its products are smaller than their chemical toxicity 

(IIFP, 2011a). 

Because of the containment systems for gasses used or created in the plant process, and the 

personal protective equipment that would be used in areas where exposure could occur, worker 
 4-53 

exposure to in-plant gaseous releases would be minimal, and no exposures exceeding 

29 CFR 1910, Subpart Z are anticipated (IIFP, 2009a). Laboratory and maintenance operations 

involving hazardous gaseous or respirable effluents would be conducted with ventilation control 

(i.e., fume hoods, local exhaust, or similar) and with the use of respiratory protection, as 

required. All regulated gaseous effluents would be below regulatory limits as specified by the 

New Mexico Air Quality Bureau (IIFP, 2011a). The NRC staff finds that impacts from routine 

releases within the facility (Phase 1 operations) to workers would be SMALL. 

The proposed action involves a major industrial activity with the potential to cause temporary 

injuries, long-term injuries and/or disabilities, and even fatalities to workers. Common 

occupational accidents at facilities similar to the proposed IIFP plant typically involve hand and 

finger injuries, tripping accidents, minor burns and impacts due to striking objects or falling 

objects. To estimate the number of potential fatal and nonfatal occupational injuries from 

operation of the proposed IIFP facility, data on fatal and nonfatal occupational injuries per 

worker per year were collected from the U.S. Department of Labor’s Bureau of Labor Statistics. 

Nonfatal and fatal occupational injury rates for the manufacturing industry were used to 

calculate the estimated fatal and nonfatal injuries associated with operation of the proposed IIFP 

facility. As shown in Table 4-29, less than four nonfatal injuries and less than one fatality are 

expected annually during operation of the proposed IIFP facility. The NRC staff finds that the 

impacts to human health from occupational injuries during operation would be SMALL. 

Table 4-29. Annual Nonfatal and Fatal Occupational Injuries Projected for Operation of 

the IIFP Facility 

Category Injury Rate Expected Occurrences 

Nonfatal Injuries 2.3 per 100 workersa 3.2 

Fatal Injuries 2.2 per 100,000 workersb less than 1 (3.1 x 10-3) a

 The expected nonfatal injury rate (total recordable cases) is from BLS (2010a). b

 The fatal injury rate is from BLS (2010b). 

c

 Expected occurrences are based on 140 workers during Phase 1 operations. 

Worker health and safety at the proposed IIFP facility would be protected by its Chemical Safety 

Program, the Radiation Protection Program, and the Industrial Safety Program. These 

programs would comply with applicable State, NRC (10 CFR 20), and OSHA (29 CFR 1910) 

requirements. Work environments that present the potential for exposure to chemical, 

biological, or physical agents (e.g., radiation, noise, heat/cold, vibration) would be evaluated, 

and appropriate safety controls would be implemented and/or safety equipment would be 

assigned to workers. Personal protective equipment requirements would be based on the 

nature of the work and chemical and/or radiological hazards present and would be a key 

component to minimizing exposure to chemical and radiological agents. Exposure monitoring 

would be conducted on radiation workers to evaluate their personal exposure; if personal 

monitoring is not feasible, work area monitoring would be used to represent personal exposure. 

The NRC staff finds that the impacts to human health from occupational injuries during 

operation would be SMALL. 

4.1.2.12 Waste Management Impacts

Waste generation during facility operation would be minimized through reduction, reuse, and 

recycling, as applicable to specific waste streams. The proposed IIFP facility would incorporate 

waste minimization systems in its operational procedures and design with the goal of conserving 
 4-54 

materials, recycling important compounds, and preventing the spread of contamination. Good 

work practices would be used to collect and sort the wastes generated during operation for 

recycling or disposal (e.g., using designated roll-off containers and collection areas for different 

types of wastes) (IIFP, 2011a). 

There would be no permanent onsite disposal of any waste; only temporary storage. Wastes 

generated at the proposed IIFP facility would be disposed of at licensed facilities designed to 

accept the various waste types. The management of stormwater and wastewater at the 

proposed IIFP facility is discussed in Section 4.1.2.6. 

Solid waste, including sanitary waste, miscellaneous trash, vehicle air filters, empty cutting oil 

cans, miscellaneous scrap metal, and paper would be shipped offsite for recycling or 

minimization, if appropriate, or transported offsite to an approved local landfill (IIFP, 2011a). 

The radioactive DUO2 waste from the deconversion process would be shipped to an offsite LLW 

disposal facility licensed to accept DUO2. Other LLW, including dust collector bags, ion 

exchange resin, crushed contaminated drums, contaminated trash, contaminated coke, and 

carbon trap material, would be collected in labeled containers in each Restricted Area and 

transferred to the Radioactive Waste Storage Area for inspection. Waste would be volumereduced, if appropriate, and disposed of at a licensed LLW disposal facility. 

Hazardous wastes and some mixed wastes would be collected at the point of generation in 

approved containers, transferred to the onsite Waste Storage Area, inspected, classified, and 

shipped by a licensed transporter to a hazardous waste treatment or disposal facility. The 

majority of the projected hazardous waste is the potential waste CaF2. As described in 

Section 2.1.6.4.2, the KOH regeneration process results in CaF2 that would be packaged and 

stored for sale. If a market for this material is not identified, the CaF2 would be sent to a 

licensed hazardous waste disposal facility. Any mixed waste would be treated in its original 

collection container prior to shipment for offsite disposal, or shipped directly to a mixed waste 

processor (IIFP, 2011a). 

Tables 4-30, 4-31, and 4-32 provide information on the types and estimated annual quantities of 

solid, hazardous, and LLW, respectively, generated from Phase 1 operations at the proposed 

IIFP facility. 

As described in Section 4.1.1.12, nonhazardous solid wastes from the proposed IIFP facility 

would likely be transported to the Lea County landfill for disposal. The Lea County landfill 

receives approximately 82,500 tons of solid waste annually (NMED, 2009). Nonhazardous, 

industrial waste generated from operation of the proposed facility (up to 46 tons per year as 

shown in Table 4-30) would result in an increase of approximately 0.06 percent in the waste that 

the Lea County Landfill receives annually from all other sources. The NRC staff finds that this 

quantity of nonhazardous waste material would result in SMALL impacts that could be managed 

effectively. 

Hazardous wastes would be packaged and shipped offsite to licensed hazardous waste 

treatment and disposal facilities in accordance with Federal and State regulations (IIFP, 2011a). 

Table 4-31 shows that the quantity of hazardous waste generated by operations could be as 

much as 154 tons per year if a market for the CaF2 cannot be identified. The projected annual 

hazardous waste generation would likely classify the proposed IIFP facility as large quantity 

generator (over 1,000 kg/mo [2,200 lb/mo]). As discussed in Section 4.1.1.12, hazardous waste 

generators in New Mexico produced 1,078,672 tons of hazardous waste in 2009 (EPA, 2010b). 
 4-55 

The maximum IIFP generation rate would result in an increase of less than 0.02 percent in the 

hazardous waste generated annually in the State of New Mexico. Therefore, the NRC staff 

finds that the quantity of operations hazardous waste material would result in SMALL impacts 

that could be managed effectively. 

Table 4-30. Solid Waste Generation – Operations 

Material Estimated Annual Amount 

Clothing 45 – 90 kg 

(100 – 200 lbs) 

Molecular sieve 140 – 230 kg 

(300– 500 lbs) 

Municipal trash waste 27,000 – 41,000 kg 

(60,000 – 90,000 lbs) 

Safety gear 90 – 180 kg 

(200 – 400 lbs) 

Waste Glass 23 – 90 kg 

(50 – 200 lbs) 

Total 27,500 – 41,400 kg 

(60,650 – 91,300 lbs) 

Source: IIFP, 2011a 

Table 4-31. Hazardous Waste Generation – Operations 

Material Estimated Annual Amount 

Aerosol cans, paints cans, bulbs 450 – 1400 kg 

(1,000 – 3,000 lbs) 

CaF2

a 90,000 – 136,000 kg 

(200,000 – 300,000 lbs) 

Lab chemicals 90 – 180 kg 

(200 – 400 lbs) 

Oil sorbent 900 – 2,300 kg 

(2,000 – 5,000 lbs) 

Totala 92,000 – 140,000 kg 

(203,200 – 308,400 lbs) 

Source: IIFP, 2011a 

a

 Includes CaF2 that would not be waste if sold. 

Table 4-32. Low Level Radioactive Waste Generation – Operations 

Material Estimated Annual Amount 

Activated alumina 900 – 1,800 kg 

(2,000 – 4,000 lbs) 

Air ventilation filters 23 – 45 kg 

(50 – 100 lbs) 

Carbon 11,000 – 14,000 kg 

(25,000 – 30,000 lbs) 

DUF4 clinkers 2,300 – 4,500 kg 

(5,000 – 10,000 lbs) 

Coke 3,600 – 5,400 kg 

(8,000 – 12,000 lbs) 
 4-56 

Table 4-32. Low Level Radioactive Waste Generation – Operations (Continued) 

Material Estimated Annual Amount 

Crushed drums 450 – 1,400 kg 

(1,000 – 3,000 lbs) 

Dust collector bags 230 – 1,400 kg 

(500 – 3,000 lbs) 

Ion exchange resin 450 – 900 kg 

(1,000 – 2,000 lbs) 

Oxide for burial (plus drums) 1,270,000 – 2,800,000 kg 

(2,800,000 – 6,200,000 lbs) 

Radioactive waste trash 16,000 – 25,000 kg 

(35,000 – 55,000 lbs) 

Scrap metal 1,800 – 3,600 kg 

(4,000 – 8,000 lbs) 

Sintered metal tubes 450 – 900 kg 

(1,000 – 2,000 lbs) 

Sodium fluoride 900 – 1,800 kg 

(2,000 – 4,000 lbs) 

Spent blasting sand 45 – 90 kg 

(100 – 200 lbs) 

Wood trash (pallets) 450 – 1,800 kg 

(1,000 – 4,000 lbs) 

Total 1,309,000 – 2,875,000 kg 

(2,885,650 – 6,337,300 lbs) 

Source: IIFP, 2011a 

Depleted uranium is classified as Class A low level waste; however, a specific disposal site may 

place additional limits on concentration, volume or waste form. Disposal options, including 

waste form, would be determined after licensing and may change over the operating life of the 

facility; however, licensed LLW disposal facilities, including the U.S. Ecology site in Richland, 

Washington; EnergySolutions site in Clive, Utah, DOE’s site in Area 5 of the Nevada National 

Security Site (formerly known as the Nevada Test Site), and the WCS facility in Andrews, Texas 

are potentially viable options, provided regulatory and contractual conditions can be satisfied. 

The U.S. Ecology facility is in the Pacific Northwest Compact, which has an agreement with 

Rocky Mountain Compact, of which New Mexico is a member, to dispose of waste but the U.S. 

Ecology facility would need a revision in the allowable total uranium inventory. EnergySolutions

accepts shipments from all states. Shipment to the Nevada National Security Site would require 

DOE to accept possession of the LLW (consistent with Section 13 of the USEC Privatization Act 

of 1996). 

The WCS facility is 42 km (26 mi) southeast of the proposed site but is currently limited to waste 

from the Texas Compact and therefore, would have to establish approval mechanisms for outof-compact waste to be disposed. Furthermore, the Rocky Mountain Compact would have to 

approve shipment outside the compact. The analysis in this EIS is not intended to support 

selection of the LLW disposal facility for the DUO2. 

Decisions regarding the disposal location for DUO2 and other LLW would be made based on 

economic and other considerations. For analysis purposes, the radioactive wastes were 

assumed to be shipped to the EnergySolutions site in Clive, Utah. As shown in Table 4-32, up 

to 3,170 tons per year of LLW could be sent for disposal. Most of the LLW generated 
 4-57 

Acute Exposure Guideline Levels 

(AEGLs) 

AEGLs represent threshold exposure limits 

for the general public and are applicable to 

five emergency exposure periods (10 

minutes, 30 minutes, 1 hour, 4 hours, and 

8 hours) and are distinguished by varying 

degrees of severity of toxic effects. It is 

believed that the recommended exposure 

levels are applicable to the general 

population including infants and children, 

and other individuals who may be 

susceptible. The three AEGLs have been 

defined as follows: 

AEGL-1 is the airborne concentration of a 

substance, expressed as parts per million 

or milligrams per cubic meter (ppm or 

mg/m3) above which it is estimated that the 

general population, including susceptible 

individuals, could experience notable 

discomfort, irritation, or certain 

asymptomatic nonsensory effects. 

However, the effects are not disabling and 

are transient and reversible upon cessation 

of exposure. 

AEGL-2 is the airborne concentration 

(expressed as ppm or mg/m3) of a 

substance above which it is estimated that 

the general population, including 

susceptible individuals, could experience 

irreversible or other serious, long-lasting 

adverse health effects or an impaired 

ability to escape. 

AEGL-3 is the airborne concentration 

(expressed as ppm or mg/m3) of a 

substance above which it is estimated that 

the general population, including 

susceptible individuals, could experience 

life-threatening health effects or death.

(approximately 97 percent) would be the DUO2 produced by the deconversion process. The 

DUO2 and other LLW generated would be Class A waste (IIFP, 2009a). The projected 

quantities of DUO2 and other Class A LLW generated by the proposed IIFP facility operations 

would have little effect on the available disposal capacity for such material. The projected 

volume of DUO2 waste (up to 6,200 55-gal drums or 1,300 m3

/yr) represents approximately 

0.04 percent of the 3.1 million m3 disposal volume of the Class A cell at the Clive facility (DOE, 

2000). The Clive facility accepts most of the United States’ Class A waste and is estimated to 

have capacity to accept this waste at current volume levels for more than 20 years (GAO, 

2004). The NRC staff finds that the potential impact of proposed IIFP facility operations on LLW 

disposal capacity would be SMALL. 

4.1.2.13 Impacts of Postulated Accidents 

4.1.2.13.1 Facility Accidents 

The operation of the proposed IIFP facility would 

involve risks to workers, the public, and the 

environment from potential accidents. The facility 

would be licensed under 10 CFR 40, Domestic 

Licensing of Source Material, and would also be subject 

to consideration of 10 CFR 70, Subpart H, Additional 

Requirements for Certain Licensees Authorized to 

Possess a Critical Mass of Special Nuclear Material, as 

part of the licensing basis for the application review of 

certain new source material facilities as an interim 

measure pending the completion of 10 CFR 40 

rulemaking. NRC regulation 10 CFR 70 requires that 

each applicant or licensee evaluate, in an Integrated 

Safety Analysis (ISA), its compliance with certain 

performance requirements. As part of the safety 

review, the NRC staff would conduct a confirmatory 

analysis, which independently evaluates the 

consequences of potential accidents identified in IIFP’s 

ISA plans. The accidents evaluated are a 

representative selection of the types of accidents that 

are possible at the proposed facility. 

The analytical methods used in the NRC staff’s 

consequence assessment are based on NRC guidance 

for analysis of nuclear fuel-cycle facility accidents 

(NRC, 1990; NRC, 1991; NRC, 1998) and regulatory 

guidance cited by IIFP (EPA, 1999). The consequence 

assessment considered the available information 

regarding the facility prior to final design. The NRC 

staff analyzed accidents involving the release of HF, 

the primary chemical hazard at the facility. HF is a 

clear, colorless, corrosive, fuming liquid. In high 

concentrations, a release could form dense white vapor 

clouds. HF releases pose a chemical risk to workers, 

the public, and the environment. Both direct releases 

of HF and releases from a byproduct reaction involving 
 4-58 

other fluoride species (DUF6, DUF4, SiF4 and BF3) could pose accident risks. NRC staff also 

evaluated accidents involving radioactive materials (depleted uranium bound with fluoride 

and/or oxide) for radiation and chemical (heavy metal toxicity) impacts. 

4.1.2.13.1.1 Accidents Considered 

A number of potential accidents could occur at the proposed facility. The NRC staff selected, 

for detailed evaluation, a subset of the potential accident scenarios that is intended to 

encompass the range of possible accidents. The accident sequences the staff selected vary in 

severity from high- to low-consequence events, and include accidents initiated by natural 

phenomena (seismic event), operator error, and equipment failure. 

The accident scenarios evaluated were as follows: 

• Seismic event causing multiple process containment failures: This scenario would occur 

across multiple processes. The staff evaluation of acute effects was limited to cylinder 

breaches in the cylinder storage area which IIFP identified as resulting in high 

consequences. The staff evaluation of collective effects utilized an estimate of the total 

facility source term. 

• Liquid DUF6 cylinder drop: This scenario would include a breach and release of liquid 

DUF6. 

• SiF4 release: This scenario could be caused by over-pressurization of a nitrogen loop 

with secondary cold trap breach. 

• UF4 collection drum spill. 

• UF4 vacuum transfer line rupture: This scenario would occur outside of the building. 

IIFP’s ISA attributes “likelihood categories” (highly unlikely, unlikely, or not unlikely) to each 

accident sequence. The staff’s analysis described in this section does not include an estimate 

of the probability of occurrence of accidents, which, in combination with consequences, would 

reflect the overall risk from an accident. Instead, analyzed accidents are assumed to occur and 

consequences of each accident reported. 

4.1.2.13.1.2 Accident Consequences 

The performance requirements in 10 CFR 70, Subpart H, define acceptable levels of risk of 

accidents at nuclear fuel cycle facilities such as the proposed facility. The regulations in 

Subpart H require that IIFP reduce the risks of credible high-consequence and intermediateconsequence events, with all nuclear processes being subcritical. Table 4-33 defines the 

accident consequence categories used for the accident analysis. Table 4-34 defines exposure 

thresholds, by receptor and for intermediate- and high- consequence accidents, for each 

chemical species analyzed, as interpreted by IIFP. Subcritical conditions are assured because 

the facility would work exclusively with depleted uranium materials, and the incoming materials 

would be assayed to ensure this condition. 

The staff evaluated the consequences of the selected accidents against the threshold values for 

a facility worker, a site worker 100 m (328 ft) from the release point, an individual at the site 

boundary, and the environment at the site boundary. Table 4-35 summarizes these results. 
4-59 

Table 4-33. Accident Consequence Categories 

Category Workers Off-Site Public Environment 

Category 3 High Consequences 

• Individual Radiation Dose ≥100 rem • Individual Chemical Dose = endanger 

life (> than AEGL-3, 10 min exposure) 

• 75 mg soluble uranium intake 

• Individual Radiation Dose ≥25 rem 

• Chemical Dose = long-lasting health 

effects (> AEGL-2, 30 min exposure) 

• 30 mg soluble uranium intake 

Category 2 Intermediate Consequences 

• Individual Radiation Dose ≥25 rem • Individual Chemical Dose = long-lasting 

health effects (>AEGL-2 but <AEGL-3, 10 min exposure) 

• Individual Radiation Dose ≥5 rem • Chemical Dose = mild transient health 

effects (>AEGL-1 but <AEGL-2, 30 min exposure) 

Radiological release >5000 times values in Table 2 of 10 CFR 20 

Category 1 Low Consequences 

Accidents of lower radiological and chemical exposures than Category 2 

Accidents of lower radiological and chemical exposures than Category 2 

Radiological releases lower than Category 2 

Source: IIFP, 2009b Table 4-34. Chemical Consequence Exposure Thresholds 

Chemical 

Intermediate Consequences High Consequences 

Worker Exposure Public Exposure Worker Exposure Public Exposure 

Level of 

Concern 

Concentration, 

mg/m3

Level of 

Concern 

Concentration, 

mg/m3

Level of 

Concern 

Concentration, 

mg/m3

Level of 

Concern 

Concentration, 

mg/m3

Hydrogen fluoride (HF) 

AEGL-2 

10 min 

77.8 AEGL-1 

30 min 0.82 AEGL-3 10 min 139 AEGL-2 30 min 28 

Silicon tetrafluoride (SiF4) 

AEGL-2 

10 min 27 AEGL-1 30 min 0.21 AEGL-3 10 min 81 AEGL-2 30 min 18 

Boron trifluoride (BF3) AEGL-2 

10 min 47 AEGL-1 30 min 2.5 AEGL-3 10 min 140 AEGL-2 30 min 47 

Uranium hexafluoride (UF6) 

AEGL-2 

10 min 28 AEGL-1 30 min 3.6 AEGL-3 10 min 216 AEGL-2 30 min 19 

Uranyl fluoride (UO2F2) 

AEGL-2 

10 min 28 AEGL-1 30 min 3.6 AEGL-3 10 min 216 AEGL-2 30 min 19 

Uranium tetrafluoride (UF4) 

AEGL-2 

10 min 28 AEGL-1 30 min 3.6 AEGL-3 10 min 216 AEGL-2 30 min 19 

Uranium dioxide (UO2) 

ERPG-2 

10 min 201 ERPG-1 30 min 0.68 ERPG-3 10 min 180 ERPG-2 30 min 32 

Source: IIFP, 2009b ERPG = Emergency Response Planning Guideline – Concentration values established by the American Industrial Hygiene Association that meet certain human 

response criteria similar to those for Acute exposure guideline levels (AEGLs). 
 4-60 

Table 4-35. Summary of Accident Analysis Results 

Receptor Parameter 

Worst 

Case 

DUF6

Release 

Seismic 

event 

causing 

multiple 

process 

containment 

failures 

Fluorine 

Compounds 

Release 

UF4 Spill 

Transfer 

Line 

Rupture 

Worker 

(inside room, 

10 min 

exposure) 

HF concentration 

(mg/m3

) 1.34 x 106

 56.5 

UO2F2

concentration 

(mg/m3

) 

5.14 x 106

 

Soluble U intake 

(mg) 7.94 x 105

 

Dose (rem) 686 0.052 

SiF4

concentration 

(mg/m3

) 

 73.5 

UF4

concentration 

(mg/m3

) 

 121 

Worker 

(outside 

building, 

10 min 

exposure) 

HF concentration 

(mg/m3

) 1.64 x 104

 47.3 0.452 

UO2F2

concentration 

(mg/m3

) 

6.05 x 104

 179 

Soluble U intake 

(mg) 9,340 27.6 

Dose (rem) 8.07 0.02 4.05 x 10-

4 3.48 x 10-4

SiF4

concentration 

(mg/m3

) 

 0.588 

UF4

concentration 

(mg/m3

) 

 0.953 0.817 

Public 

(at Site 

Boundary, 

30 min 

exposure) 

HF concentration 

(mg/m3

) 7,800 15.7 0.367 

UO2F2

concentration 

(mg/m3

) 

2.93 x 104

 59.4 

Soluble U intake 

(mg) 1.36 x 104

 27.4 

Dose (rem) 11.7 0.02 0.0017 3.45 x 10-4

SiF4

concentration 

(mg/m3

) 

 0.478 

UF4

concentration 

(mg/m3

) 

 1.33 0.27 
 4-61 

Table 4-35. Summary of Accident Analysis Results (Continued) 

Receptor Parameter 

Worst 

Case 

DUF6

Release 

Seismic 

event 

causing 

multiple 

process 

containment 

failures 

Fluorine 

Compounds 

Release 

UF4 Spill 

Transfer 

Line 

Rupture 

Environment 

(at Site 

Boundary, 

24 hr avg) 

Activity 

Concentration 

(uCi/mL) 

2.7 2 x 10-7 4.96 x 10-10 6.67 x 10-

12 2.17 x 10-12

Public 

collective 

exposure 

Dose (personrem) 16.1 135 0.00317 0.00192 

LCF 0.00351 0.0297 2.63 x 10-6 1.59 x 10-6

Source: NRC, 2011 

Note: Not all accident sequences resulted in datum for the categories listed in this table. This could be because the sequence was 

postulated to occur outside of a building or did not involve all the chemicals or radioactive materials listed. 

The most significant accident consequences are those associated with the release of liquefied 

UF6 caused by rupturing a cylinder. The facility emergency plan addresses this type of event, 

as well as all other lower-risk, high- and intermediate-consequence events. IIFP would reduce 

the likelihood of this type of event by requiring a robust cylinder design that maintains its 

integrity during credible drops, shocks, collisions, and thermal events, and an interlock on the 

autoclave which would prevent the removal of liquid or partially full cylinders during heating/feed 

cycles. The NRC staff concludes that through the combination of plant design, passive and 

active engineered controls, and administrative controls, accidents at the facility would pose an 

acceptably SMALL risk to workers, the environment, and the public. 

NRC regulations and IIFP’s operating procedures for the proposed facility would be designed to 

ensure that the high and intermediate accident scenarios would be highly unlikely and unlikely, 

respectively. The combination of responses by Items Relied on for Safety, which mitigate or 

prevent emergency conditions, and the implementation of emergency procedures and protective 

actions in accordance with the facility emergency plan would limit the consequences and reduce 

the likelihood of accidents that could otherwise extend beyond the proposed facility site and 

property boundaries. 

4.1.2.13.2 Transportation Accidents 

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

enrichment facilities, empty DUF6 cylinders back to the commercial enrichment facilities, DUO2

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

facilities. Section 4.1.2.9.2 describes these shipments, which are summarized here in 

Table 4-36. 

NRC staff used the TRAGIS (Johnson and Michelhaugh, 2003) transportation routing computer 

modeling code and the RADTRAN5 (Neuhauser and Kanipe, 2003) transportation risk 

assessment computer modeling code to calculate the radiological transportation dose-risk to the 

exposed population along the transportation route. Dose-risk is the product of dose and 

probability for small segments along the route and summed over the entire route. Accident 

frequencies were taken from Saricks and Tompkins (1999). Severity fractions and 

package/contents response characteristics were taken from NUREG-0170 (NRC, 1977). 
 4-62 

Results of that analysis are provided in Table 4-37, with more details on the analysis provided in 

Appendix E. LCF risk is the product of dose-risk times the Interagency Steering Committee on 

Radiation Standards conversion factor of 6 x 10-4 LCFs per person-rem (ISCORS, 2002). 

Table 4-36. Summary of Annual Radiological Transportation Shipments 

Description Origin Destination 

Number of 

Shipments Packaging 

Full DUF6 cylinders URENCO USA IIFP 293 1 cylinder per truck 

Full DUF6 cylinders GLE IIFP 293 1 cylinder per truck 

Full DUF6 cylinders from 

AREVA Eagle Rock 

Eagle Rock IIFP 293 1 cylinder per truck 

Empty DUF6 cylinders IIFP URENCO USA 293 1 cylinder per truck 

Empty DUF6 cylinders IIFP GLE 293 1 cylinder per truck 

Empty DUF6 cylinders IIFP Eagle Rock 293 1 cylinder per truck 

DUO2 IIFP EnergySolutions, 

Clive Facility 

155 55-gal drums, 

40 per truck 

DUO2 IIFP Waste Control 

Specialists 

155 55-gal drums, 

40 per truck 

Miscellaneous LLW IIFP EnergySolutions, 

Clive Facility 

31 55-gal drums, 

40 per truck 

Miscellaneous LLW IIFP Waste Control 

Specialists 

31 55-gal drums, 

40 per truck 

Source: IIFP, 2011a 

Table 4-37. Annual Accident Dose-Risk and LCF-Risk from Radiological Transportation 

Description 

Dose-Risk 

(person-Sv) 

Dose-Risk 

(person-rem) LCF Risk 

Full DUF6 cylinders from URENCO USA 4.0 x 10-5 0.0040 2.4 x 10-6

Full DUF6 cylinders from GLE Facility 0.14 14 0.0081 

Full DUF6 cylinders from AREVA Eagle Rock 0.10 10 0.0060 

Empty DUF6 cylinders to URENCO USA 1.5 x 10-7 1.5 x 10-5 8.7 x 10-9

Empty DUF6 cylinders to GLE Facility 4.9 x 10-4 0.049 2.9 x 10-5

Empty DUF6 cylinders to AREVA Eagle Rock 3.7 x 10-4 0.037 2.2 x 10-5

DUO2 to EnergySolutions, Clive 0.10 10 0.0063 

DUO2 to Waste Control Specialists 3.9 x 10-5 0.0039 2.3 x 10-6 

Miscellaneous LLW to EnergySolutions, Clive 5.5 x 10-5 0.0055 E 3.3 x 10-6

Miscellaneous LLW to Waste Control 

Specialists 2.0 x 10-8 2.0 x 10-6 1.2 x 10-9

Source: See Appendix E 

Assuming a scenario in which DUF6 is shipped from the enrichment facility and the DUO2 waste 

is shipped to the waste disposal facility as the greatest transportation risks, one arrives at 

0.24 person-sievert (24 person-rem) of accident risk annually. This is for receipt and return of 

cylinders to the GLE facility in Wilmington, North Carolina and disposal of low-level waste at 
 4-63 

EnergySolutions Clive, Utah facility. The equivalent number of latent cancer fatalities is 

0.014 LCF. 

According to the Centers for Disease Control and Prevention (CDC, 2010), there were 

178.4 cancer deaths per 100,000 people in 2007 with a probability of occurrence of 100 percent. 

Given the high rate of cancer fatalities in the U.S. from all causes, the addition of 0.014 LCF 

from the risk of a radiological transportation accident from the proposed facility is considered by 

the NRC staff to be a SMALL impact. While mitigation measures are not required, IIFP would 

be required by NRC and DOT regulations to package and manage the transported waste to 

minimize the probability of accidental release of radioactive material. 

4.1.3 Decommissioning Impacts 

This section summarizes the potential environmental impacts of the decommissioning of the 

proposed IIFP facility. Decommissioning as described in Chapter 10 of the License Application 

(IIFP, 2009a), would involve the decontamination of equipment and buildings and the removal 

and disposal of all operating fuel-cycle facility equipment. Decommissioning would be funded in 

accordance with a decommissioning funding plan for the proposed IIFP facility, which will be 

prepared by IIFP in accordance with 10 CFR 70.25(a) and NUREG-1757 (NRC, 2006). 

A complete description of the actions to be taken to decommission the proposed IIFP facility at 

the expiration of the plant’s NRC license period (if the license is granted) cannot be provided at 

this time. In accordance with 10 CFR 70.38, IIFP must prepare and submit a decommissioning 

plan (different from the decommissioning funding plan) to the NRC for review and comment at 

least 12 months prior to the expiration of the proposed facility’s NRC license. IIFP would submit 

a final decommissioning plan to the NRC for review prior to the start of decommissioning. This 

plan would include more detail than is available at this time. All decommissioning activities 

would comply with the applicable Federal, State, and local regulations in effect at the time of the 

decontamination and decommissioning activities. 

It is reasonable to expect that decommissioning would occur over the course of three years and 

that it would be expected to employ 40 workers for the three-year period (IIFP, 2009a). 

Two possibilities exist for decommissioning the facility. One is to leave the structures and most 

(non-uranium-processing) support equipment in place after they are decontaminated to 

appropriate (unrestricted release) levels, in accordance with 10 CFR 20, for ultimate use by 

another industrial tenant or owner. The second is to decontaminate and raze the entire facility, 

restoring the site to its current use as open range land (e.g., grazing and wildlife habitat). The 

final disposition of the property would be determined at the time of decommissioning. The ER 

assumes that “...decommissioning...will involve the removal of the internal equipment, utilities, 

and products from the building(s); however the physical structure, associated foundations, 

access roads, and utility lines will likely remain intact,” (IIFP, 2009a). Therefore, this section 

evaluates leaving structures for industrial re-use as the likely decommissioning option. 

Decontamination and decommissioning of the proposed facility is described in Section 2.1.7. 

Regardless of the end use of the facility, decommissioning would begin with the 

decontamination and removal of uranium-processing equipment and other materials to be 

shipped offsite for licensed disposal. The number of daily truck shipments is anticipated to be 

similar to the average daily shipments during operations, and the total number of shipments 

would depend upon the volume of demolition debris and materials packaged for disposal. 

Radioactively-contaminated equipment and materials would be disposed of by shipping them to 
 4-64 

a licensed treatment or disposal facility in compliance with applicable NRC and DOT 

requirements. 

Discussions of issue- and resource-specific impacts of decommissioning include the following: 

LAND USE: The chain-link perimeter security fence surrounding the facility compound could be 

removed following decommissioning. If decommissioning included the removal of all facilities, 

the land could revert to its current use for grazing and wildlife habitat. If buildings are not 

removed, another industry could move into the facility; and the 16 ha (40 ac) would not be 

available for grazing; however, the undeveloped land (240 ha, or 600 ac) could be available for 

grazing. Land use plans and land uses surrounding the site would be unaffected by 

decommissioning. The NRC staff concludes that regardless of the condition (option with 

structures remaining for alternate uses or option with all structures removed/site restored), the 

impacts to local land use due to decommissioning would be SMALL. 

HISTORIC AND CULTURAL RESOURCES: Decommissioning of the facility would not involve 

land disturbance which could affect historic properties, districts, resources or significant 

historic/precontact archaeological sites. No historic resources were identified within the cultural 

resources APEs and three isolated artifacts that are not NRHP-eligible were identified during the 

cultural resource survey. No Native American Tribes expressed concerns to the NRC regarding 

the project. 

Therefore, the NRC staff concludes that any impacts to historic properties, districts, resources 

or significant historic/precontact archaeological sites during facility decommissioning would be 

SMALL.

CLIMATE, METEOROLOGY, AND AIR QUALITY: GHG emissions associated with 

decommissioning would result primarily from three activities: (1) the onsite consumption of 

fossil fuels in vehicles and equipment used to dismantle and possibly demolish existing 

structures or excavate buried utilities and components, (2) the transportation of waste materials 

and salvage materials from the proposed site to appropriate offsite disposal or recycling 

facilities, and (3) the commuting decommissioning workforce. 

The following are conservative assumptions that can be made relative to the proposed IIFP 

facility decommissioning and that can be used to estimate GHG impacts associated with 

decommissioning activities (IIFP, 2011a): 

• CO2 emissions from shipments of DUF6 feed materials and operational waste shipments 

still occurring during the initial period of decommissioning are treated as operational 

GHG impacts. 

• Shipments of wastes or recycling materials would occur by diesel-fueled trucks 

averaging 23.5 liters of fuel per100 km (10 mpg). 

• LLW resulting from decontamination activities would be substantially greater in volume 

than LLW resulting from routine IIFP facility operation. 

• All non-radioactive and non-hazardous solid wastes would be delivered to the same area 

landfills and treatment facilities that received wastes of similar nature during IIFP facility 

operation. Assuming successful decontamination of the majority of IIFP facility 

equipment and structures, a significantly higher number of annual trips would occur 

throughout the 3-year decommissioning phase than would have occurred annually 
 4-65 

during IIFP facility operation, and the resulting CO2 emissions would be at least an order 

of magnitude greater than the values for such waste shipments appearing in 

Section 4.1.2.4.1, “Greenhouse Gases”. 

• All non-radioactive hazardous waste generated during IIFP facility operations would 

already have been transported to permitted disposal facilities. The CO2 emissions of 

such deliveries would be credited to the IIFP facility operational phase. The amount of 

non-radioactive hazardous waste generated as a result of decommissioning is expected 

to be small and would likely be transported to the same disposal facilities that received 

similar waste during IIFP facility operation. It is further assumed that an appropriately 

permitted disposal facility will be located within a reasonable distance from the proposed 

IIFP facility, resulting in limited amounts of GHG emissions from transport. 

• Except for the period at the beginning of decommissioning when some operations would 

still be ongoing, the decommissioning workforce would decrease from 140 to 

40 employees. Therefore annual releases of CO2 related to workforce commuting would 

be approximately one-third of the values shown in Table 4-13 for operations. Releases 

of CO2 related to workforce commuting during the time that operations are continuing as 

decommissioning is beginning would be approximately one-third higher than the values 

shown in Table 4-13. 

Therefore, the NRC staff concludes that impacts to climate and air quality would be SMALL. 

GEOLOGY, MINERALS, AND SOIL: The general condition of the site geologic resources would 

not change during or after decommissioning activities. Minerals at the site and vicinity would 

not be affected by decommissioning. As with construction, demolition of structures and 

disturbed areas would be subject to BMPs to prevent adverse impacts to soils. As a final step in 

decommissioning, soil testing would demonstrate that site soils meet NRC, EPA, and NMED 

regulations and guidelines for free release. Accordingly, the NRC staff concludes that impacts 

to geology, minerals, and soil during decommissioning would be SMALL. 

WATER RESOURCES: No surface water is present on the site, so decommissioning would not 

affect surface water. The management of stormwater is not expected to change during or after 

decommissioning activities, unless the site is restored to its original open range conditions. 

Groundwater would be used during decommissioning for the potable water system, and 

decommissioning needs such as dust suppression. Water for facility processes would no longer 

be used; therefore, water withdrawal during decommissioning would be less than during 

operations. 

Accordingly, the NRC staff concludes that impacts to water resources during decommissioning 

would be SMALL. 

SOCIOECONOMICS: Decommissioning is expected to employ 40 workers over three years. 

The workers would be IIFP employees or work in the construction trades. All would be 

residents of the ROI. No workers would migrate into the area; however, some former IIFP staff 

could migrate out of the area. The NRC staff finds that impacts to socioeconomic resource 

would be SMALL. The NRC staff finds that no disproportionately high or adverse impacts would 

be incurred by any minority or low-income population. 

TRAFFIC AND TRANSPORTATION: Impacts to traffic would be similar to the impacts during 

construction and operations. The Phase 2 construction and operations workforces and the 

number of trucks transporting materials to/from the facility on a daily basis would be similar to 
 4-66 

the number during Phase 1 construction and operation. IIFP would ensure that all 

transportation of materials met NRC and DOT regulations. 

Therefore, the NRC staff concludes that impacts to traffic and transportation would be SMALL. 

NOISE: Impacts from noise during decommissioning would be very similar to impacts during 

construction. Therefore, the NRC staff concludes that impacts would be SMALL. 

OCCUPATIONAL AND PUBLIC HEALTH: Impacts to occupational and public health would be 

similar to impacts during construction. Therefore, the NRC staff concludes that impacts would 

be SMALL. 

WASTE MANAGEMENT: The overall strategy for decommissioning would be to remove all 

radioactively contaminated materials, hazardous materials and chemicals from the site. 

Decommissioning programs and procedures would focus on minimizing waste volumes. For 

example, as described in Chapter 10 of the License Application (IIFP, 2009a), IIFP would 

incorporate design features that would result in minimizing the radioactive waste volumes 

including the following: 

• A washable coating on floors and walls in the Restricted Areas, which have the potential 

to become radioactively contaminated during operation would lower waste volumes 

during decontamination and simplify the decontamination process. 

• Sealed, nonporous pipe insulation in areas with higher potential to become 

contaminated would facilitate cleaning in event of a spill and reduce the waste volume 

during decommissioning. 

• Tanks would have access for entry and decontamination. Design provisions would be 

made to allow complete draining of the wastes contained in the tanks. 

• Connections in the process systems would provide access during operation and 

maintenance and to allow for thorough purging at plant shutdown which would remove 

some radioactive contamination prior to disassembly. 

Decommissioning activities would include cleaning to remove radioactive and hazardous 

contamination that could be present on materials, equipment, and structures. Wastes produced 

during decommissioning would be collected, handled, and disposed of in a manner similar to 

that described for the wastes produced during operation. These wastes would consist of 

industrial trash, nonhazardous chemicals and fluids, small amounts of hazardous materials, and 

radioactive wastes. The radioactive waste would consist primarily of piping, tanks, hoppers, and 

compactable trash generated during the dismantling process. 

Solid wastes would be generated by decontamination activities and by the removal of used 

process equipment. Decontaminated used equipment would be shipped offsite to salvage or 

disposal facilities, as appropriate. In the event that structures would be demolished as part of 

the decommissioning activities, the demolition material would be shipped offsite for disposal in 

permitted disposal facilities. Radioactively- contaminated equipment and materials would be 

shipped to a licensed treatment or disposal facility (as appropriate for the material type) or 

disposed of in a manner authorized by the NRC. Similarly, materials constituting hazardous 

wastes would be shipped to a RCRA-permitted treatment and/or disposal facility or an 

appropriate licensed recovery facility. 
 4-67 

A detailed estimate of the wastes produced during decommissioning would be provided in the 

decommissioning plan that would be submitted to the NRC prior to initiating the 

decommissioning of the plant (IIFP, 2009a). Approximately 56,000,000 L (2 million ft3

) of 

commercial LLW were disposed of in the United States in 2008 (NRC, 2010). The estimated 

decommissioning LLW generation from decommissioning represents less than 1 percent of the 

national annual disposal volume. The LLWs from the decommissioning are expected to be 

Class A waste. In its analysis of LLW disposal capacity, the U.S. Government Accountability 

Office concluded that the availability of disposal capacity in the United States for Class A LLW is 

not considered to be a problem for the short or long term (GAO, 2004). The NRC staff 

concludes that the waste management impacts resulting from decommissioning of the IIFP 

facility, decontamination, disposal, and closure activities would be SMALL. 

4.2 Cumulative Impacts 

The CEQ regulations implementing NEPA define cumulative impacts, or effects, as “the impact 

on the environment which results from the action when added to other past, present, and 

reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or 

person undertakes such other actions” (40 CFR 1508.7). In the following analysis, cumulative 

impacts are assessed from the anticipated impacts of the proposed construction, operation, and 

decommissioning of the proposed IIFP facility when added to other identified projects, facilities, 

or activities in the region that have impacts that affect the same resources or human 

populations. Effects from the various sources may be direct or indirect and they may be 

additive or interactive. Such effects are assessed that, when on their own, may be minor, but in 

combination with other effects may produce a cumulative effect that is of greater concern. 

To identify the activities in the region that could contribute to cumulative impacts, NRC staff 

defined an ROI for each resource that is expected to be affected by the proposed IIFP facility. 

An ROI for a particular resource is the size of the surrounding area within which impacts from 

multiple sources may be additive or interactive. The sizes of the ROIs may be different for 

various resources, and some resources may be remote from the proposed site, such as a waste 

disposal facility. Still others might cover large areas, such as a watershed or airshed. 

NUREG-1748 (NRC, 2003) states that the surrounding area of the proposed action can range 

from less than 1.6 km to 80 km (1 mi to 50 mi). Consistent with NUREG-1748, for the proposed 

IIFP facility, an ROI radius of 16 km (10 mi) was identified for the majority of resources. The 

exceptions include socioeconomics, for which an ROI radius of 80 km (50 mi) was identified 

(Section 3.9); and cultural and historic resources and visual resources, for which an ROI radius 

of 10 km (6 mi) was identified (Section 3.3.4). Additionally, in order to assess the potential 

cumulative impacts of radiological transportation, the analysis includes consideration of the 

URENCO USA/LES uranium enrichment facility and the DOE WIPP, both of which are more 

than 16 km (10 mi) from the proposed IIFP facility. 

In order to identify projects or activities in the region that could contribute to cumulative effects, 

the NRC staff conducted Internet searches, reviewed news media (local newspapers and local 

television), and reviewed other relevant NEPA documents (such as the Environmental Impact 

Statement for the Proposed National Enrichment Facility in Lea County, New Mexico 

[NUREG-1790; NRC, 2005a], the Final Complex Transformation Supplemental Programmatic 

Environmental Impact Statement [DOE/EIS-0236-S4; DOE, 2008 ], and the Supplement 

Analysis for the Waste Isolation Pilot Plant Site-Wide Operations [DOE/EIS-0026-SA-07, 

DOE, 2009]). This cumulative impacts analysis included review of existing activities in the 

region that would affect the same resources as the proposed IIFP facility, known past impacts 
 4-68 

on these resources, and reasonably foreseeable proposed new projects, activities, or facilities 

that could impact these resources. Section 4.2.1 discusses these projects or activities. 

4.2.1 Past, Present, and Reasonably Foreseeable Future Actions 

Five other projects or actions are identified and described in this section: 

1. Preconstruction activities on the proposed IIFP site that could occur prior to NRC issuing a 

license for construction, operation, and decommissioning of the proposed IIFP facility. 

2. Construction, operation, and decommissioning of Phase 2 of the IIFP facility. 

3. Construction, operation, and decommissioning of the URENCO USA/LES uranium 

enrichment facility (formerly known as the National Enrichment Facility) in Lea County, New 

Mexico. 

4. Operation of the DOE WIPP near Carlsbad, New Mexico. 

5. Construction and operations related to energy production facilities in the region. 

4.2.1.1 Proposed IIFP Facility Preconstruction Activities 

The preconstruction activities would be preparatory in nature and would not involve any 

radiological process or safety related equipment or systems. Required Federal and State 

permits would be obtained prior to the start of preconstruction, and preoperational baseline 

environmental samples would be collected. Preconstruction activities for the proposed IIFP 

project would include (IIFP, 2011a): 

• Clearing land 

• Site grading and erosion control 

• Installing temporary fencing 

• Installing main entrance roadbed and drainage to highway 

• Installing construction trailer 

• Preparing preliminary site roadways and gravel parking area 

• Drilling water wells 

• Constructing power substation and electric utility lines 

• Stubbing in gas line to the meter 

• Beginning administration building construction 

• Beginning maintenance and stores building construction 

• Beginning warehouse building construction 

• Installing geothermal heating/cooling loops 

• Installing firewater tanks 

• Installing truck washing station 

Based on the characteristics of the proposed IIFP site, major grading would not be required. 

Excavation would be required for sewer systems, roads, pads, and structure foundations. Less 
 4-69 

than 10 percent of the total 259-ha (640-ac) area would be disturbed. The area of clearing 

would include locations of buildings, process structures, storage pads and roads. During this 

pre-licensing, preconstruction phase, conventional earthmoving and grading equipment would 

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

ripping tools. Soil removal work for foundations would be controlled to minimize excavation. In 

addition, loose soil and/or damaged caliche would be removed prior to installation of 

foundations for seismically-designed structures. Temporary silt fencing and sediment straw 

bales would be installed around the areas of construction to entrap silt and to prevent its 

migration off site. Drainage trenches and ditch checks would be installed along the entrance 

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

earth berms, underground drainage pipe, and wet sediment retention basins would be installed 

to entrap storm water run-off from construction areas (IIFP, 2011a). 

The natural gas line feeding the site would be connected to an existing, nearby line. This would 

minimize impacts of short-term disturbances related to the placement of the tie-in line. A new 

electrical distribution line is proposed for providing electrical service to the IIFP facility. There 

are currently 115 and 230 kV transmission lines along US 62/180 and NM 483 and crossing the 

site. IIFP anticipates that the additional line would be erected in an existing right(s)-of-way. In 

conjunction with the new electrical lines serving the site, the local electrical utility company 

would install an independent substation within the 16-ha (40-ac) facility to ensure service 

(IIFP, 2011a). 

The Clean Water Act NPDES requires an NPDES(s) permit for discharges to surface waters, for 

stormwater from construction projects and industrial pollutant discharges. This could include 

construction and operation of a facility such as the proposed IIFP. A Spill Prevention, Control, 

and Countermeasures (SPCC) plan would also be implemented to prevent and, if necessary, 

respond to oil spills. An SPCC plan would be completed and an NPDES Construction 

Stormwater Permit with the General Construction Permit would be obtained by IIFP prior to the 

implementation of preconstruction activities (IIFP, 2011a), if necessary. 

4.2.1.2 Proposed Phase 2 of the IIFP Facility 

The proposed Phase 2 project would add additional deconversion capacity at the facility and a 

process for the direct deconversion of DUF6 to uranium oxide. Phase 2 construction activities 

are proposed to begin in early 2015 and would be completed to support operations by mid-2016 

and require a maximum of 180 additional workers (IIFP, 2011a). 

Prior to the proposed Phase 2 expansion, IIFP would prepare and submit an amended license 

application to the NRC for the Phase 2 facility, including possession of up to 2,200,000 kg 

(4,850,120 lb) of DUF6 (compared to the 750,000 kg [1,653,450 lb] of DUF6 that were requested 

in the Phase 1 application). IIFP plans to submit a license amendment for this plant expansion 

in 2013 (IIFP, 2011a). 

During Phase 2 construction, additions are planned for the DUF6 Autoclave Building, the Oxide 

Process Building, Direct Oxide Staging Building, and the HF Distillation Annex. The entire site 

clearing would occur during preconstruction and Phase 1 construction. No roads would need to 

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

required. Hence, no major earth grading or movement would be necessary, but excavation 

would be required for sewer and building foundations and floors and for tie-ins for water, natural 

gas, and utilities. Excavation for foundations would be minimized. Loose soil and/or damaged 

caliche would be removed prior to installation of foundations for seismically designed structures. 
 4-70 

Approximately 20 percent more building space would be added to the existing Phase 1 facility. 

Considering the total 259-ha (640-ac) area, minimal soil disturbance would occur. Silt fences 

and straw bales would be used to control erosion and to protect undisturbed areas (IIFP, 

2009a). As part of the Phase 2 plant expansion, another major stack would be added for 

venting filtered exhaust gas from the oxide process dust collector system. Phase 2 construction 

would be accomplished with an average construction crew of 150 to 180 workers (IIFP, 2011a). 

Once the Phase 2 facility is operational in mid-2016, all of the fluorides in the DUF6 could be 

directly converted to AHF, and SiF4 and BF3 would not be produced unless warranted by market 

conditions for these products. Despite different internal operations, many aspects of the Phase 

2 operations that would give rise to potential environmental impacts would be very similar to 

those in Phase 1 (IIFP, 2011a). Upon completion of Phase 2, the integrated facility would have 

an overall total deconversion capacity of nearly 800 DUF6 cylinders per year; about 9.8 million 

kg/yr (21.7 million lb/yr) of DUF6. Nearly 2.6 million kg/yr (5.7 million lb/yr) of AHF product is 

projected to be produced and sold (IIFP, 2009a). 

The utilities needed to support the Phase 2 facility would be the same as those for the Phase 1 

facility, although there would be an increase in overall utility usage (especially electricity and 

steam) with the addition of the Phase 2 facility. For example, when the Phase 2 facility 

becomes operational, the total steam load would increase to about 2,722 to 3,629 kg/hr 

(6,000 to 8,000 lb/hr) compared to 1,134 to 1,588 kg/hr (2,500 to 3,500 lb/hr) for Phase 1 

operations (IIFP, 2009a). At the end of its useful life, the IIFP facility would be decommissioned 

consistent with the decommissioning plan that is developed. 

4.2.1.3 URENCO USA/LES Uranium Enrichment Facility 

In December 2003, the LES submitted a license application to the NRC to construct, operate, 

and decommission a facility to produce enriched U-235, up to 5 percent weight, by the gas 

centrifuge process. The enriched uranium would be used as fuel in commercial nuclear power 

plants. The NRC staff issued a Final EIS (NUREG-1790) (NRC, 2005a) and SER 

(NUREG-1827) (NRC, 2005b) for the facility in June 2005. In June 2006, the NRC issued LES 

a 30-year license to construct and operate the facility with a nominal production capacity of 

3 million separative work units (SWUs) per year. On November 21, 2008, LES announced 

plans to expand the facility capacity to 5.7 million SWUs per year (NRC, 2010); although a 

license application for the facility expansion has not yet been submitted to the NRC. 

The URENCO USA/LES Uranium Enrichment facility commenced initial operations on June 11, 

2010. Construction of the project will continue until the plant reaches the planned 5.7 million 

SWU capacity and full operations are expected in 2015 (assuming a license for the additional 

2.7 million SWU is granted by the NRC). The facility is located approximately 32 km (20 mi) 

south of Hobbs, New Mexico, 8 km (5 mi) east of Eunice, and approximately 40 km (25 mi) 

south of the proposed IIFP site. DUF6 is a waste product of the uranium enrichment process, 

and the URENCO USA/LES Uranium Enrichment facility would be one of the likely DUF6

suppliers to the IIFP facility. 

This cumulative impacts analysis is based on information in the Final EIS (NUREG-1790) 

(NRC, 2005a). 
 4-71 

4.2.1.4 DOE Waste Isolation Pilot Plant (WIPP) 

The WIPP facility is the nation’s first underground repository 

permitted to safely and permanently dispose of transuranic 

radioactive waste generated by defense-related activities. 

Waste generated at DOE sites is shipped to the WIPP and 

permanently disposed in an ancient salt formation 655 m 

(2,150 ft) below the surface. Over the planned 35-year 

operational lifetime ending in 2034, the WIPP is expected to 

receive approximately 37,000 shipments of waste from 

locations across the United States (DOE, 2008). The WIPP 

disposal site is 42 km (26 mi) east of Carlsbad, in Eddy County 

in the Chihuahuan Desert of southeastern New Mexico, and 

approximately 87 km (54 mi) from the proposed IIFP facility 

site. 

Waste disposal operations began at the WIPP in March 1999. As of August 2010, the WIPP 

has received 8,812 transuranic waste shipments, totaling more than 16.1 million km (10 million 

mi) of transport on U.S. highways of approximately 69,240 m3

 (90,566 yd3) of transuranic waste. 

Based on the most recent transuranic waste inventory data, DOE estimates that approximately 

140,000 m3

 (182,779 yd3) of transuranic waste either has been disposed of or could be eligible 

for disposal at the WIPP (DOE, 2010). 

4.2.1.5 Regional Energy Production Facilities 

As shown on Figure 3-2 and described in this section, there are four energy production facilities 

in the vicinity of the IIFP facility that could contribute to cumulative impacts: 

1. Xcel Energy Cunningham Station 

2. Xcel Energy Maddox Station 

3. Colorado Energy Station 

4. DCP Midstream Linam Ranch Natural Gas Processing Facility 

The cumulative impacts analysis is based on information in Section 4.1 of this EIS, the 

Environmental Report submitted by IIFP (IIFP, 2009a), Official Responses to the Environmental 

Report Requests for Additional Information (IIFP, 2011a), and the other references identified in 

Section 4.2.2. 

4.2.2 Cumulative Impacts to Environmental Resources 

The potential cumulative impacts are presented for each resource presented in Section 4.1. 

4.2.2.1 Land Use 

As described in Section 3.2, the proposed IIFP facility would be located in a sparsely populated 

area on undeveloped land and near four power and gas industry plants. Present land uses in 

the vicinity include cattle grazing and oil and gas development. The preconstruction, 

construction, and operation of Phase 1 would disturb less than 10 percent of the total 259-ha 

(640-ac) site (IIFP, 2011a). Because approximately 93 percent of Lea County (approximately 

1.0 million ha [2.6 million ac]) is used as range land for grazing, the impacts resulting from 

Transuranic Waste 

Transuranic waste is 

waste that contains alphaemitting radionuclides with 

atomic numbers greater 

than uranium (92) and 

half-lives greater than 

20 years, in 

concentrations greater 

than 100 nanocuries per 

gram of waste. 
 4-72 

restricting the current land use would be negligible due to the abundance of other nearby 

grazing land. There are no zoning restrictions on the property. As described in Section 4.2.1.2, 

during the Phase 2 expansion, no roads would be added and only minor revisions to paved or 

concrete areas may be required. Hence, no major earth grading and land disturbance would 

occur. Therefore, the NRC staff concludes that cumulative impacts on land use from the 

preconstruction of the proposed facility, the proposed action, and Phase 2 construction, 

operation, and decommissioning would be SMALL. 

4.2.2.2 Historic and Cultural Resources 

As described in Section 3.3, an archaeological survey of the site conducted in May 2009 

identified three isolated artifacts and no archaeological sites. A review of the current listings for 

the New Mexico State Register of Cultural Resource Properties and the National Register of 

Historic Places indicate no NRHP-listed or eligible historic properties within 10 km (6 mi) of the 

proposed site and one State-listed property just less than 10 km (6 mi) south of the IIFP site. 

The archaeological consultant recommended no further work based on the survey results. The 

NM SHPO concurred with this determination (Appendix B). Preconstruction activities at the 

proposed IIFP site and Phase 2 expansion, which would occur within the same footprint as the 

proposed action, would have no impact on historic properties, districts, resources or significant 

historic/precontact archaeological sites. Therefore, the NRC staff concludes that cumulative 

impacts on historic and cultural resources from the proposed action, preconstruction of the 

proposed facility, and Phase 2 construction, operation, and decommissioning would be SMALL. 

4.2.2.3 Visual Resources 

As discussed in Section 3.4, the construction of the proposed facility would occur in a sparsely 

populated area with an existing low-quality viewshed. No regionally or locally important high 

quality views occur in the vicinity of the proposed IIFP facility. Consequently, the NRC staff 

concludes that cumulative impacts would be SMALL. 

4.2.2.4 Climatology/Meteorology/Air Quality 

4.2.2.4.1 Greenhouse Gases 

Greenhouse gas emissions from construction vehicles and equipment were taken into account 

in the analysis for Phase 2. During the Phase 2 construction, it was assumed that the workforce 

of 180 would commute 2,900,000 km (1,800,000 mi) over the 1-year construction period (250 

days). Over the course of the construction period, it was also estimated that there would be 20 

deliveries each day each also traveling a distance of 64 km (40 mi). NRC staff used EPA 

MOVES to calculate the resulting CO2 emissions associated with workforce commuting and 

construction deliveries during Phase 2 construction. The total CO2 equivalent emissions, 

expected during the Phase 2 construction period would be 1,303 metric tons (1,435 tons), which 

are substantially less than those expected from the Phase 1 construction period. 

Using calendar year 2000 as a reference point (the latest year for which New Mexico 

greenhouse gas emission data are available), and as shown in Table 3-1, total net CO2

emissions for New Mexico for the year 2000 were 62 million metric tons (68 million tons) of CO2

equivalents. For the United States for that same year, total net CO2 emissions were 

5,977 million metric tons (6,588 million tons) (EPA, 2010a). By comparison, during the Phase 2 

construction phase, CO2 emissions are projected to be 1,303 metric tons (1,435 tons), 

approximately 0.002 percent of the New Mexico statewide output or 0.00002 percent of the 
 4-73 

nationwide emissions for calendar year 2000. Consequently, the NRC staff concludes that 

potential cumulative impacts on greenhouse gas emissions would be SMALL 

4.2.2.4.2 Air Quality 

4.2.2.4.2.1 Air Quality (pre-construction) 

Air quality impacts from the operation of construction equipment and support vehicles during the 

preconstruction stage were evaluated based on the construction schedules and parameters 

provided by IIFP (IIFP, 2011a). The proposed IIFP facility site is 16 ha (40 ac). 

Activities that would take place during preconstruction are described in Section 4.2.1.1. IIFP 

estimates preconstruction would last for a period of approximately three months, and would be 

followed by approximately 12 months of Phase 1 construction (IIFP, 2011b). 

During preconstruction, criteria pollutants (e.g., CO, NO2, PM10, PM2.5, and SO2), HAPs, and 

VOCs would be generated by the operation of construction vehicles and equipment (operating 

at 10 hours a day, 5 days a week), delivery vehicles (estimated at 20 trips a day), and workforce 

transport vehicles (estimated at 140 trips per day) traveling to and from the site. These 

emissions would include (1) fugitive dust emissions from the disturbance of unpaved surfaces, 

(2) combustion emissions from the operation of diesel-fired vehicles and equipment, (3) tailpipe 

emissions from the operation of gasoline and diesel-fired commuter and delivery vehicles, and 

(4) fugitive HAP and VOC emissions due to evaporative losses from diesel fuel tanks and diesel 

fuel transfers. 

The quantities of air pollutants that would be generated from preconstruction activities at the 

IIFP site were estimated using the equipment list and description of planned activities provided 

by IIFP (2011b); and emission factors from the EPA MOVES Model (EPA, 2009a), the EPA 

NONROAD model (EPA, 2005), and EPA AP-42 emission factors (EPA, 1995a). Air quality 

impacts were evaluated using the EPA SCREEN3 (EPA, 1995b) air dispersion model. 

IIFP anticipates that most of the earth moving activities would take place during preconstruction. 

Consequently, fugitive dust emission rates would be greater during preconstruction than during 

the Phase 1 construction period, however, the 3-month preconstruction period is relatively short. 

The estimated pollutant emissions during preconstruction would represent a very small fraction 

of the current emissions in Lea County. 

Dispersion modeling results show that air pollutant concentrations at the IIFP site boundary 

during preconstruction would be similar to the concentrations during Phase 1 construction (See 

Appendix C). The estimated incremental increases in ambient background concentrations due 

to the proposed preconstruction activities would be above the NAAQS for NO2, PM2.5 and PM10

emissions. Pollutant emissions from preconstruction activities potentially could change the 

existing ambient air quality in the vicinity of the proposed IIFP facility temporarily. Because 

conservative assumptions that tend to overestimate impacts were used to produce these 

estimates, actual emissions from the construction activities are expected to be lower. Overall, 

the preconstruction impacts would be localized and short-term. 

Because preconstruction and Phase 1 construction would not occur simultaneously, the impacts 

would not be cumulative. As discussed in Section 3.5.3, Lea County is in attainment for all 

criteria pollutants. The cumulative air impacts of preconstruction and other projects in the 

region of influence are not expected to change this attainment status. Therefore, the NRC staff 
 4-74 

concludes that the air quality impacts resulting from the preconstruction of the proposed IIFP 

facility would be MODERATE for NO2, PM2.5, and PM10 emissions and SMALL for other 

emissions. BMPs during preconstruction and construction as described in Chapter 5, Mitigation 

Measures and Commitments, would reduce impacts to air quality. NRC staff considers the use 

of BMPs to minimize impacts to air quality as an environmental commitment. Furthermore, the 

NRC staff finds that the BMPs committed to by IIFP would be sufficient to ensure that preconstruction impacts of the proposed IIFP facility to air quality would be MODERATE for NO2 

and particulate emissions; and SMALL for other emissions. 

4.2.2.4.2.2 Air Quality (Phase 2 Construction and Operation) 

During Phase 2 construction, the process area would be expanded approximately 28 percent to 

add a 33.5 m x 33.5 m (110 ft x 110 ft) area next to the Phase 1 process buildings. Less than 

1 percent of the 16-ha (40-ac) site area would be disturbed during the Phase 2 construction 

period of approximately 1 year (IIFP, 2011a). 

Pollutant emissions and diesel fuel consumption attributable to Phase 2 construction activities 

were estimated using the equipment list and description of planned activities provided by IIFP 

(2011b); and emission factors from the EPA MOVES Model (EPA, 2009a), the EPA NONROAD 

model (EPA, 2005), and EPA AP-42 emission factors (EPA, 1995a). Air quality impacts were 

evaluated using the EPA SCREEN3 (EPA, 1995b) air dispersion model. 

Heavy earth-moving equipment (e.g. dozers, excavators, and graders) would not be required for 

Phase 2 construction, so annualized Phase 2 emissions would be approximately 25 percent 

less than annualized Phase 1 construction emissions (See Appendix C). The estimated 

pollutant emissions during Phase 2 construction represent a very small fraction of the current 

emissions in Lea County. 

Dispersion modeling results show that air pollutant concentrations at the IIFP site boundary 

during Phase 2 construction would be much lower than the concentrations during Phase 1 

construction (See Appendix C). The estimated incremental increases in ambient background 

concentrations due to the proposed preconstruction activities would be above the NAAQS for 

NO2 emissions over a 1-hr averaging time. All other pollutant concentrations were estimated to 

be below NAAQS. Pollutant emissions from Phase 2 construction activities potentially could 

change temporarily the existing ambient air quality in the vicinity of the IIFP facility with respect 

to NO2. Because conservative assumptions that tend to overestimate impacts were used to 

produce these estimates, actual emissions from the construction activities are expected to be 

lower. Overall, the Phase 2 construction impacts would be localized and short-term. 

Because Phase 2 and Phase 1 construction would not occur simultaneously, the impacts would 

not be cumulative. As discussed in Section 3.5.3, Lea County is in attainment for all criteria 

pollutants. The cumulative air impacts of Phase 2 construction and other projects in the region 

of influence are not expected to change this attainment status. Therefore, the NRC staff finds 

that the air quality impacts resulting from the construction of the IIFP Phase 2 facility would be 

MODERATE for NO2 emissions and SMALL for other air emissions. BMPs used during 

construction would reduce the impact of construction activities on air quality. These BMPs are 

described in Chapter 5, Mitigation Measures and Commitments. The NRC staff finds that the 

BMPs committed to by IIFP for the proposed facility would be sufficient to maintain impacts to 

air quality from Phase 2 construction as MODERATE to SMALL. 
 4-75 

Greenhouse gas emissions from construction vehicles and equipment were taken into account 

in the analysis for Phase 2. During the Phase 2 construction, it was assumed that the workforce 

of 180 would commute 2,900,000 km (1,800,000 mi) over the 1-year construction period (250 

days). Over the course of the construction period, it was also estimated that there would be 20 

deliveries each day each also traveling a distance of 64 km (40 mi). NRC staff used EPA 

MOVES to calculate the resulting CO2 emissions associated with workforce commuting and 

construction deliveries during Phase 2 construction. The total CO2 equivalent emissions, 

expected during the Phase 2 construction period would be 1,303 metric tons (1,435 tons), which 

are substantially less than those expected from the Phase 1 construction period. 

Greenhouse gas emissions from operation of the IIFP facility would be insignificant (less than 

0.1 percent) when compared to the greenhouse gas emissions from the regional energy 

facilities. In 2008, the total CO2 emissions from the Cunningham Station, Maddox Station, 

Colorado Energy Station, and DCP Midstream Linam Ranch Natural Gas Processing Facility 

were more than 1.3 million metric tons (1.43 million tons) (NMED, 2010). 

For Phase 2 operations, criteria pollutant emissions attributable to operations are well below 

Title V and Class II PSD thresholds. IIFP evaluated regional impacts with SCREEN3 based on 

frequency-weighted site-specific meteorological data. Pollutant concentrations at the site 

boundary were determined to be well below the NAAQS (IIFP, 2011a). The cumulative air 

impacts of Phase 2 operations of the IIFP facility and other projects in the region of influence, 

including IIFP Phase 1 operations, are not expected to change the attainment status of Lea 

County. Consequently, the NRC staff concludes that potential cumulative impacts on air quality 

would be SMALL. 

4.2.2.5 Geology, Minerals, and Soil 

Preconstruction would occur within about 16 ha (40 ac) of the 259-ha (640-ac) proposed site 

(IIFP 2009a; IIFP 2011a); and construction, operation, and decommissioning for Phase 2 would 

occur within the previously disturbed 16-ha (40-ac) footprint of the Phase 1 IIFP facility. 

Therefore, these actions would have little or no additional impacts on geology, minerals, 

seismology, and soil beyond those of the proposed action. 

During all preconstruction and Phase 2 construction activities, BMPs would be employed to limit 

soil loss and mitigate these impacts. These would include: 

• Soil stabilization (e.g. temporary and permanent seeding), 

• Structural controls (e.g. hay bales and sediment fences), 

• Drainage trenches and ditch checks would be installed along the entrance road to 

prevent run-off and silt from the site onto NM 483 right-of-way, and 

• Management practices (e.g. construction sequencing, materials delivery sequencing, 

physical delineation of disturbed areas) (IIFP, 2011a). 

Once the Phase 2 facility is constructed, no additional impacts to geology, minerals, seismicity, 

and soil are expected. Thus, the NRC staff concludes that cumulative impacts from 

preconstruction of the proposed IIFP facility, the proposed action, and Phase 2 construction, 

operation, and decommissioning would be SMALL. 
 4-76 

4.2.2.6 Water Resources 

Preconstruction activities are not expected to require any use of on-site of groundwater. During 

the preconstruction period, up to two new wells would be installed, and capped at the wellheads 

for connections to the facility water distribution systems after possible NRC license approval. 

For dust control during preconstruction activities, IIFP would bring in tanker trucks of water from 

the City of Hobbs municipal system. The City of Hobbs groundwater allocation is included as 

part of Lea County’s 40-Year Water Development Plan and preconstruction activities would not 

result in cumulative impacts to groundwater use. Site sloping, earth berms, underground 

drainage pipe, and wet sediment retention basins would be installed to entrap storm water runoff from construction areas. As discussed in Section 3.7.2, no permanent surface water or 

jurisdictional waters are present on the proposed IIFP site and, therefore, there would not be 

any cumulative impacts to surface water. 

Approximately 3.79 m3

/day (1,000 gal/day) of groundwater would be required during Phase 2 

construction, mainly for dust suppression control, fill compaction, and concrete formation. 

Average and peak site water requirements for Phase 2 operations are expected to be 

approximately 11.36 m3

/day (3,000 gal/day) and 37.85 m3/day (10,000 gal/day), respectively. 

Phase 2 facility operation would require relatively low volumes of water because it would recycle 

process water and re-circulate cooling water. Groundwater use during operation is projected to 

be less than 37,854 L (10,000 gal) per day (IIFP, 2011a), and would be below the water 

allotment set aside by Lea County. Therefore, the NRC staff concludes that cumulative impacts 

to groundwater use from preconstruction of the proposed IIFP facility, the proposed action and 

Phase 2 construction and operation would be SMALL. 

As summarized in Section 3.13.5, there are four energy production facilities in the vicinity of the 

proposed IIFP facility. Each of these facilities uses groundwater from the Ogallala aquifer, as 

would the proposed action. The Xcel Energy Cunningham Station, which is adjacent to the IIFP 

site, is a zero discharge plant, meaning no process waters are discharged from the plant site. 

The cooling water from the Cunningham Station is reused to irrigate pecan orchards. The 

groundwater rights and use for the four facilities were allocated prior to the development of the 

Lea County 40-Year Water Development Plan and, thus, are not reliant on Lea County’s 

assigned unappropriated 4,215.2 ha-m (34,173 ac-ft) per year of water rights. In 2005, the four 

energy plants were factored into the Lea County annual groundwater withdrawals of 2,293,700 

ha-m/yr (185,952 ac-ft/yr) (McCoy and Perry, 2004). The Lea County 40-Year Water 

Development Plan includes an assessment of groundwater use impacts from existing and future 

beneficial uses of groundwater. 

The National Enrichment Facility operations are expected to use on an average approximately 

87,600 million m3

 (23.1 million gal) of water annually. For the life of the facility, the National 

Enrichment Facility could use up to 263,000 m3

 (695 million gal) of the Ogallala waters, 

encompassing both construction and operations use. This constitutes a small portion, 0.004 

percent, of the 60 billion m3

 (49 million ac-ft or 16 trillion gal) of Ogallala reserves in the State of 

New Mexico territory. Water use during decontamination and decommissioning would be less 

than or equal to the water consumption during operations (NRC 2005a). 

As discussed in Section 4.1.2.6, Lea County has allocated up to 175 ac-ft/yr of water rights to 

the proposed IIFP site in their 40-year plan, which takes into account existing groundwater 

users. As discussed above, the IIFP site’s groundwater use would be much less than this 

allotment. In accordance with regulations of the New Mexico Office of the State Engineer for 
 4-77 

wells installed in a non-Critical Management Area, the two site wells are not expected to create 

drawdowns that exceed the limit of 2.4 m (8 ft) over 40 years, or 0.06 m/yr (0.20 ft/yr). 

Therefore, the NRC staff concludes that the cumulative groundwater use impact related to the 

Lea County unappropriated water rights from the operation of the four existing energy 

production facilities, the National Enrichment Facility, and the activities associated with the 

proposed IIFP facility would be SMALL. 

With respect to groundwater quality, the Xcel Energy Cunningham Station, which is the closest 

energy facility to the proposed IIFP Facility, operated with an unlined cooling tower and boiler 

cleanout pond for a number of years. The pond has recently been lined. Xcel Energy 

monitoring wells along the western boundary of the proposed IIFP site were installed to monitor 

contaminants in groundwater that potentially originated from cooling water pond and/or 

agricultural fields. Data since 2004 from these monitoring wells indicate that concentrations of 

sulfate, chloride, and total dissolved solids have exceeded New Mexico Water Quality Control 

Commission Standards for Groundwater (IIFP, 2011a). 

During preconstruction, operations, and decommissioning of the proposed IIFP facility, control 

of surface water runoff would be required by the NPDES permit. As a result, no impacts are 

expected to surface or groundwater bodies. Stormwater and effluent sampling would be 

conducted as required by the NPDES permit to protect surface water quality. In addition, sitewide groundwater levels would continue to be monitored routinely, and samples from the 

groundwater monitoring-well and pumping-well networks would continue to be analyzed to 

confirm that cumulative impacts to groundwater quality would be SMALL (IIFP, 2011a). 

Therefore, the NRC staff finds that groundwater quality impacts would be SMALL. 

4.2.2.7 Ecological Resources 

Most of the impacts to ecological resources would occur during the preconstruction activities. 

Land clearing would occur within the 16 ha (40 ac) facility area and would destroy the Western 

Great Plains Shortgrass Prairie and Apacherian-Chihuahuan Mesquite Upland Scrub vegetation 

communities. The amount of vegetation cleared would be limited, to the extent practicable, to 

the land area needed for the proposed IIFP facility’s operational, security, and utility 

requirements (IIFP, 2011a). However, neither of these vegetation communities provides unique 

habitat in the area. The existing natural habitats on the proposed IIFP site and the region 

surrounding the proposed site have been previously impacted by domestic livestock grazing, 

wildfires, oil/gas pipeline rights-of-way and access roads (IIFP, 2011a). The total area to be 

disturbed for the facility (16 ha [40 ac]) represents less than one-tenth of the total site area. 

Therefore, the NRC staff finds that the loss of 16 ha (40 ac) of either habitat type, for both direct 

and onsite cumulative impacts, would have a SMALL impact on native vegetation in the vicinity 

of proposed action. 

During preconstruction, an access roadway off of northbound NM 483 would be built to support 

construction and delivery of materials to the site during construction. Roadway preconstruction 

activities would have a SMALL effect on ecological resources, due to the limited amount of area 

involved. 

Noise, dust, and air emissions associated with site clearing would be short-lived and represent 

only a temporary adverse impact to the biota of the IIFP site (IIFP, 2011a). Removal of the 

vegetation and the soil disturbance that would occur during preconstruction activities would 

likely destroy nesting substrates for many of the potential breeding bird species found in this 

area (see Table 3-17). However, the impacts are not likely to have population-level impacts to 
 4-78 

the affected species (SORA, 2011). NMGF has suggested a minimization measure, for 

preconstruction to take place outside of the nesting season of migratory birds, which, if 

instituted, would impact few nesting activities in the affected habitat. Accordingly, 

preconstruction site clearing activities would have a SMALL effect on ecological resources. 

Construction of Phase 2, which will occur on recently disturbed land adjacent to the Phase 1 

facility, would not affect ecological resources. Accordingly, Phase 2 construction would have a 

SMALL effect on ecological resources. 

Therefore, the NRC staff concludes that cumulative impacts to ecological resources would be 

SMALL. 

4.2.2.8 Socioeconomic Resources 

Preconstruction activities are assumed to begin in 2011 and to conclude prior to the end of 

2011. Initially 35 and later as many as 70 workers would be involved in preconstruction 

activities. During preconstruction, the work force would consist of heavy equipment operators 

and structural crafts, most of which are expected to come from the ROI. Preconstruction 

activities are expected to result in impacts that would be approximately one-fourth to one-half 

the impacts presented in Section 4.1.8 for Phase 1 construction. As such, the NRC staff finds 

that there would be a correspondingly SMALL impact on housing, taxes, infrastructure and 

community services (IIFP, 2011a). 

Phase 2 would use a construction crew of 150 to 180 workers. IIFP estimates approximately 

27 workers of the construction work force are expected to move into the vicinity as new 

residents (15 percent of 180 workers). The increases in area population during Phase 2 

construction, therefore, would be approximately the same as Phase 1 construction and the NRC 

staff finds that those increases would have SMALL impacts to socioeconomic resources. 

The Phase 2 operations of the IIFP facility would require a maximum of 40 additional workers 

(IIFP, 2009). Using the same assumptions for the Phase 1 operations workforce, the NRC staff 

assumed that 32 workers would already reside in the area, and that 8 would in-migrate. Given 

the excess housing, public utilities and capacity in local schools, as described in Section 3.9, the 

NRC staff concludes that socioeconomic impacts from Phase 2 operations would be SMALL. 

No disproportionately high or adverse impacts would occur to environmental justice populations 

in the ROI. The NRC staff finds that the cumulative impacts of preconstruction, the proposed 

action and Phase 2 construction and operation on socioeconomic resources would be SMALL. 

The URENCO USA/LES Uranium Enrichment facility is expected to employ a maximum of 

210 people annually and would indirectly create an additional 173 jobs (NRC, 2005a). 

Overall, the NRC staff concludes that the cumulative impacts from the proposed IIFP project 

and the UNENCO facility Phase 2 construction and operation are expected to be SMALL.

4.2.2.9 Traffic and Transportation 

The peak preconstruction workforce is estimated to be 70 employees (INIS, 2011). The 

construction work force would predominantly use NM 483 and US 62/180 to access the IIFP 

site. The existing AADT of both of these roadways is within the general capacity of 

3,400 personal cars per hour for two-lane highways. There would be an increase of a maximum 
 4-79 

Latent Cancer Fatality (LCF) 

A latent cancer fatality (LCF) is a 

fatality associated with acute or 

chronic environmental exposures to 

chemicals or radiation. The fatality 

may occur many years after the 

exposure. 

of 140 trips per day, two trips per potential employee, 

plus up to 40 additional trips associated with 

preconstruction equipment or supply deliveries (IIFP, 

2009a). During preconstruction, the roadways would 

still operate well within their capacity. There would be 

no radiological transportation during preconstruction. 

The NRC staff finds that the impacts from increased 

traffic during preconstruction would be SMALL and 

temporary; therefore, the NRC staff concludes that no 

cumulative impacts would occur. 

An average construction crew of 150 to 180 workers would be required during the approximately 

15-month Phase 2 construction period. Once operational, the workforce at the IIFP facility 

would increase from approximately 120-138 for Phase 1 operations to 145-160 for Phase 2 

operations. If all the construction traffic used the access road off NM 483 this would result in a 

75 percent increase during Phase 2 construction (including construction and operations traffic). 

The vast majority of this increase is expected to be on the 2.4 km (1.5 mi) section between the 

access road and US 62/180. Compared with the traffic count for the various highways from 

2006 through 2008 and the transportation commuting statistics in Lea County from the 2000 

census data, the impact of this temporary increase in traffic during Phase 2 construction is 

considered to be MODERATE for the peak construction period on NM 483. During construction 

of Phase 2 mitigation could include staggering the construction and operations shifts, 

encouraging carpooling or providing vans to transport construction workers from remote 

locations. Mitigation would reduce the impacts from MODERATE to SMALL. 

After Phase 2 is operational, there would be a maximum of 40 additional round trips per day due 

to operation workers, resulting in an additional 80 vehicles on the area highways per day which 

would not exceed the design capacity of the roadways. The NRC staff finds that operational 

traffic would have a SMALL impact on the local transportation pattern. 

During Phase 2 operations, the number of radiological shipments (including DUO2 and LLW) per 

year would increase from 145 -155 shipments of DUO2 (IIFP, 2011b) during Phase 1 with a total 

of approximately 700 radiological shipments (IIFP, 2011b) total, to 450-500 shipments of DUO2

(IIFP, 2011b) during Phase 2 with a total of approximately 2,150 radiological shipments (IIFP, 

2011b). The number of non-radiological shipments is not expected to change from 1,950 

shipments. Therefore during Phase 2 operations, a total of 4,100 shipments are estimated 

annually or approximately 16 round trips per day. Compared with the transportation commuting 

statistics in Lea County from the 2000 census data and the AADT on the specific highways, the 

NRC staff finds that this increase in traffic from operational deliveries and waste removal would 

be SMALL for Phase 2 operations. One mitigation measure to be considered by IIFP is to 

schedule operations worker shift changes and truck shipments for off-peak traffic periods, when 

practical. 

The URENCO USA/LES Uranium Enrichment facility truck shipments of feed, product, and 

waste materials (including DUF6) could result in 2 LCFs to the general population over the life of 

the facility due to vehicle emissions and fewer than 0.03 LCF due to direct radiation. All rail 

shipments of feed, product, waste materials, and empty cylinders were estimated to result in 

fewer than 0.08 LCF to the general population over the life of the facility, and 0.1 LCF from 

direct radiation (NRC, 2005a). 
 4-80 

Some adverse transportation impacts are expected as a result of moving the transuranic wastes 

from sites across the country to the WIPP. One of the official WIPP routes is US 62/180, which 

runs along the southern boundary of the proposed IIFP facility site. DOE estimated that the 

non-radiological impacts of transportation related to WIPP operations would result in 

approximately one traffic fatality and less than one death from pollution health effects. 

Radiological impacts associated with WIPP-related accident-free transportation are expected to 

be much less than 1 LCF (DOE, 2009). 

The radiological impacts associated with combined Phase 1 and Phase 2 operations would 

result in a total population dose of 1.7 person-Sv (170 person-rem) annually. Statistically, this 

dose could result in 0.10 LCFs annually. When combined with the radiological transportation 

impacts from operation of the LES (0.1 LCFs over the facility life) and radiological transportation 

impacts from the WIPP (less than 1 LCF annually), the NRC staff finds that the cumulative 

radiological impacts from transportation would be SMALL (less than 1 LCF annually) 

(IIFP, 2009a). 

4.2.2.10 Noise 

As discussed in Section 3.11.2, there are no noise sensitive receptors in close proximity to the 

proposed IIFP facility. The nearest commercial facility is the Xcel Energy Cunningham 

Generating Station, approximately 1.6 km (1 mi) west of the proposed site. The nearest 

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

facilities areas within 8.0 km (5.0 mi) of the proposed site. Because of the absence of any 

sensitive noise receptors, no noise impacts are anticipated during preconstruction activities and 

Phase 2 construction activities and no cumulative impacts would occur. 

Cumulative impacts from all site noise sources would remain at or below HUD guidelines of 

65 dBA Ldn (24 CFR 51), and the EPA guidelines of 55 dBA Ldn, (EPA, 1974) at the site 

boundary during IIFP facility construction and operation. Therefore, the NRC staff concludes 

that the cumulative noise of all site construction and operation activities, even when considered 

in conjunction with surrounding regional energy production facilities would have a SMALL 

impact and to only those receptors closest to the site boundary. 

4.2.2.11 Public and Occupational Health 

The preconstruction activities have the potential to cause industrial accidents, material-handling 

accidents, falls, etc., that could result in temporary injuries, long-term injuries and/or disabilities, 

and even fatalities. The proposed activities are not anticipated to be any more hazardous than 

the construction activities discussed in Section 4.1.1.11. The preconstruction workforce would 

be smaller than the construction workforce and the duration of preconstruction would be less 

than that of construction. Less than six nonfatal injuries and no fatalities (less than one fatality) 

are expected during preconstruction activities. Therefore, the NRC staff concludes that 

preconstruction health and safety impacts would be SMALL. 

The Phase 2 construction activities have the potential to cause industrial accidents, materialhandling accidents, falls, etc., that could result in temporary injuries, long-term injuries and/or 

disabilities, and even fatalities. The proposed activities are not anticipated to be any more 

hazardous than the construction activities discussed in Section 4.1.1.11. The Phase 2 

construction workforce would be slightly larger than the Phase 1 construction workforce, and 

less than 13 nonfatal injuries and no fatalities (less than 1 fatality) are expected during Phase 2 

construction activities. 
 4-81 

Once operational, the workforce at the IIFP facility would increase from 140 for Phase 1 

operations to 180 for Phase 1 and Phase 2 operations. Statistically, this would increase the 

potential number of both nonfatal and fatal occupational injuries by approximately 10 - 

15 percent. Overall, less than seven nonfatal injuries and no fatalities (less than 1 fatality) are 

expected annually during the proposed operation of Phase 1 and Phase 2. 

The NRC staff finds that radiological impacts associated with operation of the Phase 2 facility 

would be SMALL. The differential in the total population dose between the integrated Phase 1 

and Phase 2 operations and Phase 1 operations alone would be an increase of 2.33 ×10-4 

person-Sv/yr (2.33 ×10-2 person-rem/year). The differential in the dose to the MEI would be 

1.62 ×10-8 person-Sv/yr (1.62 ×10-6 rem/yr). The differential between the two operational 

phases for the dose to the nearest resident would be 1.18 ×10-8 Sv/yr (1.18 ×10-6 rem/year) 

(IIFP, 2011a). The difference, therefore, between operational phases is very low. 

The types of postulated accidents and release scenarios for the Phase 2 facility would not differ 

from those already addressed in Phase 1 operations because Phase 2 operations only add 

inventory and capacity; no new types of chemical or radiological risks would be added. As 

such, the types of accidents and the description of postulated accidents for the Phase 1 facility 

would be representative of the range of credible accidents associated with the Phase 2 facility. 

Therefore, the NRC staff concludes that the cumulative impacts to occupational and public 

health from preconstruction, the proposed action, and Phase 2 construction and operations 

would be SMALL. 

4.2.2.12 Waste Management 

As discussed in Section 4.1.1.12, the NRC staff finds that the quantities of wastes generated 

during construction of the proposed IIFP facility would result in SMALL impacts that could be 

managed effectively. Approximately 300-500 kg (650-1,100 lbs) of solid waste and 270–820 kg 

(600-1,800 lbs) of hazardous waste would be generated (INIS, 2011). Preconstruction activities 

are expected to generate waste types similar to and with volumes less than those estimated for 

construction (IIFP, 2011a). No radiological wastes would be generated during preconstruction. 

As a point of comparison, the operation of the National Enrichment Facility would generate 

approximately 172,500 kg (380,400 lbs) of solid nonradioactive waste annually, including 

approximately 1,900 L (500 gal) of hazardous liquid wastes (NRC, 2005a). Approximately 

87,000 kg (191,800 lbs) of radiological and mixed waste would be generated annually, of which 

approximately 50 kg (110 lbs) would be mixed waste. When added to the wastes from other 

waste generators, such as the National Enrichment Facility, the NRC staff finds that the impacts 

and cumulative impacts of disposal of hazardous and solid (nonhazardous) wastes from 

preconstruction activities of the proposed IIFP facility would be SMALL. 

Phase 2 construction would necessitate connections to existing Phase 1 facilities and 

installation of additional autoclaves (IIFP, 2011b). Radiological materials would not be used in 

the construction of the Phase 2 facility. However, Phase 2 construction involving connections to 

Phase 1 facilities could result in generation of radioactive wastes. The construction waste types 

and volumes would be similar to those during Phase 1 construction. Tables 4-38 through 4-40 

provide the estimated annual quantities of solid, hazardous, and radioactive wastes generated 

during Phase 2 construction. 
 4-82 

Table 4-38. Phase 2 Construction Solid Waste Generation 

Waste Type Estimated Annual Amount 

Air filters(vehicle) 23 – 45 kg 

(50 – 100 lbs) 

Cardboard / packing 136 – 227kg 

(300 – 500 lbs) 

Fiber drums 136 – 318 kg 

(300 – 700 lbs) 

Total 

295 – 590 kg 

(650 – 1,300 lbs) 

Source: IIFP, 2011a 

Table 4-39. Phase 2 Construction Hazardous Waste Generation 

Waste Type Estimated Annual Amount 

Adhesives, resins, caulking residues 54 – 109 kg 

(120 – 240 lbs) 

Lead (batteries) 45 –113 kg 

(100 – 250 lbs) 

Oil filters 45 – 91 kg 

(100 – 200 lbs) 

Paints, thinners, solvents, organic residues 45 – 227 kg 

(100 – 500 lbs) 

Pesticides 45 – 68 kg 

(100 – 150 lbs) 

Petroleum products, oils, lubricants residues 45 – 227 kg 

(100 – 500 lbs) 

Total 281 – 835 kg 

(620 – 1,840 lbs) 

Source: IIFP, 2011a 

Table 4-40. Phase 2 Construction Radioactive Waste Generation 

Material Estimated Annual Amount 

Scrap metal 1,800 – 2,700 kg 

(4,000 – 6,000 lbs) 

Spent blasting sand 45 kg 

(100 lbs) 

Wood trash (pallets) 450 – 680 kg 

(1,000 – 1,500 lbs) 

Total 2,300 – 3,400 kg 

(5,100 – 7,600 lbs) 

Source: IIFP, 2011a. 

As described in Section 4.1.1.12, all construction wastes would be transferred offsite to licensed 

waste disposal facilities with adequate disposal capacity for the estimated volumes. Thus, it is 

also anticipated by NRC staff that the waste management impacts from Phase 2 construction 

would be SMALL. 

The URENCO USA/LES Uranium Enrichment facility commenced initial operations on June 11, 

2010 and full operations are expected in 2015. Projected waste volumes from the enrichment 

facility operations include 173,000 kg/yr (380,400 lb/yr) of solid waste; 1,890 kg/yr (4,165 lb/yr) 

of hazardous and mixed waste; and 87,000 kg/yr (191,800 lb/yr) of LLW (NRC, 2005b). DUF6 is 

a waste product of the uranium enrichment process, and the URENCO USA/LES Uranium 
 4-83 

Enrichment facility would be one of the likely DUF6 suppliers to the proposed IIFP facility. The 

enrichment facility will produce depleted uranium at a rate of 627 cylinders or 7,800 metric 

tons/yr (NRC, 2005b). During Phase 1, the proposed IIFP facility would process 266 cylinders 

annually of DUF6 as feed to the deconversion process. 

Solid waste from the enrichment facility would be disposed of at the Lea County Landfill along 

with waste from the proposed IIFP facility. The solid waste generated by the enrichment facility 

would potentially increase the volume of wastes received at the landfill by less than 0.03 percent 

(NRC, 2005b). That increase in combination with the highest IIFP annual solid waste 

generation rate (during Phase 1 and Phase 2 operations) would result in less than 0.1 percent 

change in the waste received by the Lea County Landfill. Hazardous waste generated by the 

enrichment facility (less than 1, 814 kg [2 tons] per year) and the proposed IIFP facility (up to 

154 tons/yr during Phase 1 operations) represents less than 0.02 percent of the hazardous 

waste managed in the state of New Mexico (more than 1 million tons in 2009). The NRC staff 

finds that the combined impacts of managing the solid and hazardous wastes generated by both 

facilities on the available capacity would be SMALL. 

In the final EIS for the URENCO USA/LES Uranium Enrichment facility (NUREG-1790; NRC, 

2005a), NRC staff considered the impacts of conversion of the DUF6 from the enrichment 

process (up to 15,727 cylinders over the operating life) to depleted U3O8 and disposal of the 

resulting Class A LLW in a licensed disposal facility. The NRC staff concluded that both the 

environmental impacts of shallow land disposal such as the EnergySolutions site in Clive, Utah, 

and the effect on national disposal capacity for Class A LLW would be SMALL. The 

deconversion of DUF6 by the proposed IIFP facility and disposal of the resulting DUO2 as Class 

A LLW represents a subset of the impacts previously considered in NUREG-1790 (NRC, 2005a) 

(the oxide form of the converted depleted uranium waste, whether U3O8 or UO2, would not 

materially change the consequences). Therefore, the NRC staff concludes that the cumulative 

effects of the management of depleted uranium wastes from the proposed IIFP facility and the 

URENCO USA/LES Uranium Enrichment facility would be SMALL. 

The wastes from Phase 2 construction would generate much less than 1 percent of the annual 

wastes from the National Enrichment Facility (172,500 kg [380,400 lbs] of solid nonradioactive 

waste and approximately 87,000 kg [191,800 lbs] of radiological and mixed waste). Based on 

available capacities at hazardous, solid, and radioactive waste treatment and disposal sites, and 

the expectation that there would be no large developments in the Hobbs area that would cause 

a significant increase in municipal waste disposal volume, the NRC staff finds that the 

cumulative impacts from hazardous, solid, and radioactive waste generation would be SMALL. 

As described in Section 4.1.2.12, the NRC staff finds that the impact of disposal of hazardous, 

solid, and radioactive wastes from operation of the proposed Phase 1 IIFP facility at the 

appropriate offsite facilities would be SMALL. Phase 2 operations would generate waste types 

similar to those during Phase 1 operations. The hazardous waste volumes are expected to be 

lower and LLW volumes higher than from the Phase 1 facility. 

The cumulative LLW generation rate during combined Phase 1 and 2 operations would be about 

three times higher than from Phase 1 alone. Most of that increase would result from tripling the 

production of DUO2. The generation rate of other LLW streams (e.g., trash, waste drums and 

pallets) would also increase with the expanded Phase 2 facility. Tables 4-41 through 4-43 

provide the estimated annual waste quantities generated during combined Phase 1 and 2 

operations, for solid, hazardous, and radioactive wastes, respectively. 
 4-84 

The cumulative solid waste generation (up to 49,900 kg [55 tons] per year) would be 20 percent 

greater than during Phase 1 operations. Cumulative Phase 1 and 2 operations would result in 

an increase of approximately 0.07 percent in the waste that the Lea County landfill receives 

annually from all other sources. The NRC staff finds that this quantity of nonhazardous waste 

material would result in SMALL impacts that could be managed effectively. 

The quantity of cumulative hazardous waste could be as much as 46,300 kg (51 tons) per year 

if a market for the CaF2 cannot be identified during Phase 2 operations. Because of the added 

process technology used in the expansion to the Phase 2 facility, when Phase 2 becomes 

operational, a large part of the fluoride-bearing spent scrubber liquids (the HF liquor portion) 

from the plant KOH scrubbing system can be recycled to the add-on direct oxide deconversion 

process and recovered rather than be treated with lime to generate CaF2, thus reducing the 

amount of hazardous waste produced compared to Phase 1 operations. As discussed in 

Section 4.1.1.12, hazardous waste generators in New Mexico accounted for 978,554,778 kg 

(1,078,672 tons) of hazardous waste in 2009 (EPA, 2010b). The maximum cumulative 

generation rate would result in an increase of less than 0.005 percent in the hazardous waste 

generated in the State of New Mexico. 

DUO2 and other radiological waste would be shipped offsite to licensed disposal facilities. As 

shown in Table 4-43, up to 9,168,009 kg (10,106 tons) per year of LLW could be sent for 

disposal each year. Most of the estimated annual LLW generation (approximately 99 percent) 

would be the DUO2 produced by the deconversion process. Assuming 450 kg (1,000 lbs) per 

oxide drum, Phase 1 and 2 operations would result in 8,700 to 20,000 drums of material being 

sent for disposal. This uranium oxide waste volume represents 3.1 percent to 7.2 percent of the 

annual commercial waste volume currently received at the EnergySolutions facility in Clive, 

Utah (NRC, 2010). The Clive facility accepts the majority of the United States’ Class A waste 

and is estimated to have capacity to accept this waste at current volume levels for more than 20 

years (GAO, 2004). The NRC staff finds that the estimated generation of depleted uranium 

oxide and other LLW from the Phase 2 deconversion process would result in SMALL impacts to 

LLW disposal capacity. 

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

Material Estimated Annual Amount 

Clothing 68 – 136 kg 

(150 – 300 lbs) 

Molecular sieve 136 – 227 kg 

(300– 500 lbs) 

Municipal trash waste 32,659 – 48,988 kg 

(72,000 – 108,000 lbs) 

Safety gear 181 – 363 kg 

(400 – 800 lbs) 

Waste Glass 34 – 136 kg 

(75 – 300 lbs) 

Total 33,078 – 49,850 kg 

(72,925 – 109,900 lbs) 

Source: IIFP, 2011a 
 4-85 

Table 4-42. Cumulative Hazardous Waste Generation -– Phase 1 and 2 IIFP Facility 

Material Estimated Annual Amount 

Aerosol cans, paints cans, bulbs 907 – 1,814 kg 

(2,000 – 4,000 lbs) 

Calcium fluoride* 27,216 – 40,823 kg 

(60,000 – 90,000 lbs) 

Lab chemicals 91 – 182 kg 

(200 – 400 lbs) 

Oil sorb 1,361 – 3,175 kg 

(3,000 – 7,000 lbs) 

Total* 29,574 – 45,994 kg 

(65,200 – 101,400 lbs) 

Source: IIFP, 2011a 

*Includes calcium fluoride which would not be waste if sold. 

Table 4-43. Cumulative Radioactive Waste Generation – Phase 1 and 2 IIFP Facility 

Material Estimated Annual Amount 

Activated alumina 907 – 1,814 kg 

(2,000 – 4,000 lbs) 

Air ventilation filters 29 – 45 kg 

(65 – 100 lbs) 

Carbon 11,340 – 13,608 kg 

(25,000 – 30,000 lbs) 

DUF4 clinkers 2,268 – 4,536 kg 

(5,000 – 10,000 lbs) 

Coke 3,629 – 5,443 kg 

(8,000 – 12,000 lbs) 

Crushed drums 907 – 3,629 kg 

(2,000 – 8,000 lbs) 

Dust collector bags 454 – 1,361 kg 

(1,000 – 3,000 lbs) 

Ion exchange resin 907 – 1,814 kg 

(2,000 – 4,000 lbs) 

Oxide for burial (plus drums) 3,946,258 – 9,071,858 kg 

(8,700,000 – 20,000,000 lbs) 

Radioactive waste trash 31,752 – 45,359 kg 

(70,000 – 100,000 lbs) 

Scrap metal 5,443 – 7,257 kg 

(12,000 – 16,000 lbs) 

Sintered metal tubes 907 – 1,361 kg 

(2,000 – 3,000 lbs) 

Sodium fluoride 907 – 1,814 kg 

(2,000 – 4,000 lbs) 

Spent blasting sand 45 – 91 kg 

(100 – 200 lbs) 

Wood trash (pallets) 1,361 – 5,443 kg 

(3,000 – 12,000 lbs) 

Total 4,007,115 – 9,167,702 kg 

(8,834,165 – 20,211,300 lbs) 

Source: IIFP, 2011a 
 4-86 

The wastes generated during cumulative Phase 1 and 2 operations would be transferred offsite 

to licensed waste facilities with adequate disposal capacity for the estimated volumes. Thus, 

the NRC staff anticipates that the waste management impacts from cumulative operations 

would be SMALL. 

4.3 No-Action Alternative 

As presented in Section 2.2 of this EIS, the no-action alternative would be to not construct, 

operate, and decommission the proposed IIFP facility in Lea County, near Hobbs, New Mexico. 

As discussed in Section 2.1, IIFP expects to carry out preconstruction activities (i.e., site 

preparation and non-safety related construction activities) prior to issuance of a license by NRC. 

If NRC does not ultimately grant IIFP a license for the proposed plant, these would be activities 

associated with the no-action alternative. 

Preconstruction would be overseen by the NMED and Lea County, pursuant to applicable 

permit requirements. NMED state permits would include those listed in Section 1.4, including 

stormwater controls, and erosion and sedimentation controls. A New Mexico Department of 

Transportation right-of-way permit would be required in order to construct access to NM 483. 

Lea County ordinances would require adherence to applicable building codes and fire code 

standards. There could be additional activities at the proposed site in the future under the noaction alternative that could have (adverse or beneficial) impacts on the environment and 

community. The impacts associated with these activities would depend on what IIFP would 

decide to do with the proposed site or the improvements (e.g., access roads, buildings, etc.) 

already constructed on the site, should the license not be granted. The conclusions presented 

in this section for the no-action alternative address the impacts of denying the license, but do 

not include the impacts of the NRC-approved preconstruction activities, which have been 

discussed in Section 4.2.2, Cumulative Impacts. 

Under the no-action alternative, as discussed in Section 2.2.1, commercial uranium enrichment 

facilities would continue to store depleted uranium. DOE, which operated three gaseous 

diffusion plants near Oak Ridge, Tennessee, Piketon, Ohio, and Paducah, Kentucky, as part of 

the process of enriching uranium for civilian and defense applications, and would continue to 

deconvert its stockpiles of DUF6. In the future, DOE deconversion technology and recently 

constructed deconversion plants at Paducah and Piketon would become available to deconvert 

commercial DUF6. However, this would only occur when all of the DOE’s DUF6 stockpiles at 

Oak Ridge, Portsmouth, and Paducah are deconverted which is projected to take 25 years. 

Therefore, the no-action alternative would involve long term storage of depleted uranium at 

commercial enrichment facilities until such time as DOE could accept DUF6 from facilities other 

than its own. 

As discussed in Section 2.2.2, other alternatives, including Alternative Sites, Alternative 

Technologies, Overseas Shipment, Indefinite Storage, or deconversion at the commercial 

enrichment plants, have been dismissed for various reasons, and it is, therefore, assumed that 

none of those alternatives would occur. The environmental impacts of deconversion 

alternatives involving other sites and technologies would have impacts similar to or greater than 

the impacts from the Proposed Action. Alternatives involving overseas shipment would involve 

unreasonable shipment costs, increased potential for adverse transportation-related impacts, 

and potentially unacceptable risks. Indefinite storage is not practical or reasonable compared to 

the benefits of added commercial fluoride product and increased safety afforded by the 

deconversion process. Deconversion onsite at commercial uranium enrichment facilities is not 
 4-87 

feasible, considering technological and marketing advantages of using existing DOE facilities 

and/or the proposed IIFP facility. Therefore, the no-action alternative is limited to the Proposed 

Action, and its affiliated positive or adverse effects, not occurring. 

The no-action alternative assumes that preconstruction occurred within the 16-ha (40-ac) facility 

and that fencing was erected around the 259-ha (640-ac) proposed IIFP site. Impacts from the 

no-action alternative to affected resources are as follows: 

LAND USE: If the fencing was not removed, it would restrict cattle grazing. Other land uses in 

the vicinity of the site would be unaffected. A Site Redress Plan (SRP) could be required by 

NRC. The SRP could require the site to be restored to original grade and condition, including 

removal of fencing. The NRC staff finds that impacts to local land use would be SMALL, 

because of the amount of land adversely affected compared to the large amount of land 

available in the vicinity. 

HISTORIC AND CULTURAL RESOURCES: For the same reasons as described for the 

proposed action, the NRC staff finds that impacts to historic and cultural resources would be 

SMALL and would result in no effect on historic properties, districts, resources or significant 

historic/precontact archaeological sites. 

VISUAL RESOURCES: The existing character of the area would be altered only within the 

preconstruction area perimeter and access road. This disturbance would be limited to less than 

ten percent of the Section 27 (IIFP) site, and the NRC could require that all structures be 

removed. Therefore, the NRC staff finds that impacts would be SMALL. 

CLIMATE, METEOROLOGY, AND AIR QUALITY: Impacts to air quality from preconstruction 

activities would be small, localized, and temporary. Local and global atmospheric conditions 

would not be altered noticeably, and the NRC staff finds that impacts to air quality would be 

SMALL. 

GEOLOGY, MINERALS, AND SOILS: Land disturbance from preconstruction clearing, grading, 

and excavation would have occurred. For reasons discussed in Section 4.2.2.5, the NRC staff 

finds that the impacts would be SMALL. 

WATER RESOURCES: Consumptive use of water for preconstruction is anticipated (dust 

suppression and domestic use for workers). Water would be brought to the IIFP site by tanker 

trucks from the Hobbs municipal water system, which has adequate capacity. No surface water 

is present on the site, and so no impacts to surface water quality, including from sedimentation 

are expected. Water tanker trucks used for preconstruction would likely obtain water from 

groundwater wells within the region, near to, but not within the IIFP site. As indicated in Section 

4.1.2.6.1, the NRC staff finds that impacts to surface water and groundwater would be SMALL. 

ECOLOGICAL RESOURCES: Preconstruction would result in the loss of vegetation and 

terrestrial habitat. Some wildlife may be destroyed. This disturbance would be limited to less 

than 10 percent of the 259-ha (640-ac) site. If NRC requires an SRP, the site could be restored 

to near original grade and condition, including replanting or re-seeding to allow vegetation to 

reclaim the facility location. The NRC staff finds that impacts to ecological resources would be 

SMALL. 

SOCIOECONOMICS AND ENVIRONMENTAL JUSTICE: Any consequences of the 

construction, operation, and decommissioning of the proposed IIFP facility (positive or adverse) 
 4-88 

would not occur and socioeconomic conditions in the ROI would remain unchanged. Population 

in the ROI would grow in accordance with current projections. The socioeconomic 

characteristics of the region, including housing availability, school enrollment, availability of 

health service resources, and law enforcement and firefighting resources, would not be affected 

by the proposed action. The no-action alternative would not cause any high and adverse 

impacts, including to low-income and minority populations. Therefore, there would not be any 

environmental justice concerns. The NRC staff finds that impacts of no action on 

socioeconomic conditions, including those of low-income and minority populations, in the region 

would be SMALL. 

TRAFFIC AND TRANSPORTATION: There would be no increased traffic as a result of the noaction alternative. The NRC staff finds that impacts to the regional and national traffic and 

transportation system would be SMALL. 

NOISE: Temporary, slight increases in ambient noise levels in the immediate area of the facility 

would occur during preconstruction, however, other than those temporary increases in local 

noise, the no-action alternative would not affect ambient noise levels. No changes in land use 

plans or traffic are expected. Therefore, based on all of these considerations, the NRC staff 

finds that impacts to noise would be SMALL. 

PUBLIC AND OCCUPATIONAL HEALTH: Except for the potential for construction-related 

injuries during preconstruction, the no-action alternative would not affect public or occupational 

health. Therefore, the NRC staff finds that impacts to public and occupational health would be 

SMALL. 

WASTE MANAGEMENT: The no-action alternative would not be expected to cause changes in 

management of solid, hazardous, or mixed waste in the region. No radiologically contaminated 

waste would be generated during preconstruction or to meet the requirements of the SRP, and, 

therefore, the NRC staff finds that impacts to waste management, would be SMALL. 

ACCIDENTS: The no-action alternative would not cause accidents to occur within the IIFP 

facility. Therefore, the NRC staff finds that impacts from accidents would be SMALL. 

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Mexico Institute of Mining and Technology, New Mexico Center for Energy Policy. ADAMS 

Accession No. ML103080942. 
 
 5-1 

5.0 MITIGATION MEASURES AND COMMITMENTS 

This chapter identifies possible measures to mitigate potential environmental impacts from the 

proposed action, as required by Appendix A to Subpart A of 10 CFR 51. CEQ’s regulation for 

implementing NEPA at 40 CFR 1500.2 (f) requires Federal agencies to “[u]se all practicable 

means consistent with the requirements of the NEPA and other essential considerations of 

national policy to restore and enhance the quality of the human environment and avoid or 

minimize any possible adverse effects of their actions on the quality of the human environment.” 

The CEQ regulations (40 CFR 1508.20) note that mitigation activities include those that 

“(1) avoid the impact altogether by not taking a certain action or parts of an action; (2) minimize 

impacts by limiting the degree or magnitude of the action and its implementation; (3) repair, 

rehabilitate, or restore the affected environment; (4) reduce or eliminate impacts over time by 

preservation or maintenance operations during the life of the action; or (5) compensate for the 

impact by replacing or substituting resources or environments.” As such, mitigation 

measures are those actions or processes (e.g., process controls and management plans) that 

would be implemented to control and minimize potential impacts associated with the proposed 

IIFP facility. 

IIFP must comply with applicable laws and regulations, including obtaining all required 

construction and operating permits, and decommissioning requirements. Chapter 5 

summarizes the mitigation measures that were proposed by IIFP (IIFP, 2009). The proposed 

mitigation measures do not include environmental monitoring activities. Environmental 

monitoring activities are described in Chapter 6 (Environmental Measurements and Monitoring 

Programs). The NRC staff has reviewed the mitigation measures proposed by IIFP and has 

concluded that the mitigation measures would reduce or minimize impacts. 

IIFP identified measures in its Environmental Report and in responses to Requests for 

Additional Information that would mitigate environmental impacts associated with the proposed 

action (IIFP, 2009; IIFP, 2011). Table 5-1 lists measures proposed to mitigate the impacts of 

construction. Table 5-2 lists measures proposed to mitigate the impacts of operations. 

These measures do not preclude additional mitigation that may be considered by IIFP based 

upon consultations with regulatory agencies other than NRC. In a letter to the NRC dated 

June 21, 2011, the NMGF recommended additional mitigation measures such as a noxious 

weed management plan, protective screening of all open stacks and vents to exclude birds or 

bats, and designing stormwater retention ponds to exclude wildlife or to provide a means of 

escape from the ponds. A copy of this letter is included in Appendix B 

Consultation/Coordination) of this EIS. 
 5-2 

Table 5-1. Summary of Potential Mitigation Measures Proposed by IIFP for Construction (Including 

Preconstruction Activities) 

Impact Area Activity Mitigation Measures 

Land Use Land disturbance • The construction footprint would be minimized to the extent possible. 

• After construction is complete, disturbed areas of the site would be stabilized with native, 

drought-resistant landscaping; and areas expected to handle regular vehicular and pedestrian traffic would be stabilized with pavement or gravel. 

• To the extent possible utilities would be placed within existing rights-of-way. 

Historic and Cultural Resources 

Disturbance of historic and cultural resources eligible for listing on the National Register of Historic Places (NRHP) 

• In the event that human remains or items of archaeological significance were discovered 

during construction, IIFP would cease work in the area around the discovery and notify the NM SHPO and Native American Tribes, so that they could determine the appropriate measures to identify, evaluate, and treat these discoveries. 

• Avoidance and data collection are the two most common forms of mitigation for sites 

considered eligible based on NRHP. When possible, avoidance is the preferred alternative because the site is preserved in place and mitigation costs are minimized. When avoidance is not possible, data collection becomes the preferred alternative. Data collection proceeds 

after the sites have been determined eligible. A treatment plan would be submitted to the appropriate regulatory agencies. The plan would describe the expected data content of the sites and how data would be collected, analyzed, and reported. A treatment/mitigation plan would be developed by IIFP, if necessary. 

Visual Resources Change in visual 

character 

• Native, drought-resistant landscaping would be used to limit visual impacts. • Disturbed areas would be promptly re-vegetated or covered 

Water Resources Runoff • Stormwater would be controlled at the proposed facility during preconstruction and 

construction by complying with the NPDES Construction General Permit requirements and by applying BMPs as detailed in the Stormwater Pollution Prevention Plan. 

• Construction equipment would be in good repair and without visible leaks of oil, grease, or 

hydraulic fluid, and would be periodically maintained and inspected. 

• BMPs would be used for dust control associated with excavation and fill operations during 

construction. Water conservation would be considered when deciding how often dust suppression sprays would be applied. 

• Stone construction pads would be placed at entrance/exits where an unpaved construction 

access road intersects a publicly maintained road. 

• Stormwater basins would be designed to facilitate the prompt, systematic sampling of runoff 

in the event of any special needs. 
 5-3 

Table 5-1. Summary of Potential Mitigation Measures Proposed by IIFP for Construction (Including Preconstruction  Activities) (Continued) 

Impact Area Activity Mitigation Measures 

Water Resources (continued 

• A spill control program would be implemented for accidental oil spills. An SPCC Plan would 

be prepared prior to the start of construction or prior to the storage of oil on site in excess of de minimis quantities and would contain the following information: 

• Identification of potential significant sources of spills and a prediction of the direction and 

quantity of flow that would result from a spill from each source 

• Identification of the containment-type or diversionary structures such as dikes, berms, 

culverts, booms, sumps, and diversion basins used at the facility to prevent discharged oil from reaching the surrounding environment 

• Procedures for inspection of potential sources of spills and spill containment/diversion 

structures 

• As part of the SPCC Plan, other measures would include control of drainage of rain water 

from dike areas, containment of oil and diesel fuel in bulk storage tanks, above-ground tank integrity testing, and oil and diesel fuel transfer operational safeguards, as appropriate. 

• Sanitary wastes generated during site construction would be handled by portable systems 

until the plant sanitary waste treatment facility was available for use. 

Air Quality Fugitive dust and 

point-source releases of criteria pollutants 

• Construction BMPs would minimize fugitive dust: Water or dust suppressants would be 

used to control dust on dirt roads. Water conservation will be considered when deciding how often dust suppression sprays would be applied. 

• Designate personnel to monitor dust emissions and direct increased watering where 

necessary. 

• Implement monitoring and inspection programs to identify equipment malfunction so that 

corrective action can be taken promptly. 

• Work practices would prevent or reduce air emissions releases. • Beds of open-bodied trucks transporting materials likely to give rise to airborne dust would 

be covered when in motion. 

• Construction equipment and related vehicles would be equipped with standard pollution 

control devices and maintained in good working order. 

Geology, Minerals, and Soil 

Soil disturbance • Erosion impacts due to site clearing and grading would be mitigated by use of construction 

and erosion control BMPs. 

• The construction footprint would be minimized to the extent possible. • Disturbed soils would be stabilized by placing crushed stone on areas of concentrated runoff 

to reduce potential for erosion and sedimentation. 
 5-4 

Table 5-1. Summary of Potential Mitigation Measures Proposed by IIFP for Construction (Including Preconstruction  Activities) (Continued) 

Impact Area Activity Mitigation Measures 

Geology, Minerals, and Soil (Continued) 

• Earthen berms, dikes, and sediment fences would be installed as necessary to limit 

suspended solids in runoff. 

• Cleared areas not covered by structures or pavement would be stabilized by acceptable 

means as soon as practical. 

• Watering or dust suppressants would be used to control fugitive dust and prevent loss of 

topsoil. 

• The facility would be designed and constructed to collect surface runoff in temporary 

detention basins. 

• Standard drilling and blasting techniques, if required, would be used to minimize impacts to 

bedrock, reducing the potential for over-excavation and thereby minimizing damage to the surrounding rock. 

• Drainage culverts and ditches would be stabilized and lined with rock aggregate to reduce 

flow velocity and trap sediments. 

• Soil stockpiles would be constructed in a manner to reduce erosion. • Site slopes would be limited to a horizontal-to-vertical ratio of three to one. • Excavated materials would be reused whenever possible. • An SPCC Plan would be implemented. 

Waste Management Waste generation 

and management 

• The quantities of waste generated would be minimized by collecting and sorting waste for 

recycling or disposal. 

• An assessment for each onsite waste storage area would be performed to identify and 

prevent potential accidental releases to the environment. 

• Onsite waste storage facilities would be monitored and inspected on an established 

schedule to detect any leaks or releases to the environment, so that corrective action could be taken promptly. 

• Waste that requires offsite storage, treatment, or disposal would be shipped to a licensed 

facility appropriate for the waste type and in compliance with State and Federal requirements. 

Ecological Resources Disturbance to 

plant and animal habitat 

• The construction footprint would be minimized to the extent possible. • Site stabilization practices would be implemented to reduce the potential for soil erosion and 

deposition of sediment into down slope wildlife and aquatic habitats. 

• Unused open areas would be left undisturbed and managed for the benefit of wildlife. 
 5-5 

Table 5-1. Summary of Potential Mitigation Measures Proposed by IIFP for Construction (Including Preconstruction  Activities) (Continued) 

Impact Area Activity Mitigation Measures 

Ecological Resources Disturbance to 

plant and animal habitat (continued) 

• Security lighting for all ground level facilities and equipment would be directed downward. • The use of native plant species in disturbed areas for revegetation would enhance and 

maximize the opportunity for native wildlife habitat to be reestablished at the site. 

• No herbicides would be used during construction 

Transportation Dust deposition 

on roadways 

• To control fugitive dust production, reasonable precautions would be taken to prevent 

particulate matter from becoming airborne, including the following actions: • Use water or dust-suppressants to control dust on dirt roads and in clearing and grading 

operations and construction activities. Water conservation would be considered when deciding how often dust suppression sprays would be applied. 

• Adequate containment methods would be used during excavation. • Open-bodied trucks transporting materials likely to give rise to airborne dust would be 

covered when in motion. 

• Disturbed areas would be stabilized or covered promptly once earth moving activities are 

completed. 

• Construction equipment and related vehicles would be operated with standard pollution 

control devices maintained in good working order. 

• Designated personnel would be assigned to monitor dust emissions and increase 

watering or application of dust suppressants where necessary. 

Traffic • During the course of construction, short-duration activities (e.g., concrete and other 

construction material deliveries) would be scheduled to minimize traffic impacts. 

• Work shifts would be implemented during construction to minimize impacts to traffic. 

Noise Operation of 

construction vehicles 

• Heavy truck and earth moving equipment usage would be prohibited after twilight and during 

early morning hours. 

• Noise suppression systems (mufflers) on construction vehicles would be kept in proper 

operation. 

• When possible, quiet equipment or methods to minimize noise emissions would be utilized 

during an activity. 

• When possible and practical, equipment with internal combustion engines would be operated 

at the lowest operating speed to minimize noise emissions. 

• Engine housing doors would be closed during operation of the equipment to reduce noise 

emissions from the engine. 

• Equipment engine idling would be avoided to the extent possible. 
 5-6 

Table 5-1. Summary of Potential Mitigation Measures Proposed by IIFP for Construction (Including Preconstruction  Activities) (Continued) 

Impact Area Activity Mitigation Measures 

Public and Occupational Health 

Hazardous materials worker safety 

• Integrated Safety Management System program and procedures would be adhered to. • All construction personnel would be required to take safety training and IIFP and all 

construction contractors would ensure that OSHA practices for construction are implemented and followed. 

Source: IIFP, 2009; IFP 2011 Table 5-2. Summary of Potential Mitigation Measures Proposed by IIFP for Operations 

Impact Area Activity Mitigation Measures 

Land Use No mitigation measures necessary Geology, Minerals, and Soil 

Materials storage • Aboveground storage tanks would be constructed of appropriate materials according to 

industry standards and applicable regulations and appropriate measures for spill containment would be installed. 

• Tanks storing petroleum products and hazardous chemicals would be equipped with 

secondary containment. 

• Routine visual inspections and preventive maintenance would be conducted. • Spill cleanup materials would be stored in the areas of fuel line and tank hose connections 

and maintained in good working order. 

• Contaminated soils would be sampled, analyzed, and managed in accordance with NRC, 

State, and other Federal requirements. 

• An SPCC plan would be developed and implemented. 

Water Resources Runoff • All aboveground petroleum storage tanks would be surrounded by berms to contain spills or 

leaks. 

• Routine visual inspections and preventive maintenance would be conducted. • Any hazardous materials would be handled by approved methods and hazardous wastes 

would be shipped offsite to licensed disposal sites. 

• The facility’s liquid effluent collection and treatment system would provide a means to control 

liquid waste within the plant, including the collection, evaporation, and minimization of liquid wastes for disposal. 

• Radioactive liquid effluent releases to the evaporative tank would be maintained at 

concentrations below 10 CFR 20 uncontrolled release limits. 
 5-7 

Table 5-2. Summary of Potential Mitigation Measures Proposed by IIFP for Operations (Continued) 

Impact Area Activity Mitigation Measures 

Water Resources (Continued) 

• Control of surface water runoff would be required for activities as required by the NPDES 

General Permit. 

• Stormwater and effluent sampling would be conducted as required by the NPDES permit to 

protect surface water quality. In addition, groundwater would be monitored to confirm that the impacts to groundwater from the IIFP facility were minimal. 

• An SPCC plan would be implemented which would include: • Identification of potential significant sources of spills and a prediction of the direction and 

quantity of flow that would result from a spill from each source. 

 Water use • Identification of containment-type or diversionary structures such as dikes, berms, 

culverts, booms, sumps, and diversion basins used at the facility to prevent discharged oil from reaching the surrounding environment. 

• Procedures for inspection of potential sources of spills and spill containment/diversion 

structures. 

• Assigned responsibilities for implementing the plan, inspections, and reporting. 

• Control of drainage of rain water from dike areas. • Containment of oil and diesel fuel in bulk storage tanks. • Aboveground tank integrity testing. • Oil and diesel fuel transfer operational safeguards. 

• Native, drought-resistant vegetation would be planted. • Floor washing using mops and self-contained cleaning machines would be used to reduce 

water usage, as opposed to conventional washing with a hose. 

• High-efficiency washing machines would be installed. • Closed-loop cooling systems would be incorporated where possible. • Process waste water would be treated and recycled. Any small amounts of excess water 

from miscellaneous processes would be retained in a storage tank and sent to an evaporator. 

Waste Management Waste generation 

and management 

• Minimize the quantities of waste by collecting and sorting waste for recycling or disposal. • Perform an assessment for each onsite waste storage area to identify and prevent potential 

accidental releases to the environment. 

• Monitor and inspect onsite waste storage facilities on an established schedule to detect any 

leaks or releases to the environment due to equipment malfunctions, so that corrective action could be taken promptly. 

Waste Management • Ship waste that requires offsite storage, treatment, or disposal to a licensed facility 
 5-8 

Table 5-2. Summary of Potential Mitigation Measures Proposed by IIFP for Operations (Continued) 

Impact Area Activity Mitigation Measures 

(Continued) appropriate for the waste type and in compliance with State and Federal requirements. Air Quality Emissions • Process design features would be developed to lower the potential for air emissions. 

• Implement monitoring and inspection programs to detect any air emissions from equipment 

malfunction during operations, so that corrective action can be taken promptly. 

• Work practices would be employed to prevent or reduce air emissions releases. • Air emissions control systems (i.e., scrubber systems and dust collectors) would be 

designed to collect and strip potentially hazardous gases from plant effluents prior to release into the atmosphere. 

• Emission stacks would be sampled continuously and routinely analyzed. 

Ecological Resources Removal of plant 

and animal habitat 

• A raptor perch would be placed in an unused open area. • Bird feeders would be installed at the visitor’s center and quail feeders would be placed in 

unused open areas away from buildings. 

• Unused open areas, including areas of native grasses and shrubs, would be managed for 

the benefit of wildlife. 

• Drought-resistant native plant species would be used to revegetate disturbed areas and to 

enhance wildlife habitat. 

• Netting or other suitable material would be used to ensure birds are excluded from retention 

(evaporation) basins that do not meet New Mexico Water Quality Control Commission surface water standards for wildlife usage. 

• Animal-friendly fencing would be used within the site so that wildlife would not be injured or 

entangled. 

• The number of open trenches would be minimized at any given time. • Air-scrubbers system liquids would be treated prior to disposal or recycled. • Security lighting for all ground level facilities and equipment would be directed downward. 

• Herbicides would be used in limited amounts according to government regulations and 

manufacturer’s instructions to control unwanted noxious vegetation. 

Transportation Traffic • Shift changes and truck shipments would be scheduled for off-peak traffic periods, when 

practical. 

Noise Operation of 

Equipment and Vehicles 

• The facility would be designed so that the reaction vessel systems, valves, transformers, 

pumps, generators, and other equipment would generally be located inside structures; the buildings themselves would limit noise outside the facility. 

• Distance, vegetation, and site buildings and structures would mitigate noise from equipment 

located outside of structures. 
 5-9 

Table 5-2. Summary of Potential Mitigation Measures Proposed by IIFP for Operations (Continued) 

Impact Area Activity Mitigation Measures 

Public and Occupational Health 

Hazardous materials processing 

• To protect the public and workers, the plant design would incorporate features to minimize 

gaseous and liquid effluent releases and to keep them well below regulatory limits. 

• The radiation protection program would require routine radiation surveys and air sampling to 

assure that worker exposures are maintained ALARA. Exposure-monitoring techniques at the plant would include use of personal dosimeters by workers, personnel breathing zone air sampling, and annual whole-body counting. 

• Annual radiation exposure for an employee would be controlled, monitored, and maintained 

ALARA through the IIFP Radiation Protection Program. 

• Worker health and safety would be protected by a Chemical Safety Program, a Radiation 

Protection Program, and an Industrial Safety Program. 

• Handling of all chemicals and wastes would be conducted in accordance with an 

Environment, Health, and Safety Program which would conform to 29 CFR 1910 and specify the use of appropriate engineered controls, and personnel protective equipment to minimize potential chemical exposures. 

• Laboratory and maintenance operations activities involving hazardous gaseous or respirable 

emissions would be conducted with ventilation control (i.e., fume hoods, local exhaust or similar) and/or with the use of respiratory protection. 

Source: IIFP, 2009; IIFP 2011 
5-10 

5.1 References 

(IIFP, 2009) International Isotopes Fluorine Products, Inc. 2009. Fluorine Extraction Process 

and Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A, ERIFP-001. December 27, 2009. ADAMS Accession No. ML100120758. 

(IIFP, 2011) International Isotopes Fluorine Products, Inc. 2011. Fluorine Extraction Process 

and Depleted Uranium De-conversion Plant (FEP/DUP) Official Responses to Environmental 

Report RAI’s. Revision A. March 31, 2011. ADAMS Accession No. ML110970481. 
 6-1 

6.0 ENVIRONMENTAL MEASUREMENTS AND MONITORING 

PROGRAMS 

This chapter describes programs that would be used to measure and monitor radiation, 

radiological materials, and chemicals associated with operation of the proposed IIFP facility. It 

also provides data on principal pathways of exposure to the public and biota. This chapter is 

organized as follows: Section 6.1 describes the radiological monitoring program; Section 6.2 

describes the physicochemical (i.e., chemical and meteorological properties that affect 

measurements) monitoring program; and Section 6.3 describes the ecological monitoring 

program. 

These monitoring programs would comprise soil and vegetation sampling, water/sediment 

sampling, continuous airborne emission particulate monitoring and measuring, groundwater 

monitoring, direct radiation measuring, and sampling of stack emissions and air vents within the 

facility. Exact sampling locations would be determined at a later date based on site information 

(IIFP, 2009). 

The facility would have an onsite analytical environmental monitoring laboratory equipped with 

analytical instruments necessary to ensure that the operation of the plant activities complies 

with Federal, State and local regulations and requirements. Compliance would be 

demonstrated by monitoring/sampling at various plant and process locations, and in the 

environment surrounding the facility, analyzing the samples and reporting the results of these 

analyses to the appropriate agencies. The environmental sampling/monitoring locations would 

be selected by the Health, Safety and Environmental staff in accordance with facility permits 

and good sampling practices. 

The onsite laboratory would perform analyses on air, water, soil, flora, and fauna samples 

obtained from designated release points and areas around the plant. In addition to its 

environmental and radiological capabilities, the environmental monitoring laboratory also would 

be capable of performing bioassay analyses when necessary. Commercial, offsite laboratories 

may also be contracted to perform bioassay analyses. 

6.1 Radiological Monitoring Program 

The proposed IIFP facility would address radiological monitoring through two programs: the 

Effluent Monitoring Program and the Radiological Environmental Monitoring Program. The 

Effluent Monitoring Program would monitor, record, and report data for radiological 

contaminants being discharged from specific emission points such as an airborne release stack. 

Radiological Environmental Monitoring Program would monitor radioactivity in environmental 

media (i.e., soil, sediment, groundwater, biota, and air) within and outside the proposed IIFP 

facility site boundary. The following subsections provide information on the two radiological 

monitoring programs. 

6.1.1 Effluent Monitoring Program 

The NRC requires nuclear fuel cycle facilities such as the proposed IIFP facility to monitor and 

report the release of radiological airborne and liquid effluents to the environment in accordance 

with Title 10, “Energy,” of the U.S. Code of Federal Regulations (10 CFR), 20.1501(a) and (b). 

Table 6-1 lists the guidance documents that apply to the radiological monitoring program. 
 6-2 

Table 6-1. Guidance Documents Applicable to Radiological Monitoring Program 

Document Applicable Guidelines 

Regulatory Guide 4.151 Quality Assurance for Radiological Monitoring Programs (Inception to 

Normal Operations to License Termination) - Effluent Streams and the 

Environment. This guide describes a method acceptable to the NRC for 

designing a program to ensure the quality of the results of measurements 

for radioactive materials in the effluents and the environment outside of 

nuclear facilities during normal operations. 

Regulatory Guide 4.162 Monitoring and Reporting Radioactive Materials in Liquid and Gaseous 

Effluents from Nuclear Fuel Cycle Facilities. This guide describes a 

method acceptable to the NRC for submitting semiannual reports that 

specify the quantity of each principal radionuclide released to unrestricted 

areas to estimate the maximum potential annual dose to the public 

resulting from effluent releases. 1

NRC, 2007 

2

NRC, 2010 

Public exposure to radiation from routine operations at the proposed IIFP facility may occur as 

the result of the discharge of liquid and gaseous effluents, including controlled releases from the 

uranium deconversion process lines during decontamination and maintenance of equipment. In 

addition, radiation exposure to the public may result from the transportation and storage of DUF6

feed cylinders. Of these potential pathways, discharge of gaseous effluent has the highest 

potential to introduce uranium into the environment (IIFP, 2009). Section 4.1.2.11 of this EIS 

presents the potential impacts from the potential release pathways. 

Compliance with 10 CFR 20.1301, Dose limits for individual members of the public, would be 

demonstrated using a calculation of the total effective dose equivalent (TEDE) to the individual 

likely to receive the highest dose in accordance with 10 CFR 20.1302(b)(1) (IIFP, 2009). The 

determination of the TEDE pathway analysis is supported by appropriate models, codes, and 

assumptions that accurately represent the facility, site, and the surrounding area. The computer 

codes used to calculate dose associated with potential gaseous and liquid effluent from the 

plant follow the methodology for pathway modeling, as described in Regulatory Guide 1.109 

(NRC, 1977), and have undergone validation and verification by NRC. 

Administrative action levels are established for effluent samples and monitoring instrumentation 

as an additional check in the effluent control process. These action levels are well below 

regulatory limits; their purpose is to support implementation of corrective actions before releases 

approach regulatory limits. Effluent samples that exceed the action level are cause for an 

investigation into the source of elevated radioactivity. For example, radiological analyses would 

be performed more frequently on ventilation air filters if there is an unexplained increase in 

gross radioactivity, or when a process change or other circumstance change radioactivity 

concentrations in the effluent stream. Progressively more rigorous corrective actions would be 

implemented based on the radioactivity level, through means of automatic shutdown 

programming and operating procedures to be developed in the detailed alarm design (IIFP, 

2009). 

Under routine operating conditions, radioactive material in effluent discharged from the facility 

would comply with regulatory release criteria. Compliance would be demonstrated through 

effluent and environmental sampling data. Processes are designed to include, when practical, 

provision for automatic shutdown in the event action levels are exceeded. Appropriate action 
 6-3 

levels and actions to be taken are specified for liquid effluents and gaseous releases (IIFP, 

2009). 

The effluent monitoring program would be overseen by IIFP Radiation Safety Program, Quality 

Assurance (QA) personnel and would be subject to periodic audits. Written procedures would 

specify the collection of representative samples, use of appropriate sampling methods and 

equipment, appropriate locations for sampling points, and proper handling, storage, transport, 

and analyses of effluent samples. In addition, IIFP would develop written procedures for 

maintaining and calibrating sampling and measuring equipment, including ancillary equipment 

such as airflow meters, to ensure that all radiological monitoring equipment is properly 

maintained and calibrated at regular intervals. The effluent monitoring program procedures 

would include functional testing and routine checks to demonstrate that monitoring and 

measuring instruments are in working condition. Employees involved in implementation of this 

program would be trained in the program procedures (IIFP, 2009). 

6.1.1.1 Gaseous Effluent Monitoring 

To ensure compliance with regulatory requirements, potentially radioactive effluents from the 

facility would be discharged only through monitored pathways. The effluent sampling program 

would measure the quantities and concentrations of radionuclides discharged to the 

environment. Uranium isotopes and daughter products are expected to be the most common 

radionuclides in the gaseous effluent. 

Effluents would be sampled as shown in Table 6-2. Representative samples would be collected 

from each release point. Because uranium in gaseous effluents may exist in a variety of 

compounds (e.g., UF6, uranium oxide, UF4, and uranyl fluoride), effluent data would be 

maintained, reviewed, and assessed by the facility’s Radiation Protection Manager to ensure 

that all gaseous effluent discharges comply with regulatory release criteria for uranium. 

However, the gaseous effluent monitoring program for the IIFP plant would be designed to 

determine the quantities and concentrations of all gaseous discharges to the environment, not 

just uranium. The process exhaust stacks would be equipped with monitors for particulates, HF, 

and gross radioactivity (IIFP, 2009). 

Table 6-2. Gaseous Effluent Sampling Program 

Area Type of Sample Type of Analysis Frequency 

Dust Collector Stacks Continuous Air Filter Gross Alpha/Beta 

Isotopic 

Weekly/Composite/ 

Quarterly 

Process Stacks Continuous Air Filter Gross Alpha/Beta 

Isotopic/Fluoride 

Weekly/Composite/ 

Quarterly 

Air Vents Continuous Air Filter Gross Alpha/Beta 

Isotopic 

Weekly/Composite/ 

Quarterly 

Source: IIFP, 2009 

Monitoring for uranium isotopes would be performed continuously and samples would be 

analyzed at least once per operating shift. If an unacceptable level of uranium is detected 

(i.e., if it exceeded the administrative action level), IIFP would investigate the cause and 

corrective action would be taken. The gaseous effluent sampling program would support the 

determination of quantity and concentration of radionuclides discharged from the facility and 

support the collection of other information required for 10 CFR 20.1501(a) and (b) (IIFP, 2009). 
 6-4 

6.1.1.2 Liquid Effluent Monitoring 

Liquids potentially contaminated with low concentrations of uranium could be generated from 

equipment decontamination, floor washings, and laundry. Except for discharges from the 

Sanitary Treatment System, liquid effluents would be contained on the proposed IIFP site via 

collection tanks and retention basins (IIFP, 2009). 

Potentially contaminated liquid effluent would be routed to the Decontamination Area for 

treatment. In the Decontamination Area, radioactive material would be removed from waste 

water through a combination of clean-up processes that would include precipitation, filtration, 

and ion exchange. Representative sampling would be ensured through the use of tank agitators 

and recirculation lines. Collection tanks would be sampled before the contents were sent 

through any treatment process. Treated water would then be collected in other tanks, which 

would be sampled. Concentrated radioactive solids generated by the liquid treatment 

processes would be disposed of as LLW at an off-site licensed disposal facility (IIFP, 2009). 

6.1.2 Radiological Environmental Monitoring Program 

The primary objective of the Radiological Environmental Monitoring Program (REMP) would be 

to provide verification that IIFP operations do not result in detrimental radiological impacts to the 

environment. The REMP data would confirm the effectiveness of effluent controls and provide 

additional verification of the power of the effluent monitoring program to produce results. The 

REMP would establish a process for collecting data for assessing radiological concentrations in 

the environment, estimate the potential impacts on the public, and support the demonstration of 

compliance with applicable radiation protection standards and guidelines. 

6.1.2.1 Sampling Program 

To meet the REMP objectives, representative samples from various environmental media would 

be collected and analyzed for radioactivity. The types and frequency of sampling and analyses 

are summarized in Table 6-3. Environmental media identified for sampling consist of ambient 

air, groundwater, soil/sediment, and vegetation. 

Environmental samples would generally be analyzed at the on-site analytical laboratory. 

However, samples could be shipped to a qualified independent laboratory for analyses. 

Monitoring and sampling activities, laboratory analyses, and reporting of radioactivity in the 

environment would be conducted in accordance with industry-accepted and agency-approved 

methodologies. 

The REMP would include the collection of data during pre-operational years in order to establish 

baseline radiological information that would be used in determining and evaluating releases 

from plant operations to the local environment. The REMP would be initiated at least 12 months 

prior to initiation of plant operations in order to develop a sufficient database before the arrival of 

the first uranium hexafluoride shipment. Radionuclides in environmental media would be 

identified using technically appropriate, accurate, and sensitive analytical instruments. 

Data collected during the operational years would be compared to the baseline generated by 

the pre-operational data. Such comparisons would provide a means of assessing the 

magnitude of potential radiological impacts on members of the public and in demonstrating 

compliance with applicable radiation protection standards. 
 6-5 

Table 6-3. Radiological Sampling and Analysis Program 

Sample Type Location Sampling 

Collection 

Frequency 

Type of 

Analysis 

Continuous 

Airborne particulate 

Six locations along 

fence line and in 

the region of 

influence, including 

the location of the 

nearest resident 

Continuous 

operation of air 

sampler with 

sample collection 

as necessary 

based on dust 

loading, but at 

least biweekly 

Quarterly 

composite 

samples by 

location 

Gross beta/gross 

alpha analyses 

each filter 

change. 

Quarterly 

isotopic analysis 

on composite 

sample 

Vegetation/Soil 

Analyses 

Five (including four 

locations along 

fence line and a 

control at an offsite 

location some 

distance away) 

For each 

vegetation and 

soil sample, 1 to 

2 kg (2.2 to 

4.4 lbs) 

Quarterly preoperation/semiannual during 

operation 

Isotopic 

analyses/fluoride 

Groundwater Four wells Samples [4 L 

(1.1 gal)] 

Semiannually Isotopic 

analyses 

Thermoluminescent 

Dosimeters (TLDs) 

Eight locations 

along fence line 

Samples 

collected 

quarterly 

Quarterly Gamma and 

neutron 

equivalent 

Stormwater Site Stormwater 

Retention Basin, 

DUF6 Cylinder 

Storage Pads, 

Stormwater 

Retention Basins 

Water sample 4 L 

(1.1 gal). 

Sediment 

samples 1 to 2 kg 

(2.2 to 4.4 lbs) 

Semiannually Isotopic 

analyses 

Source: IIFP, 2009 

Over time, revisions to the REMP may be necessary and appropriate to assure reliable 

sampling and collection of environmental data. The rationale and actions behind such revisions 

to the program would be documented and reported to the appropriate regulatory agency, as 

required. REMP sampling focuses on locations within 1.6 km (1 mi) of the facility, but may also 

include distant locations as control sites. The sampling locations may be subject to change, as 

determined from the results of periodic review of land use. 

The concentrations of radioactive material in gaseous effluent from the proposed IIFP facility are 

expected to be very low because of process and effluent controls. Consequently, air samples 

collected at locations that are close to the facility would provide the best opportunity to detect 

and identify plant-related radioactivity in the ambient air. Therefore, air monitoring activities 

would concentrate on locations close to the plant, such as the plant perimeter fence or the plant 

property line. Air monitoring stations would be situated along the fence perimeter, at the 

nearest residence, and at “control comparative” locations. In addition, an air monitoring station 

would be located next to the Stormwater Retention Basins to measure for particulate 

radioactivity that may be resuspended into the air from sediment when the basin is dry. 

Environmental air samplers would operate on a continuous basis with sample retrieval for a 

gross alpha and beta analysis occurring weekly (or more often if dust loads are heavy) 

(IIFP, 2009). 
 6-6 

Vegetation and soil samples, from on and offsite locations would be collected quarterly in each 

compass sector during the pre-operational REMP. This would ensure the development of an 

adequate baseline. During the operational years, vegetation and soil sampling would be 

performed semiannually in five compass sectors, including the three with the highest predicted 

atmospheric deposition (based on the prevailing wind direction). Vegetation samples may 

include garden vegetables or grass, depending on availability. Soil samples would be collected 

in the same vicinity as the vegetation samples (IIFP, 2009). 

On October 15, 2010, soil and vegetation samples were collected and shipped to analytical 

laboratories for analysis (GL Environmental, 2010) to establish baseline conditions. Table 6-4 

presents the results of these samples. 

Table 6-4. Baseline Radiological Soil and Vegetation Samples 

Soil Sample 

Bq/g (μCi/g) Vegetation Sample 

U-234 0.016 to 0.022 

(4.42 x 10-7 to 5.95 x 10-7) 

Less than minimum detectable 

concentrations 

U-235/U-236 2.06 x 10-4 to 9.62 x 10-4

(5.58 x 10-9 to 2.60 x 10-8) 

Less than minimum detectable 

concentrations 

U-238 0.0217 to 0.0220 

(5.86 x 10-7 to 5.95 x 10-7) 

3.85 x 10-4

(1.04 x 10-8) 

Other Isotopic Uranium Less than minimum detectable 

concentrations 

Less than minimum detectable 

concentrations 

Source: GL Environmental, 2010 

Bq/g = becquerel/gram 

μCi/g = microcurie/gram 

Groundwater samples from onsite monitoring wells would be collected semiannually for 

radiological analysis. Two monitoring wells would be downgradient of the proposed IIFP site, 

one would be located downgradient of the DUF6 Cylinder Storage Pads, and one (background 

monitoring well) would be upgradient of the site. Sediment samples would be collected 

semiannually from the stormwater runoff retention basins on site to analyze for any buildup of 

uranic material being deposited (IIFP, 2009). 

Direct radiation in offsite areas from processes inside the facility buildings is expected to be 

minimal because the low-energy radiation associated with the uranium would be shielded by 

process piping, equipment, and cylinders. Because the offsite dose equivalent rate from stored 

DUF6 cylinders is expected to be very low and difficult to distinguish from the variance in normal 

background radiation beyond the site boundary, demonstration of compliance would rely on a 

system that combines direct dose equivalent measurements and computer modeling to 

extrapolate the measurements. Environmental TLDs would be placed at the plant perimeter 

fence line or other location(s) close to the DUF6 cylinders to provide quarterly direct dose 

equivalent information. The direct dose equivalent at offsite locations would be estimated 

through extrapolation of the quarterly TLD data using computer programs (IIFP, 2009). 

6.1.2.2 Procedures 

Monitoring procedures would employ approved analytical methods and instrumentation. The 

instrument maintenance and calibration program would comply with manufacturers 
 6-7 

recommendations. The onsite laboratory and any contract laboratory used to analyze the IIFP 

facility samples would participate in third-party laboratory intercomparison programs appropriate 

to the media and analyses being measured. The following are examples of these third-party 

programs: 

• The DOE Mixed Analyte Performance Evaluation Program and DOE Quality Assurance 

Program 

• Analytics, Inc., Environmental Radiochemistry Cross-Check Program 

IIFP would require that all radiological and nonradiological laboratory vendors are certified by 

the National Environmental Laboratory Accreditation Program or an equivalent State laboratory 

accreditation agency for the analytes being tested (IIFP, 2009). 

The REMP would fall under the oversight of IIFP’s Quality Assurance Program. Quality 

assurance procedures would be implemented to ensure representative sampling, proper use of 

appropriate sampling methods and equipment, proper locations for sampling points, and proper 

handling, storage, transport, and analyses of effluent samples. In addition, written procedures 

would ensure that sampling and measuring equipment, including ancillary equipment such as 

airflow meters, would be properly maintained and calibrated at regular intervals according to 

manufacturer recommendations. The implementing procedures would include functional testing 

and routine checks to demonstrate that monitoring and measuring instruments were in working 

condition. 

Audits would be periodically conducted as part of its Quality Assurance Program (IIFP, 2009). 

The quality control procedures used by the analytical laboratories would conform to the 

guidance in Regulatory Guide 4.15 (NRC, 2007). These quality control procedures would 

include the use of established standards such as those provided by the National Institute of 

Standards and Technology and the use of standard analytical procedures such as those 

established by the National Environmental Laboratory Accreditation Conference (IIFP, 2009). 

6.1.2.3 Reporting 

Reporting procedures would comply with the requirements of 10 CFR 70.59 and the guidance 

specified in Regulatory Guide 4.16 (NRC, 2010). Reports of the concentrations of principal 

radionuclides released to unrestricted areas in effluents would be provided and would include 

the minimum detectable concentration (MDC) for the analysis and the error for each data point. 

Each year, IIFP would submit a summary report of the environmental sampling program to the 

NRC, including all associated data, as required by 10 CFR 70. The report also would include 

the types, numbers, and frequencies of environmental measurements and the identity and 

concentrations of nuclides found in the environmental samples. Significant positive trends 

would also be noted in the report, along with any adjustment to the program, unavailable 

samples, and deviations from the sampling program. 

6.2 Physicochemical Monitoring 

6.2.1 Introduction 

The primary objective of physicochemical monitoring would be to provide verification that the 

operations at the IIFP plant do not result in detrimental chemical impacts on the environment. 

Effluent controls would be in place to ensure that chemical concentrations in gaseous and liquid 
 6-8 

effluents are maintained ALARA. In addition, physicochemical monitoring would provide data to 

confirm the effectiveness of effluent controls. 

Administrative action levels would ensure that chemical discharges remain below the limits 

specified in the facility discharge permits: the EPA Region 6 NPDES General Discharge 

Permits and the New Mexico Environment Department / Water Quality Bureau WQB) 

Groundwater Discharge Permit/Plan. Physicochemical monitoring would be performed for 

routine operations with provisions for additional evaluation in response to potential accidental 

releases. 

Physicochemical monitoring would sample stormwater, soil, sediment, vegetation, and 

groundwater (Table 6-5) to confirm that chemical discharges are below regulatory limits. There 

are no surface waters on the site; therefore, no surface water monitoring program would be 

implemented. However, soil sampling would include outfall/overflow areas such as the outfall at 

the Site Stormwater Retention Basins. In the event of any accidental release from the facility, 

these sampling protocols would be initiated immediately and on a continuing basis to document 

the extent/impact of the release until conditions have been abated and mitigated (IIFP, 2009). 

Table 6-5. Physicochemical Sampling 

Sample Type Sample Location Frequency 

Sampling and 

Collections2

Stormwater Stormwater Detention 

Basins Quarterly Analytes as determined by baseline program 

Vegetation 5 minimum1 Quarterly/ 

Semiannually3

Fluoride Uptake 

(growing seasons) 

Soils 5 minimum1 Quarterly/ 

Semiannually3

Metals, Organics, 

Pesticides, and 

Fluoride Uptake 

Water/Sediment 2 minimum1 Quarterly/ 

Semiannually3

Analytes as determined 

by baseline program 

Groundwater Selected Groundwater 

Wells Semiannually Metals, Organics, and Pesticides 

Source: IIFP, 2009 

1

Locations to be established by Health Safety &Environmental organization. 

2

Analyses will meet EPA Lower Limits of Detection (LLD), as applicable, and will be based on the baseline surveys 

and the sample type. 3

Quarterly during pre-operations; semiannual during operations. 

Waste liquids, solids and gases from related processes and decontamination operations would 

be analyzed and/or monitored for chemical contamination to determine safe disposal methods 

or further treatment requirements. 

6.2.2 Evaluation and Analysis of Samples 

Samples of liquid effluents, solids and gaseous effluents from plant processes would be 

analyzed in the environmental monitoring laboratory. Results of process sample analyses 

would be used to verify that process parameters were operating within expected performance 

ranges. Results of liquid effluent sample analyses would be characterized to determine if 

treatment is required prior to discharge or disposal. 
 6-9 

6.2.3 Quality Assurance 

Quality assurance would be achieved by following a set of formalized and controlled procedures 

that IIFP would create, implement and periodically review for sample collection, lab analysis, 

chain of custody, reporting of results, and corrective actions. Corrective actions would be 

instituted if an action level is exceeded for any of the measured parameters. IIFP would 

establish three action levels: the sample parameter is three times the normal background level, 

the sample parameter exceeds any existing administrative limits, or the sample parameter 

exceeds any regulatory limit. The third scenario represents the worst case, which is not 

expected, however, triggering any of the three action levels would initiate an action plan. 

Corrective actions would be implemented to ensure that the cause for the action level 

exceedance is identified and immediately corrected; applicable regulatory agencies are notified, 

if required; communications to address lessons learned are dispersed to appropriate personnel; 

and applicable procedures are revised accordingly, if needed. Action plans would be 

commensurate with the severity of the exceedance. 

IIFP would ensure that the onsite laboratory and any contract laboratory used to analyze IIFP 

samples participates in third-party laboratory intercomparison programs appropriate to the 

media and analytes being measured. The IIFP facility would require all radiological and nonradiological laboratory vendors to be certified by the National Environmental Laboratory 

Accreditation Conference or an equivalent State laboratory accreditation agency for the analytes 

being tested. 

6.2.4 Lower Limits of Detection 

Lower limits of detection (LLDs) for the parameters sampled for in the Stormwater Monitoring 

Program are listed in Section 6.2.6. LLDs for the non-radiological parameters would be based 

on the results of the baseline surveys and the sampled media. Minimum detectable 

concentrations for environmental samples are listed in Table 6-6. 

Table 6-6. Required Minimum Detectable Concentrations for Environmental Sample 

Analyses 

Medium Analysis 

Minimum Detectable 

Concentrations 

Bq/ml (μCi/ml) 

Ambient Air gross alpha 3.7 x 10-14 (1.0 x 10-18) 

Vegetation isotopic uranium 3.7 x 10-6 (1.0 x 10-10) 

Soil/Sediment isotopic uranium 1.1 x 10-2 (3.0 x 10-7) 

Groundwater isotopic uranium 3.7 x 10-8 (1.0 x 10-12) 

Source: IIFP, 2009. 

Bq/ml = becquerel/milliliter 

μCi/ml = microcurie/milliliter 

6.2.5 Effluent Monitoring 

Chemical constituents that may be discharged to the environment would be below 

concentrations established by State and Federal regulatory agencies as protective of the public 

health and the natural environment. Under routine operating conditions, no significant quantities 

of contaminants would be released from the facility. This would be confirmed through 
 6-10 

monitoring and collection and analysis of environmental data. The facility would not directly 

discharge any industrial effluents to surface waters or to offsite locations, and there would be no 

plant tie-in to a publicly owned wastewater treatment works. Except for discharges from the 

sanitary treatment system, liquid effluents would be contained in the IIFP facility in collection 

tanks and retention basins. 

No chemical sampling is planned for sanitary wastes because no plant process related effluents 

would be introduced into that system. 

6.2.6 Stormwater Monitoring Program 

A stormwater monitoring program would be initiated during construction. Data collected from 

the program would be used to evaluate the effectiveness of measures taken to prevent the 

contamination of stormwater and to retain sediments within site boundaries. A temporary 

detention basin would be used as a sediment control basin during construction as part of the 

overall sedimentation erosion control plan. 

Stormwater monitoring would continue with the same frequency upon initiation of facility 

operation. During plant operation, samples would be collected from the DUF6 Cylinders Storage 

Pad Stormwater Retention Basin and the Site Stormwater Detention Basin to demonstrate that 

runoff does not contain contaminants. A list of parameters to be monitored and monitoring 

frequencies is presented in Table 6-7. 

Table 6-7. Stormwater Monitoring Program 

Parameter Frequency Sampling Method 

Lower Limit of 

Detection 

Oil & Grease Quarterly Grab 0.5 ppm 

Total Suspended Solids Quarterly Grab 0.5 ppm 

5-Day Biological Oxygen 

Demand Quarterly Grab 2 ppm 

Chemical Oxygen Demand Quarterly Grab 1 ppm 

Total Phosphorous Quarterly Grab 0.1 ppm 

Total Kjeldahl Nitrogen Quarterly Grab 0.1 ppm 

pH Quarterly Grab 0.01 units 

Nitrate plus Nitrite Nitrogen Quarterly Grab 0.2 ppm 

Metals Quarterly Grab Varies1

Source: IIFP, 2009. 

1

 Analyses will meet EPA LLD, as applicable, and will be based on the baseline surveys and the sample type. 

ppm = parts per million 

The monitoring program would be refined to reflect applicable requirements as determined 

during the NPDES permit application process. Additionally, the Site Stormwater Retention 

Basin would adhere to the requirements of the Groundwater Discharge Permit/Plan from the 

New Mexico Water Quality Board. 
 6-11 

6.2.7 Environmental Monitoring 

The purpose of this section is to describe the surveillance monitoring program, which would be 

implemented to measure non-radiological chemical impacts on the environment. The ability to 

detect and contain any potentially adverse chemical releases from the facility to the environment 

would depend on chemistry data collected as part of the effluent and stormwater monitoring 

programs described in the preceding sections. Data acquisition from these programs 

encompasses both onsite and offsite sample collections. Final constituent analysis 

requirements would be in accordance with permit mandates. Sampling locations would be 

determined based on meteorological information and current land use. The sampling locations 

may be subject to change as determined from the results or any significant changes in land use. 

The chemical monitoring program is designed to identify chemical concentrations in the 

environment that could be attributed to plant operations. 

Vegetation samples would include grasses and shrub brush. Soil would be collected in the 

same vicinity as the vegetation sample. The samples would be collected from sectors chosen 

based on predicted direction of the prevailing winds. Sediment samples would be collected 

from the discharge points of the stormwater collection basins. Groundwater samples would be 

collected from the series of wells described in Section 6.1.2.1. Stormwater samples collected in 

the DUF6 Cylinder Storage Pad Stormwater Retention Basin would be sampled to ensure no 

contaminants are present. 

Operational sample results would be compared to baseline data collected during preoperational 

sampling to identify any positive trends. On October 15, 2010, two soil and two vegetation 

baseline samples were collected for analysis. Tables 6-8 and 6-9 present the results of these 

samples. 

Operational monitoring surveys would be conducted at locations and frequencies established 

from baseline sampling data and as determined by requirements in EPA Region 6 NPDES 

General Discharge Permits and the New Mexico Water Quality Board Groundwater Discharge 

Permit/Plan. 

Annually IIFP would submit a summary of the environmental sampling program results to 

regulatory authorities, as required. This summary would include the types, numbers and 

frequencies of samples collected, analytical results, and a discussion of any observed trends. 

Significant positive trends would be discussed, along with any adjustments to the program, 

unavailable samples, or deviations from the sampling protocol. 

Table 6-8. Baseline Physicochemical Soil Sample Results 

Soil Sample 1 

(mg/kg) 

Soil Sample 2 

(mg/kg) 

Barium 88.5 109 

Cadmium 0.27 0.42 

Chromium 10.0 12.2 

Lead 11.7 14.7 

All other Resource 

Conservation and Recovery Act 

Metal Concentrations 

Less than minimum detectable 

concentrations 

Less than minimum detectable 

concentrations 

Source: GL Environmental, 2010 

mg/kg = milligrams/kilogram 
 6-12 

Table 6-9. Baseline Physicochemical Vegetation Sample Results 

Vegetation Sample 1 

(mg/kg) 

Vegetation Sample 2 

(mg/kg) 

Resource Conservation and 

Recovery Act Metal 

Concentrations 

Less than minimum detectable 

concentrations 

Less than minimum detectable 

concentrations 

Barium 10.6 10.9 

Benzoic acid 0.48 0.46 

Bis(2-ethylhexyl) phthalate 0.26 0.19 

Phenol 0.40 Less than minimum detectable 

concentrations 

Source: GL Environmental, 2010 

mg/kg = milligrams/kilogram 

6.2.8 Meteorological Monitoring 

Atmospheric conditions (e.g., wind speed, wind direction, temperature, precipitation, relative 

humidity) would be monitored by electronic sensors mounted on a 40 m (131 ft) tower located 

on site. Data from this monitoring program would be used to characterize the site’s 

meteorological conditions (both normal and extreme) in order to predict patterns of radionuclide 

and chemical dispersion and deposition. The meteorological tower would be at the same 

elevation as the finished facility grade. The tower would be located at a distance at least ten 

times the height of any obstruction to ensure that wind flow around structures would interfere 

with meteorological sampling. IIFP would establish instrument maintenance and calibration 

schedules, keep back-up monitoring equipment on hand, and deploy redundant data recorders 

to ensure at least 90 percent data recovery. 

6.3 Ecological Monitoring 

The ecological monitoring program would be designed to characterize changes that may occur 

in the composition of biotic communities as a result of site preparation, construction, operation, 

and decommissioning of the proposed IIFP facility. The program would focus on observable 

changes in habitat characteristics and wildlife populations. 

The ecological monitoring program would be carried out in accordance with generally accepted 

monitoring practices and the requirements of the USFWS and NMGF. Under the program, data 

would be collected and analyzed. Procedures would be established, as appropriate, for data 

collection, storage, analysis, reporting, and corrective actions. 

6.3.1 General Ecological Conditions of the Site 

Section 3.8 describes the natural environment of the proposed site and vicinity. The area is a 

transitional zone between the shortgrass prairie north of the Mescalero Ridge (Western Great 

Plains Shortgrass Prairie) and the desert communities south of the Mescalero Ridge 

(Apacherian-Chihuahuan Mesquite Upland Scrub). These habitat types commonly occur in the 

vicinity of the IIFP site (Figure 3-19). The vegetation in this area is dominated by deep sand 

tolerant- and extreme drought- and grazing-tolerant plant species. The natural habitats on the 

IIFP site and the region surrounding the site have been degraded by livestock grazing, oil and 
 6-13 

gas pipeline rights-of-way and access roads. As described in Section 3.7.2 of this EIS, there 

are no wetlands or stream systems on the facility footprint, and therefore, no riparian habitat. 

There are no important ecological communities on site that are vulnerable to change or that 

contain important species habitats, such as breeding areas, nursery, feeding, or other areas 

important to important species (Section 3.8). 

6.3.2 Monitoring Program Elements 

Several ecological elements would be monitored vegetation, birds, mammals, reptiles and 

amphibians. Currently there are no known actions or reporting levels for any of these elements. 

However, discussions with the responsible agencies (NMGF and USFWS) would continue and 

agency recommendations would be considered when developing action and/or reporting levels 

for each element. 

IIFP would periodically monitor the proposed site property during the construction phases, 

operation phases, and decommissioning to ensure the risk to wildlife is minimized. 

6.3.3 Observations and Sampling Design 

The monitoring program would establish site baseline data collected before commencement of 

preconstruction activities. The procedures to characterize the baseline plant and animal 

populations would also be used for the construction and operations monitoring programs. 

Monitoring surveys during operations would be conducted annually for vegetation and 

semiannually for animals using the same sampling sites established during the baseline 

monitoring program (IIFP, 2009). 

These surveys are intended to be sufficient to characterize broad changes in the composition of 

the ecological community in the vicinity of the facility that could be attributed to activities at the 

facility. 

The analyses would comprise descriptive statistics (sample size, mean, standard deviation, 

standard error, and confidence interval for the mean). For these studies, a significance level of 

5 percent would be used, resulting in a 95 percent confidence level (IIFP, 2009). 

The data collected would be analyzed by the Environment, Health, and Safety staff. Annually a 

report summarizing the results would be prepared (IIFP, 2009). The monitoring program for 

each of the ecological elements described below would be used for the duration stipulated in the 

terms of the NRC license agreement, if granted. The anticipated duration would most likely be 

the first three years of operation of the proposed IIFP facility. Following that initial monitoring 

period, program changes could be initiated based on operational experience and the results of 

the initial monitoring. 

6.3.3.1 Vegetation 

The following vegetation parameters would be monitored: species composition, percent ground 

cover, stem frequency, woody plant density, and production data. Sampling from 16 permanent 

sampling locations on the IIFP site would occur annually in September or October. Annual 

sampling is scheduled to coincide with the mature flowering stages of the dominant perennial 

species. 
 6-14 

The sampling locations would be selected in areas outside of the proposed footprint of the IIFP 

facility. The selected sampling locations would be clearly marked (i.e., staked or flagged) on 

site, and the Global Positioning System (GPS) coordinates recorded. Permanent sampling 

locations would facilitate a long-term monitoring system designed to evaluate vegetation trends 

and characteristics. 

Transects used for data collection would extend out 30-m (98-ft) in a given compass direction at 

each sampling location. Ground cover and stem occurrence frequency would be determined 

utilizing the line intercept method. Cover measurements would be read to the nearest 0.03-m 

(0.1-ft). Woody plant densities would be determined using the belt transect method. All 

individual shrubs and trees within 2-m (6.6-ft) of the 30-m (98-ft) transect would be counted. 

Productivity would be determined by estimating the production within three 0.25-m2

 (2.7-ft2) 

plots and harvesting each species in one 0.25-m2

 (2.7-ft2) plot along the transect and converting 

the dry weight of the plot vegetation into kg of forage per ha (lbs/ac). 

6.3.3.2 Birds 

Site-specific avian surveys would be conducted in both the wintering and breeding seasons to 

verify the presence of particular bird species. For the winter survey, the distinct habitats at the 

site would be identified and the bird species composition within each of the habitats described. 

Transects, 100-m (328-ft) in length, would be established within each distinct homogenous 

habitat, and data would be collected along each transect. Species composition and relative 

abundance would be determined based on visual observations and call counts. The spring 

survey would also determine the nesting and migratory status of the species observed and (as a 

measure of the nesting potential of the site) the occurrence and number of male territories. The 

area would be surveyed using the standard point count method. 

All birds seen or heard by a qualified observer at each point would be recorded. Surveys would 

begin 15 minutes prior to sunrise and conclude by 10:00 am (or earlier on warm days) to 

coincide with the territorial males’ peak singing times. The points would be recorded using a 

GPS, enabling return visits. Data would be compared with species known to exist in the area. 

6.3.3.3 Mammals 

All mammals observed during other ecological sampling will be noted and results compared to 

the species list compiled for the area. 

6.3.3.4 Reptiles and Amphibians 

A combination of pitfall trapping and walking transects (at trap sites) would provide data in 

sufficient quantity to allow statistical measurements of population trends, community 

composition, body size distributions and sex ratios that would reflect environmental conditions 

and changes at the site over time. 

Each sample site would be located to maximize the total catch of reptile and amphibian species, 

rather than data on each individual caught. Each animal caught would be identified, sexed, 

snout-vent length measured, examined for morphological anomalies and released (sample with 

replacement design). There would be two sample periods, at the same time each year, in May 

and late June/early July, which would coincide with breeding activity for lizards; most snakes; 

and depending on rainfall, amphibians. 
 6-15 

Because reptile and amphibian species are sensitive to climatic conditions, and to account for 

the spotty effects of rainfall, each sampling event would also record rainfall, relative humidity 

and temperatures. The rainfall and temperature data would act as a covariant in the analysis. 

In addition to the monitoring plan described above, general observations would be gathered and 

recorded concurrently with other wildlife monitoring. The data would be compared to all the 

species known to exist in the area. 

6.4 References 

(GL Environmental, 2010) GL Environmental, Inc. 2010. 2010 Soil and Vegetation 

Characterization Report. Prepared for International Isotopes Fluorine Products. ADAMS 

Accession No. ML112140543 

(IIFP, 2009) International Isotopes Fluorine Products, Inc. 2009. Fluorine Extraction Process & 

Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A. 

December 27, 2009. ADAMS Accession No. ML100120758. 

(NRC, 1977) U. S. Nuclear Regulatory Commission. 1977. Calculation of Annual Doses to Man 

from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 

10 CFR 50, Appendix I. Regulatory Guide 1.109, Revision 1. October, 1977. 

(NRC, 2007) U.S. Nuclear Regulatory Commission. 2007. Quality Assurance for Radiological 

Monitoring Programs (Inception Through Normal Operations to License Termination)-Effluent 

Streams and the Environment. Regulatory Guide 4.15. Revision 2. 2007. 

(NRC, 2010) U.S. Nuclear Regulatory Commission. 2010. Monitoring and Reporting 

Radioactive Materials in Liquid and Gaseous Effluents from Nuclear Fuel Cycle Facilities. 

Regulatory Guide 4.16. Revision 2. 2010.
 
 7-1 

7.0 COST-BENEFIT ANALYSIS SUMMARY 

This chapter summarizes benefits and costs associated with the proposed action and the noaction alternative. Chapter 4 (Environmental Impacts) of this EIS discusses the potential 

impacts of the construction, operation, and decommissioning of the proposed IIFP facility. 

Implementation of the proposed action would generate national, regional, and local benefits and 

costs. The primary national benefit of the proposed IIFP facility would be a benefit to the 

national uranium fuel cycle by ensuring that commercial enrichment facilities throughout the 

nation do not have to rely on long-term storage of DUF6. The regional benefits of the proposed 

project would be increased employment, economic activity, and tax revenues in the region 

around the proposed site. Some of these regional benefits, such as tax revenues, would accrue 

specifically to Lea County and the City of Hobbs. Other benefits may extend to neighboring 

Eddy County. Environmental costs associated with the proposed IIFP facility are, for the most 

part, limited to the area immediately surrounding or on the site. 

The data for this analysis are drawn largely from Chapter 4, the assessment of environmental 

impacts. Monetary cost data is taken from IIFP’s environmental report prepared for the license 

application (IIFP, 2009) and subsequent responses to NRC staff’s requests for additional 

information (IIFP, 2011). The analysis separately covers both the construction (including 

preconstruction) and operations phases. As described in Section 4.1.3, NRC regulation 

10 CFR 40.36 requires IIFP to have a decommissioning plan and provide for funding of the 

decommissioning. Decommissioning costs are evaluated in this analysis only in terms of 

payments to a decommissioning fund. 

Section 7.1 presents the costs and benefits of the no-action alternative. Section 7.2 presents 

costs of the proposed action. Section 7.3 presents benefits of the proposed action. Section 7.4 

presents a summary of the cost-benefit analysis, including NRC staff’s determination of costeffectiveness. 

7.1 Costs and Benefits of the No-Action Alternative 

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

decommission the facility. No DUF6 would be deconverted into fluoride products (for 

commercial resale) and depleted uranium oxides (for disposal). Without a deconversion facility 

such as the proposed facility, DUF6 would continue to be stored, primarily at commercial 

uranium enrichment facilities in the United States. Fluoride products would not be 

manufactured and sold to end users. Planned or existing commercial enrichment facilities 

would not be able to send their DUF6 to the IIFP facility for deconversion. As a result, the 

proposed site would not be disturbed by the proposed project activities. Ecological, natural, and 

socioeconomic resources would remain unaffected by the proposed action, except for what 

occurred during preconstruction. All potential environmental impacts from the proposed action 

(that is, not including preconstruction) would be avoided. Similarly, all project-specific 

socioeconomic impacts (e.g., related to employment, economic activity, population, housing, 

local finance) would be avoided. 

Table 2.5 of Section 2.3 summarizes and compares the external environmental costs and 

benefits of both the proposed action and the no-action alternatives. Section 4.1 provides details 

on these external environmental and socioeconomic costs and benefits for the proposed action. 

Section 4.3 provides details for the no-action alternative. 
 7-2 

7.2 Costs of the Proposed Action 

The costs for a project are usually presented as internal and external costs. Internal costs are 

those that are borne by the owner, IIFP in this instance. These costs are most easily expressed 

as monetary costs. External costs are those borne by others or by the environment. Such 

costs can be monetary, but most often include both quantitative and qualitative environmental 

impacts. As described in Sections 2.1 and 2.2.2.2.1, IIFP intends to develop this project in two 

phases, with the Phase 1 component the subject of the current license application. Because 

Phase 2 is closely related to Phase 1 and is a reasonably foreseeable action for which analysis 

of cumulative impacts is required, this section presents both Phase 1 and Phase 2 costs. 

Section 7.2.1 discusses costs during the construction phase, and Section 7.2.2 discusses costs 

during the operations phase. 

7.2.1 Construction Costs 

7.2.1.1 Internal Costs 

Internal construction costs include capital costs and labor costs. All costs are presented in 2009 

dollars. 

IIFP’s environmental report provides cost estimates based on the assumptions presented there. 

Table 7-1 of this section presents the capital costs and labor costs. Both capital and labor costs 

are spread out over the years of construction (2012 through 2013 for Phase 1 and 2015 through 

2016 for Phase 2). 

Table 7-1. Construction Capital and Labor Costs for the IIFP Facility (Millions of 2009 

Dollars) 

Cost Category 

Phase 1 

Costsa 

(in millions of 

dollars) 

Phase 2 

Costsa 

(in millions of 

dollars)

Total Phases 1 

and 2 Costs 

(in millions of 

dollars) 

Capital Costs 

Fixed Capital 

DUF4 plant $9 – $12 0 $9 – $12 

FEP plant $15 – $19 0 $15 – $19 

Oxide add-on plant 0 $26 – $34 $26 – $34 

Balance of Plant $15 – $20 $1 – $1.5 $16 – $21.5 

Engineering, procurement, and 

construction management $7 – $11 $7 – $9 $14 – $20 

Project management and programs $2 – $3 $1 – $1.5 $3 – $4.5 

Contractor fees $2 – $3 $1 – $2 $3 – $5 

Contingency $5 – $6 $3 – $4 $8 – $10 

Subtotal Fixed Capital $55 – $74 $39 – $52 $94 – $126 

Development/Startup Capital 

Regulatory, licenses, permits $3 – $4 $1 – $1.5 $4 – $5.5 

Pre-startup working capital $9 – $12 $1 – $2 $10 – $14 
 7-3 

Table 7-1. Construction Capital and Labor Costs for the IIFP Facility (Millions of 2009 

Dollars) (Continued) 

Cost Category 

Phase 1 

Costsa 

(in millions of 

dollars) 

Phase 2 

Costsa 

(in millions of 

dollars) 

Total Phases 1 

and 2 Costs 

(in millions of 

dollars) 

Spare parts and startup inventories $3 – $4 $1 – $1.5 $4 – $5.5 

Subtotal Development/Startup $15 – $20 $3 – $5 $18 – $25 

Total Capital Costs $70 – $94 $42 – $57 $112 – $151 

Labor Costs 

Construction and installation $22.3 – $34.1 $13.7 – $20.9 $36 – $55 

Engineering, procurement, and 

construction management $6.1 – $9.2 $3.7 – $5.7 $9.8 – $14.9 

Project management $1.6 – $2.3 $0.9 – $1.4 $2.5 – $3.7 

Total Labor Costs $29.9 – $45.6 $18.4 – $28.0 $48.3 – $73.6 

Total Capital and Labor costs $99.9 – $139.6 $60.4 – $85.0 $160.3 – $224.6 

Source: IIFP, 2009 

a

Phase 1 and Phase 2 labor costs are estimated from the cumulative costs, based on the 62 percent-38 percent cost 

split for capital costs as found in the capital costs. 

7.2.1.2 External Costs 

External construction costs are summarized here. 

Land Use: 259 ha (640 ac) of grazing land converted to industrial use 

Historic and Cultural Resources: no resources expected to be affected 

Visual Resources: no adverse impact expected 

Climatology, Meteorology, and Air Quality: small, temporary, and local impacts to air quality; 

some small amount of CO2 and other GHGs, criteria pollutants, and HAPs released 

Geology, Mineral, and Soils: no prime farmland affected; 16 ha (40 ac) cleared 

Water Resources: groundwater withdrawal a small percentage of that available; groundwater 

quality not expected to be adversely impacted; no surface water use or discharge 

Ecological Resources: 16 ha (40 ac) of grassland removed; no threatened or endangered 

species expected to be affected 

Socioeconomic Resources and Local Community Services: small decrease in available public 

service capacities; small increases in local tax revenues; small influx of money to the local 

economy; small improvement in employment rate 

Traffic and Transportation: small increase in traffic near the intersection of NM 483 and 

US 62/180, but not sufficient to warrant mitigation 
 7-4 

Noise: no adverse impact expected 

Public and Occupational Health Impacts: construction injuries typical for industrial construction; 

no fatalities expected statistically 

Waste Management: waste generation a small percentage of existing disposal capacities 

7.2.2 Operations Costs 

7.2.2.1 Internal Costs 

Internal operations costs include raw materials, utilities, marketing and distribution, operations 

and maintenance, labor, waste disposal, and replacement capital costs. All costs are presented 

in 2009 dollars. The annual costs presented were estimated based on a 40-year plant operating 

life. The data presented here are from IIFP’s environmental report (IIFP, 2009) and subsequent 

responses to NRC staff’s requests for additional information (IIFP, 2011), and based on the 

assumptions presented in these documents. 

Raw Materials 

IIFP states (IIFP, 2009) that the proposed plant would use relatively small amounts of raw 

materials. This is because the primary input to the plant is a waste product from existing and 

proposed commercial enrichment facilities. The primary raw materials, other than the DUF6

feedstock, are SiO2, B2O3, Ca(OH)2, KOH, and hydrogen gas. These materials are not 

expected to be procured in the region of influence (Lea and Eddy counties). The annual costs 

(in 2009 dollars) for raw materials are as follows: 

Phase 1: $1.89 million 

Phase 2 (incremental): $0.82 million 

Cumulative: $2.71 million 

Utilities 

Utilities include electricity, natural gas, water, nitrogen, steam, and compressed air. Some of 

these utilities would be produced on site. However, approximately $1.5 million (2009 dollars) 

per year of utilities would be procured during the Phase 1 only facility operations between 2013 

and the beginning of 2017. An additional $1.7 million per year of utilities for Phase 2 would be 

procured each year from 2017 through 2050 as a result of the expansion to the Phase 2 facility. 

Beginning in 2017, the cumulative utilities procured from utility companies located in the region 

or State would cost approximately $3.2 million each year, thereby benefiting the local and state 

economies. 

Marketing and Distribution 

IIFP reports that the marketing and distribution of FEP products would likely amount to 

8 percent of the SiF4 cost or approximately $200,000 to $250,000 annually (2009 dollars). Only 

SiF4 is accompanied by any marketing and distribution costs because the other products are 

sold to only a few customers under contracts. This is an annual cost that would be incurred 

irrespective of the startup of Phase 2, because SiF4 is generated in the Phase 1 process. 
 7-5 

Operations and Maintenance 

Operations and maintenance (O&M) costs would be those associated with purchasing materials 

for repair and replacement of equipment or infrastructure, and operating supplies such as office 

supplies, safety equipment, or laboratory chemicals. IIFP estimates that the annual O&M costs 

(2009 dollars) would be: 

Phase 1: $2.7 million 

Phase 2 (incremental): $1.6 million 

Cumulative O&M cost: $4.3 million 

Not all of these monies would be spent in the region of influence. 

Labor 

Section 4.1.2.8 presents the workforce requirements for the IIFP facility operations. In 

Tables 7-8 and 7-9 of IIFP’s environmental report (IIFP, 2009), IIFP projects the annual labor 

costs for both Phase 1 and Phase 2. These are as follows, in 2009 dollars: 

Phase 1: $7.9 million to $9.1 million 

Phase 2 (incremental): $1.4 million to $1.7 million 

Cumulative labor cost: $9.6 million to $10.5 million 

Waste Disposal 

The types and quantities of waste for disposal are reported in Section 4.1.2.12. The largest 

disposal costs would be associated with depleted uranium oxide; however, other LLW, RCRA 

waste, and sanitary waste would be disposed as well. The costs for Phase 1 and Phase 2 

waste disposal are presented in Table 7-10 of the IIFP’s environmental report (IIFP, 2009 as 

modified by IIFP [2011]) and are reproduced in Table 7-2. 

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

Waste Type 

Phase 1 

(in millions of 

dollars) 

Phase 2 

(in millions of 

dollars) 

Cumulative 

(in millions of 

dollars) 

Depleted uranium oxide $2.6 – $7.0 $5.4 – $15.5 $8.0 – $22.5 

Other process low-level waste $0.25 – $0.40 $0.01 – $0.05 $0.26 – $0.45 

Miscellaneous low-level waste $0.23 – $0.35 $0.22 – $0.30 $0.45 – $0.65 

RCRA waste $0.009 – $0.035 $0.005 – $0.010 $0.014 – $0.045 

Sanitary waste $0.002 – $0.003 negligible $0.002 – $0.003 

Total1 $3.1 – $7.8 $5.6 – $16 $8.7 – $24 1

Totals rounded to two significant digits. 

Replacement Capital 

Replacement capital would be required to replace infrastructure and equipment over the life of 

the facility. IIFP estimates that replacement costs over the 40-year assumed life of the facility 

would be approximately $60 million to $85 million (2009 dollars); however, no replacement 
 7-6 

capital expenditures are expected for the first 7 years. The costs accumulate more heavily as 

the facility ages. The NRC staff calculated an average annual replacement capital cost of 

$1.8 million to $2.8 million over the 13 years of maximum replacement expenditures. 

Table 7-3 reports the values reported by IIFP in Chapter 7 of the environmental report 

(IIFP, 2009) and the subsequent response to NRC staff’s requests for additional information 

(IIFP, 2011). 

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

Time Period 

Phase 11 

(in millions of 

dollars) 

Phase 21 

(in millions of 

dollars) 

Cumulative 

(in millions of 

dollars) 

2011 – 2016 0 0 0 

2017 – 2027 $4.6 – $5.6 $4.4 – $5.4 $9 – $11 

2028 – 2037 $17.9 – $21.9 $17.2 – $21.1 $35 – $43 

2038 – 2050 $16.3 – $19.9 $15.7 – $19.1 $32 – $39 

Total 40-year period $38.8 – $47.4 $37.3 – $45.6 $76 – $93 1

IIFP (2011) states that 51 percent and 49 percent of the replacement capital costs would be associated 

with Phase 1 equipment and Phase 2 equipment, respectively. 

Summary of Internal Operations Costs 

Table 7-4 provides the total internal operations costs per year. 

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

Type of Internal Cost 

Phase 1 

(in millions of 

dollars) 

Phase 2 

(in millions of 

dollars) 

Cumulative 

(in millions of 

dollars) 

Raw materials $1.89 $0.82 $2.71 

Utilities $1.5 $1.7 $3.2 

Marketing and distribution $0.20 – $0.25 0.0 $0.20 – $0.25 

O&M $2.7 $1.6 $4.3 

Labor $7.9 – $9.1 $1.4 – $1.6 $9.6 – $10.5 

Waste disposal $3.1 – $7.8 $5.6 – $16 $8.7 – $24 

Replacement capital $38.8 – $47.4 $37.3 – $45.6 $76 – $93 

Total1 $56 – $71 $48 – $67 $100 – $140 1

Totals rounded to two significant digits. 

7.2.2.2 External Costs 

External operations costs are summarized here. 

Land Use: Land use would be consistent with other uses in the area 

Historic and Cultural Resources: no resources expected to be affected 
 7-7 

Visual Resources: no adverse impact expected 

Climatology, Meteorology, and Air Quality: small and local impacts to air quality 

Geology, Mineral, and Soils: no adverse impact 

Water Resources: groundwater withdrawal a small percentage of that available; groundwater 

quality not expected to be adversely impacted; no surface water use or discharge 

Ecological Resources: no adverse impact expected 

Socioeconomic Resources and Local Community Services: small decreases in public service 

capacities; small increases in local tax revenues; small influx of money to the local economy; 

small improvement in employment rate 

Traffic and Transportation: small increase in traffic near the intersection of NM 483 and 

US 62/180, but not sufficient to warrant mitigation; radiation doses to members of the public 

from transport of radioactive wastes and depleted uranium far less than normal background 

Noise: no adverse impact expected 

Public and Occupational Health Impacts: operation injuries typical for industrial plant operation; 

no fatalities expected statistically; radiological emissions produce immeasurably small impacts; 

chemical emissions small and localized 

Waste Management: waste generation a small percentage of existing disposal capacities 

7.3 Benefits of the Proposed Action 

7.3.1 Construction 

Taxes 

Phase 1 construction-related activities, purchases, and workforce expenditures would require 

several types of tax payments, including individual income taxes, gross receipts taxes, and 

property taxes. Increased tax revenues are considered a benefit to the State of New Mexico, 

Lea County, the Hobbs Municipal School District, the New Mexico Junior College, the 

communities in Lea County, and other locales where plant-related spending would occur. 

IIFP (2011) estimates that approximately $554,400 of fee in lieu of property taxes would be paid 

to the Hobbs Municipal School District and the New Mexico Junior College during the Phase 1 

construction period. IIFP is exempt from any other property tax. 

IIFP estimates (in 2009 dollars) that Phase 1 construction costs would be between $70 million 

and $94 million (Section 4.1.1.8). Some portion of those expenditures would occur within the 

ROI and other counties nearby. The expenditures would generate gross receipts tax revenues 

for both the affected counties and for the State of New Mexico (IIFP, 2011b). Because IIFP 

would have an industrial revenue bond with Lea County, some facility-related expenditures 

would be exempt from gross receipts taxes. 
 7-8 

Regional spending on goods and services by IIFP employees would generate gross receipts tax 

revenues for Lea and Eddy County municipalities, Lea County, Eddy County, New Mexico, and 

other locales where spending occurs. 

Employment 

During Phase 1 construction of the IIFP facility, 80 percent of the 140 IIFP construction jobs are 

expected to be filled by workers that already reside within the two-county ROI (Section 4.1.1.8). 

The 112 residents that would fill the construction jobs would represent 0.2 percent of the June 

2010 labor force within the region. If all 112 of the jobs were filled by unemployed workers, the 

unemployment rate in the region of influence would decrease by 0.2 percent. The remaining 

28 jobs would be filled by workers that would migrate into the ROI. The in-migrating workers 

would increase the labor force by 0.05 percent (Section 4.1.1.8). The 12 indirect jobs that would 

be created during Phase 1 construction of the IIFP facility would likely be filled by regional 

residents. If all 12 jobs were filled by unemployed workers, those workers would represent 

0.3 percent of the unemployed labor force in June 2010 (Section 4.1.1.8). 

Economy 

IIFP (2011b) estimates that between $9,140,000 and $13,900,000 (2009 dollars) would be 

infused into the economy annually during the construction period for labor and materials. Most 

of these values would be spent within the ROI. 

7.3.2 Operations 

Taxes 

Phase 1 operations-related activities, purchases, and workforce expenditures would require 

several types of tax payments, including corporate income taxes, individual income taxes, gross 

receipts taxes, and property taxes. Increased tax revenues are viewed as a benefit to the State 

of New Mexico, Lea County, the Hobbs Municipal School District, the New Mexico Junior 

College, the communities in Lea County, and other locales where plant-related spending would 

occur. 

Table 4-21 presents the estimated corporate income and gross receipts taxes that would be 

paid to the State of New Mexico and Lea County entities. The low estimate of corporate income 

and gross receipt taxes paid to the State is $144,200,000 and $6,500,000 to Lea County. The 

low estimate on property taxes is $8,700,000 to Lea County (IIFP, 2011b). 

In addition to IIFP’s income and gross receipts tax payments, plant employees would contribute 

state individual income and state and county gross receipts tax revenues. IIFP facility employee 

earnings would be taxed as individual income. Regional spending on goods and services by 

IIFP employees would generate gross receipts tax revenues for Lea County, Eddy County, the 

State of New Mexico, and other locales where their spending would occur. 

Employment 

Approximately 80 percent of the IIFP operation positions would be filled by people currently 

residing in the two-county ROI (Table 4-19). Those 112 workers would represent 0.2 percent of 

the June 2010 two-county labor force (Section 4.1.2.8). If all 112 of these jobs were filled by 

unemployed workers in the region, the unemployment rate would decrease by 0.2 percent. 
 7-9 

Approximately 20 percent of the IIFP operation positions (28 jobs) would be filled by people 

migrating into the region of influence from outside the region (Section 4.1.2.8). The in-migrating 

workers would represent a 0.2 percent increase of the June 2010 labor force (Section 4.1.2.8). 

The in-migration of 28 workers to fill operation positions would also create 51 new indirect jobs 

within the ROI because of the multiplier effect (Section 4.1.2.8). If unemployed workers fill the 

51 indirect jobs that would be created during the Phase 1 operation of the IIFP facility, they 

would represent 1.3 percent of the unemployed labor force in June 2010. 

Economy 

The regional economy would benefit from the capital investment expenditures and recurring 

costs associated with the operation of the IIFP facility. IIFP has provided estimates for some of 

these costs. The payroll associated with Phase 1 operating wages is within the range of 

$7,900,000 to $9,100,000 annually (Section 4.1.2.8). Operations employees and workers in 

indirect positions would spend earnings on goods and services within the region of influence. 

Additional costs associated with operations include replacement capital, waste disposal, 

insurance premiums, taxes, utilities, and maintenance materials and supplies. These 

expenditures would range from $17,315,000 to $23,727,000 annually (Section 4.1.2.8). 

National Benefits 

Long-term storage of DUF6 poses potential health risks because of the physical and chemical 

characteristics of DUF6. If DUF6 is released to the atmosphere, it reacts with water vapor in the 

air, forming HF fumes and a uranium-fluoride compound, UO2F2. These products are 

chemically toxic. HF is an extremely corrosive gas that can damage the lungs and cause death 

if inhaled. 

DUF6 has been stored at DOE sites for approximately 40 years. The Defense Nuclear Facilities 

Safety Board, in 1995, issued a Technical Report (DNFSB, 1995) calling for improved safety 

analysis, inspections, and handling procedures to ensure safe storage of DUF6. DOE has since 

embarked on a program of creating deconversion capability at two locations where uranium 

enrichment has been performed. 

The proposed IIFP facility would provide a benefit to the national uranium fuel cycle by ensuring 

that commercial enrichment facilities throughout the nation do not have to rely on long-term 

storage. 

Silicon tetrafluoride is used in the electronics industry. Boron trifluoride is used for ion 

implantation, as a catalyst for polymer reactions, and as a gas in neutron radiation detectors. 

Anhydrous hydrogen fluoride has many industrial uses. These byproducts of IIFP’s 

deconversion process are marketable. The benefit to the nation is that the IIFP plant would be 

an alternate source of inexpensive (because it is the byproduct of the main process) fluoride 

products. 

7.4 Evaluation Summary of the Proposed IIFP Facility 

The internal construction and operations costs for the IIFP facility are based on proprietary 

business analyses performed by IIFP. Given that company investors are willing to pursue the 

license in light of these costs, the NRC staff’s concern is primarily evaluation of costs to the 

communities around the facility and the State of New Mexico. Implementation of the proposed 
 7-10 

action would have a SMALL positive overall economic impact on the region of influence. The 

implementation of the proposed action would generate national, regional, and local benefits and 

costs. 

The primary national benefit of building the proposed IIFP facility would be improved 

management of the DUF6 part of the uranium fuel cycle. The regional benefits of building the 

proposed IIFP facility would be increased employment, economic activity, and tax revenues in 

the region around the site. Some of these regional benefits, such as tax revenues, accrue 

specifically to Lea County. Other benefits may extend to neighboring counties in the state of 

New Mexico. 

Costs associated with the proposed IIFP facility are, for the most part, limited to the area 

surrounding the site and the communities within commuting distance. These include monetary 

and environmental costs. As summarized above, the environmental costs are SMALL to 

MODERATE (for air quality). The influx of money into the State and local economies from the 

proposed action would appear to more than offset the small financial burdens placed on 

community services. The benefits to Lea County, Eddy County, the State of New Mexico, and 

the nation’s capacity to maintain the uranium fuel cycle weigh somewhat favorably for the 

benefit side of this comparison. 

7.5 References 

(DNFSB, 1995) U.S. Defense Nuclear Facilities Safety Board. 1995. Integrity of Uranium 

Hexafluoride Cylinders. Technical Report DNFSB/TECH-4. May 5, 1995. 

(IIFP, 2009) International Isotopes Fluorine Products. Inc. 2009. Fluorine Extraction Process 

and Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A, 

ER-IFP-001. December 27, 2009. ADAMS Accession No. ML100120758. 

(IIFP, 2011) International Isotopes Fluorine Products. 2011. Fluorine Extraction Process and 

Depleted Uranium De-conversion Plant (FEP/DUP) Official Responses to Environmental Report 

RAIs, Revision A. March 31, 2011. ADAMS Accession No. ML110970481. 
 8-1 

8.0 SUMMARY OF ENVIRONMENTAL CONSEQUENCES 

On December 30, 2009, IIFP submitted an application to the NRC for a license to construct, 

operate, and decommission the proposed IIFP facility (IIFP, 2009). IIFP proposes to locate the 

facility in Lea County, New Mexico, approximately 22.5 km (14 mi) west of Hobbs, New Mexico. 

If licensed, the proposed facility would deconvert DUF6 into fluoride products (for commercial 

resale) and depleted uranium oxides (for disposal). 

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

under Title 10, Code of Federal Regulations, Part 40 (10 CFR 40), in accordance with the 

Atomic Energy Act of 1954. Section 102 of the National Environmental Policy Act of 1969, as 

amended (NEPA) (Public Law 91-190; Title 42, Section 4321 et seq., United States Code

[42 U.S.C. 4321 et seq.]), directs that an Environmental Impact Statement (EIS) is required for 

major Federal actions that significantly affect the quality of the human environment. Section 

102(2)(C) of NEPA requires that an EIS include information about the following: 

• environmental impacts of the proposed action, 

• any adverse environmental effects that cannot be avoided, should the proposal be 

implemented, 

• alternatives to the proposed action, 

• the relationship between local short-term uses of the environment and the maintenance 

and enhancement of long-term productivity, and 

• any irreversible and irretrievable commitments of resources that would be involved if the 

proposed action is implemented. 

NRC’s regulations under 10 CFR 51 implement the requirements of NEPA. Because the NRC 

is responsible for licensing this facility, the licensing action is a Federal action, and must meet 

the requirements of NEPA. Based on the EIS and other information [including the original 

license application and responses to Requests for Additional Information (RAIs) received by 

NRC from the applicant] and analysis of the magnitude of potential impacts, the NRC staff will 

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

decommissioning of the proposed IIFP facility. 

IIFP anticipates two phases to the project, but the current license application is for the first 

phase only. Phase 2, under NEPA, is considered a “reasonably foreseeable future action” 

(40 CFR 1508.7). Therefore, Phase 2 impacts are considered cumulative impacts, and have 

been addressed in Section 4.2 of this EIS. IIFP expects to begin preconstruction activities in 

late 2011. If the license application is approved, IIFP expects to begin facility construction in 

2012, which would continue for one year. Phase 2 construction would begin in 2015 and 

continue for one year. 

As part of its license application, IIFP submitted an Environmental Report (ER). Information in 

the ER and supplemental environmental documentation provided by IIFP has been reviewed 

and independently verified by the NRC staff and used, in part, by the NRC staff in preparing this 

EIS. Upon acceptance of the ER, the NRC staff began the environmental review process 

described in 10 CFR 51 by publishing, on July 15, 2010, in the Federal Register (75 FR 42142) 

a Notice of Intent to prepare an EIS and conduct scoping. The purpose of the EIS scoping 

process was to assist in determining the range of actions, alternatives to the proposed action, 
 8-2 

and potential impacts to be considered in the EIS, and to identify significant issues related to the 

proposed action. Comments and information from the public and government agencies were 

received during the scoping period. As part of the scoping process, the NRC staff held a public 

scoping meeting on July 29, 2010, in Hobbs, New Mexico. NRC staff considered the public 

comments received during the scoping process for preparation of this EIS; the summary of the 

EIS scoping process is provided in Appendix A. 

In addition to reviewing IIFP’s ER and supplemental documentation, the NRC staff consulted 

with appropriate Federal, State, and local agencies and Native American Tribes. 

Further comments from the public and government agencies were received after the NRC 

issued a Draft EIS for public review and comment on January 13, 2012, and announced its 

availability in the Federal Register (77 FR 2096) in accordance with 10 CFR 51.74. The public 

comment period ended on February 27, 2012. During the public comment period, the NRC held 

a public meeting in Hobbs, New Mexico, on February 2, 2012, where oral comments from 

members of the public were received on the Draft EIS. In addition to comments received at the 

public meetings, the NRC received written comments by postal mail and e-mail during the public 

comment period. The public meeting transcripts and the written comments are part of the public 

record for the proposed IIFP facility. These comments were considered by the NRC in preparing 

this EIS. Comment summaries and the NRC’s responses are contained in Appendix F of this 

EIS. 

Included in this EIS are (1) the results of the NRC staff’s analyses, which consider and weigh 

the environmental effects of the proposed action; (2) mitigation measures for reducing or 

avoiding adverse effects; (3) the environmental impacts of alternatives to the proposed action; 

and (4) the NRC staff’s assessment regarding the proposed action based on its environmental 

review. 

Potential environmental impacts are evaluated in this EIS using the three-level standard of 

significance – SMALL, MODERATE, or LARGE – developed by the NRC using guidelines from 

the Council on Environmental Quality (CEQ) (40 CFR 1508.27). Table B-1 of 10 CFR 51, 

Subpart A, Appendix B provides the following definitions of the three significance levels: 

• SMALL – Environmental effects are not detectable or are so minor that they would 

neither destabilize nor noticeably alter any important attribute of the resource. 

• MODERATE – Environmental effects are sufficient to alter noticeably, but not to 

destabilize, important attributes of the resource. 

• LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize 

important attributes of the resource. 

8.1 Unavoidable Adverse Environmental Impacts 

Section 102(2)(c)(ii) of NEPA requires that an EIS include information on any adverse 

environmental effects that cannot be avoided, should the proposed action be implemented. 

Unavoidable adverse environmental impacts are those potential impacts that cannot be avoided 

and for which no practical means of mitigation are available. 

This section summarizes the environmental consequences for the proposed action that cannot 

be avoided and for which no practical means of mitigation are available. Identification and 

description of the environmental impacts for the proposed action that would result from 
 8-3 

construction, operation, and decommissioning of the proposed IIFP facility are presented in 

Chapter 4, “Environmental Impacts.” The mitigation measures that would be incorporated into 

the proposed action to control and minimize potential adverse environmental impacts are 

summarized in Chapter 5, “Mitigation Measures and Commitments.” The monitoring programs 

that would be incorporated into the proposed action are listed in Chapter 6, “Environmental 

Measurements and Monitoring Programs.” 

Implementing the proposed action would result in unavoidable adverse impacts to land use, 

ecological resources, groundwater quantity, and air quality. Unavoidable adverse impacts to 

land use would occur at the initiation of the project, commencing with restricting the current land 

use, grazing, from the property and committing it, for the duration of the facility license, to 

industrial purposes. Site preparation will destroy up to 16 ha (40 ac) of Western Shortgrass 

Prairie or Apacherian-Chihuhuan Mesquite Upland Scrub habitat. However, both habitats are 

common throughout the region. Some topsoil would be lost during the grading and clearing, but 

this loss would be minimized with BMPs. Animal habitats would be destroyed and some 

mortality of individuals would occur during construction. The presence of the facility could 

prevent some animals from foraging or nesting in the vicinity of the facility. 

During construction and operation, facility operations will consume small amounts of 

groundwater; the greatest groundwater use would occur during operations. The facility would 

use a small amount (approximately 0.5 percent) of the estimated annual 40-year planning 

period groundwater demand for Lea County, and 0.15 percent annually of the unappropriated 

water rights assigned to Lea County by the New Mexico Office of the State Engineer. 

Construction and operation would release small quantities of pollutants, including radionuclides 

to the atmosphere. Emissions of CO2 and other greenhouse gases, and CO and SO2 during 

construction would be SMALL, however, construction could result in MODERATE impacts from 

NO2, PM2.5 and PM10 emissions. Construction impact to air quality would be localized and 

temporary. BMPs would minimize impacts to air quality during construction. Plant design would 

minimize emissions of radiological and chemical pollutants to levels well below regulatory limits; 

concentrations higher than background will not be detectable beyond the site boundary, and the 

releases will not adversely affect local or regional air quality. 

8.2 Irreversible and Irretrievable Commitments of Resources 

Environmental Review Guidance for Licensing Actions Associated with NMSS Programs 

[NUREG-1748 (NRC, 2003)], defines an “irreversible” commitment and an “irretrievable” 

commitment as follows: 

• “Irreversible” refers to the commitment of environmental resources that cannot be 

restored. 

• “Irretrievable” refers to the commitment of material resources that once used cannot be 

recycled or restored for other uses by practical means. 

The implementation of the proposed action as described in Section 2.1 would include the 

commitment of land, water, energy, raw materials, and other natural and manmade resources. 

Approximately 16 ha (40 ac) on the 259-ha (640-ac) site would be affected by the construction, 

operation, and decommissioning of the proposed IIFP facility. 

It is likely that, once the land has been committed to an industrial use, it will remain in industrial 

use in perpetuity, so this should be considered an irreversible commitment. 
 8-4 

Groundwater use by the facility during both construction and operation would be consumptive. 

Groundwater withdrawn from the Ogallala aquifer will not be returned to the aquifer. Some will 

be lost to evaporation in the process, and the treated sanitary wastewater used to irrigate 

landscaping will transpire to the atmosphere through the process of photosynthesis. The depth 

to groundwater at the site is approximately 30 ft, so it is unlikely any landscape water will return 

to the groundwater. 

Energy consumption will be in the form of gasoline and diesel fuel for construction equipment 

and generators, and coal or natural gas to generate electricity to power the facility. Some 

natural gas will be consumed in the production of hydrogen at the facility. These represent 

irretrievable uses of those resources. 

The construction and operation of the proposed IIFP facility would require commitments of 

significant quantities of concrete, steel, nonferrous metals, plastics, and other material 

resources. At decommissioning, certain building materials and equipment could be recycled, 

however some materials would not be recyclable, and some materials would have been 

consumed by the deconversion process. Resources used in the construction and operation of 

the facility that could not be reused or recycled at the end of their useful life would represent an 

irreversible commitment. Materials consumed during the deconversion process would be 

irreversible commitments of resources. Hazardous and radioactive waste streams would be 

irreversible commitments of resources, as would the land needed to properly dispose of those 

waste streams. 

No other irreversible or irretrievable commitments of resources were identified for the 

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

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

 Maintenance and Enhancement of Long-Term Productivity 

Consistent with the CEQ definition in 40 CFR 1502.16 and the definition provided in NUREG1748 (NRC, 2003), this EIS defines short-term uses and long-term productivity as follows: 

• Short-term uses generally affect the present quality of life for the public (i.e., the 40-year 

license period for the proposed IIFP facility). 

• Long-term productivity affects the quality of life for future generations on the basis of 

environmental sustainability (i.e., long-term is the period after license termination for the 

proposed IIFP facility). 

Construction, operation, and decommissioning of the proposed IIFP facility would necessitate 

short-term commitments of resources. The short-term commitment of resources would include 

land, water and energy sources, and materials which could be recovered or recycled. Impacts 

would be minimized by mitigation measures and resource management. The short-term use of 

these resources would result in potential long-term socioeconomic benefits to the local area and 

the region, such as improvements to the local economy and infrastructure supported by worker 

income and tax revenues and the maintenance and enhancement of a skilled worker base. 

Workers, the public, and the environment would be exposed to slightly elevated concentrations 

of radioactive and hazardous materials over the short term from the operation of the proposed 

IIFP facility due to process emissions and the transport and disposal of hazardous and 

radioactive waste. 
 8-5 

Upon expiration of the license, IIFP would decommission the facility, recycle some equipment 

and restore the facility for another use. The use of the site and the buildings for other industrial 

purposes would constitute a long-term benefit to the community and would increase long-term 

productivity. Continued employment, expenditures, and tax revenues generated during 

preconstruction, construction, and operation of the proposed IIFP facility and from future site 

uses after the facility is decommissioned would directly benefit the local, regional, and State 

economies and would be considered a long-term benefit. 

8.4 References 

(IIFP, 2009) International Isotopes Fluorine Products, Inc. 2009. Fluorine Extraction Process & 

Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A, ER-IFP001. December 27, 2009. ADAMS Accession No. ML100120758. 

(NRC, 2003) U.S. Nuclear Regulatory Commission. 2003. Environmental Review Guidance for 

Licensing Actions Associated with NMSS Programs, NUREG-1748, Washington D.C., 2003. 

ADAMS Accession No. ML032450279.
 
 9-1 

9.0 LIST OF PREPARERS 

9.1 U.S. Nuclear Regulatory Commission Contributors 

Matt Bartlett; NMSS Project Manager 

BS, Physics, Bob Jones University, Greenville, SC, 1997 

MS, Physics, Clemson University, Clemson, SC, 2000 

PhD, Physics, Clemson University, Clemson, SC, 2004 

Years of Relevant Experience: 6 

Greg Chapman P.E., C.H.P; Analyst, Accidents 

BEE, Georgia Tech 1987 

ME, University of Florida, 1993 

Graduate Certificate, University of Tennessee, 2010 

Years of Relevant Experience: 18 

Diana Diaz-Toro; Chief, Environmental Review Branch-A; General Reviewer 

BS, Chemical Engineering, University of Puerto Rico, 2002 

MBA, American University, 2008 

Years of Relevant Experience: 9 

Nathan Goodman; Reviewer, Ecological Resources 

BS, Biology, Muhlenberg College, 1998 

MS, Environmental Science, Johns Hopkins University, 2000 

Years of Relevant Experience: 12 

Christopher Grossman; Reviewer, Waste Management 

BS, Civil Engineering, Purdue University, 1998 

MS, Environmental Engineering & Science, Clemson University, 2001 

Years of Relevant Experience: 9 

Kellee L. Jamerson; Reviewer, Environmental Measurements and Monitoring Programs 

BS, Environmental Science, Tuskegee University, 2006 

Years of Relevant Experience: 3 

Stephen Lemont, Ph.D.; Technical Reviewer, Statutory and Regulatory Requirements, 

Alternatives, Reasonably Foreseeable Actions, Land Use, Historic and Cultural Resources, 

Water Resources, Waste Management, and Geology, Minerals, and Soil 

BS, Chemistry, Brooklyn College of the City University of New York, 1971 

PhD, Physical Chemistry, Columbia University, 1976 

Years of Relevant Experience: 30 

Asimios Malliakos, Ph.D.; EIS Project Manager; General EIS Reviewer 

BS, Physics, University of Thessaloniki, Greece, 1975 

MS, Nuclear Engineering, Polytechnic Institute of New York, 1977 

PhD, Nuclear Engineering with a Minor Degree in Probability and Statistics, University of 

Missouri-Columbia, 1980 

Years of Relevant Experience: 30 
 9-2 

Christepher A. McKenney; Contributor and Technical Reviewer, Waste Management 

BS, Nuclear Engineering, Oregon State University, 1991 

Years of Relevant Experience: 20 

Johari Moore; Reviewer, Public and Occupational Health, Traffic and Transportation 

BS, Physics, Florida A & M University, 2003 

MSE, Nuclear Engineering and Radiological Sciences, University of Michigan, 2005 

Years of Relevant Experience: 3 

Ashley Waldron; Reviewer, Ecological Resources, Air Quality and Environmental Monitoring 

BS, Biology, Frostburg State University, 2009 

Years of Relevant Experience: 3 

Jean Trefethen; Reviewer, Traffic and Transportation, Noise, and Public and 

Occupational Health 

BA, Biology, Carroll College, 1987 

Years of Relevant Experience: 2 

9.2 Straughan Environmental and Tetra Tech Contributors 

Lawson Bailey; Contributing Author, Affected Environment 

BS, Biology, Virginia Polytechnic Institute & State University, 1979 

Years of Relevant Experience: 32 

Greg M. Beachley, Ph.D.; Contributor, Air Quality 

BS, Chemistry and BS, Biology, James Madison University, 2001 

PhD, Analytical & Environmental Chemistry, University of Maryland, 2009 

Years of Relevant Experience: 6 

Jacqueline K. Boltz; Technical Editor, Public Outreach Manager 

BA, French Language and Literature, Boston University, 1991 

MBA, General Business, Boston University, 1991 

Years of Relevant Experience: 19 

Steven J. Connor; Analyst, Proposed Action and Alternatives and Cost-Benefit Analysis 

Summary; Technical Reviewer 

BS, Physics, Georgia Institute of Technology, 1973 

MS, Physics, Georgia Institute of Technology, 1974 

Years of Relevant Experience: 34 

Charles Conrad; Analyst, Air Quality and Traffic 

BS, Chemical Engineering, University of Wisconsin – Madison, 2002 

Years of Relevant Experience: 5 

Krista Dearing; Analyst, Geology, Minerals, Soils and Groundwater 

BS, Geology, University of Cincinnati, 1991 

MS, Geology, University of Cincinnati, 1993 

Years of Relevant Experience: 16 
 9-3 

Amanda J. Deering; Contributor and Technical Reviewer 

BS, Environmental Studies, Towson University, 2010 

Years of Relevant Experience: 1 

Eric T. Duce; Contributor and Technical Reviewer, Land Use and Ecology 

BS, Natural Resources Management, University of Maryland, 1998 

MS, Environmental Science and Policy, Johns Hopkins University, 2005 

Years of Relevant Experience: 11 

Alverna R. (A.J.) Durham, Jr.; Analyst and Technical Reviewer, Air Quality 

BS, Industrial Technology, North Carolina Agricultural and Technical State University, 1999 

Years of Relevant Experience: 6 

Kristin Fusco Rowe, P.E.; Analyst, Noise Abatement Specialist 

BS, Engineering Science, Loyola College, 2002 

Years of Relevant Experience: 9 

Kristi Hagood; Analyst, Climatology, Meteorology, and Air Quality 

BS, Chemistry, Converse College, 1998 

MS, Astrophysical, Planetary and Atmospheric Sciences, University of Colorado, 2000 

Years of Relevant Experience: 9 

Tim J. Harvey, PMP; Program Manager 

BS, Natural Resources, Cornell University, 1983 

Years of Relevant Experience: 25 

Justin M. Haynes; Technical Reviewer 

BS, Integrated Science & Technology, Environmental Concentration, James Madison 

University, 2003 

Years of Relevant Experience: 7 

Richard L. Heimbach, II, AICP; Project Manager 

BS, Environmental Resource Management, Pennsylvania State University, 1989 

Years of Relevant Experience: 20 

Chimere M. Lesane-Matthews; Analyst, Land Use, Socioeconomics, Traffic and Transportation 

BS, Civil Engineering, Morgan State University, 2001 

Years of Relevant Experience: 10 

Anne Lovell; Contributor, Air Quality 

BS, Chemical and Petroleum Refining Engineering, Colorado School of Mines, 1985 

Years of Relevant Experience: 25 

Lisa Matis; Analyst, Waste Management 

MS, Mechanical Engineering, Stevens Institute of Technology, 1989 

BS, Chemical Engineering, Stanford University, 1984 

Years of Relevant Experience: 26 
 9-4 

Sarah M. Michailof; Analyst, Historic and Cultural Resources 

BA, Anthropology and Biology, University of North Carolina, Chapel Hill, 1994 

MA, Historic Preservation, Goucher College, 2007 

Years of Relevant Experience: 16 

Phil Moore; Technical Editor

BA, English, University of South Carolina, 1975 

MS, Wildlife Biology (Fisheries Emphasis), Clemson University, 1983 

Post Graduate Study, Zoology, Clemson University, 1977 1979 

Years of Relevant Experience: 25 

Ellen K. Mussman; Analyst, Land Use, Ecology, Mitigation and Monitoring 

BS, Conservation of Soil, Water, and the Environment, University of Maryland, 

College Park, 2002 

MS, Forest Resources, University of Washington, 2006 

Years of Relevant Experience: 6 

Karen Patterson; Task Manager and Senior Reviewer 

BA, Biology, Randolph-Macon Woman’s College, 1973 

MA, Biology, Wake Forest University, 1977 

MLIS, University of South Carolina, 1999 

Years of Relevant Experience: 37 

Nikki J. Radke; Contributor, Graphics 

BS, Biology and Wildlife Management, University of Wisconsin-Stevens Point, 1999 

MS, Wildlife Management, Texas Tech University, 2005 

Years of Relevant Experience: 7 

Noreen Raza; Contributor, Environmental Justice 

BS, English, Towson University, 2003 

Years of Relevant Experience: 5 

Jay Rose; Analyst, Cumulative Impact Assessment, Health and Safety, Accidents, and 

Executive Summary 

BS, Ocean Engineering, U.S. Naval Academy, 1983 

JD, Catholic University, Columbus School of Law, 1996 

Years of Relevant Experience: 27 

Kenneth R. Scarlatelli; Technical Reviewer, Ecology 

BS, Wildlife Biology, University of Massachusetts at Amherst, 1983 

MA, Environmental Studies, Environmental Management Concentration, 1994 

Years of Relevant Experience: 27 

Alan Toblin; Analyst, Accidents 

BE, Cooper Union, 1968 

MS, University of Maryland, 1970 

Years of Relevant Experience: 39 

 
 9-5 

9.3 Center for Nuclear Waste Regulatory Analysis Contributors 

James Durham; Principal Investigator, Contributor, Comment Responses 

PhD, Nuclear Engineering, University of Illinois at Urbana-Champaign, 1987 

Years of Relevant Experience: 25 

Amy Hester; Contributor, Socioeconomics 

BA, Environmental Studies, University of Kansas, 1998 

Years of Relevant Experience: 14 

Robert Lenhard; Project Manager 

PhD, Soil Physics, Oregon State University, 1984 

Years of Relevant Experience: 28 

Lauren Mulverhill; Technical Editor 

BS, Radio-Television, Southern Illinois University – Carbondale, 1984 

Years of Relevant Experience: 28 

John Stamatakos; Program Manager, Contributor, Geophysics 

PhD, Geology, Lehigh University, 1990 

Years of Relevant Experience: 25 

 10-1 

10.0 Glossary 

Abatement: Diminution in amount, degree, or intensity. 

Activity: A measure of the rate at which a material emits nuclear radiation, usually given in 

terms of the number of nuclear disintegrations occurring in a given length of time. The common 

unit of activity is the curie (Ci), which amounts to 37 billion disintegrations per second. The 

international unit of activity is the becquerel (Bq) and is equal to one disintegration per second. 

Air pollutant: Any substance in air which could, if present in high enough concentration, harm 

humans, animals, vegetation, or material. Pollutants may include almost any natural or artificial 

substance capable of being airborne. 

Air quality: A measure of the concentrations of pollutants, measured individually, in the air. 

These concentrations are often compared to regulatory standards. 

Air quality standards: The concentration of a pollutant in air prescribed by regulations that 

may not be exceeded during a specified time in a defined area. Air quality standards are used 

to provide a measure of the health-related and visual characteristics of the air. 

ALARA: Acronym for "as low as (is) reasonably achievable." An approach to keep radiation 

exposures (both to the workforce and the public) and releases of radioactive material to the 

environment at levels that are as low as social, technical, economic, practical, and public policy 

considerations allow. ALARA is not a dose limit; it is a practice in which the objective is the 

attainment of dose levels as far below applicable limits as possible. 

Alluvium: Clay, silt, sand, and/or gravel deposits found in a stream channel or in low parts of a 

stream valley that is subject to flooding. Ancient alluvium deposits frequently occur above the 

elevation of present-day streams. 

Alternative site: A ranked site, other than the proposed site, that was evaluated in the finescreening step. 

Ambient air: The surrounding atmosphere, usually the outside air, as it exists around people, 

plants, and structures. It is not the air in immediate proximity to emission sources. 

Ambient Air Quality Standards: Standards established on a State or Federal level, that define 

the limits for airborne concentrations of designated “criteria” pollutants (nitrogen dioxide, sulfur 

dioxide, carbon monoxide, total suspended particulates, ozone, and lead), to protect public 

health with an adequate margin of safety (primary standards) and to protect public welfare, 

including plant and animal life, visibility, and materials (secondary standards). 

Ambient Noise Level: A sound level that represents the background noise from community or 

environmental sound sources. 

Anhydrous: Without water (H2O). 

Anthropogenic: Caused or influenced by humans. 

Aqueous: Related to water. 
 10-2 

Aquifer: Geologic unit sufficiently permeable to conduct groundwater. 

Area of potential effect (APE): The geographic area or areas within which an undertaking 

may directly or indirectly cause alterations in the character or use of historic properties, if any 

such properties exist. The area of potential effects is influenced by the scale and nature of an 

undertaking and may be different for different kinds of effects caused by the undertaking. 

Assay: The qualitative or quantitative analysis of a substance; often used to determine the 

proportion of isotopes in radioactive materials. 

Asymptomatic: Without symptoms. 

Atmosphere: The layer of air surrounding the earth. 

Atomic Energy Act of 1954 as amended: A Federal law that created the Atomic Energy 

Commission, which later split into the Nuclear Regulatory Commission and the Energy and 

Research and Development Administration (ERDA). ERDA became part of the Department of 

Energy in 1977. This act encouraged development and the use of nuclear energy for the 

general welfare and the security of the United States. This act authorized the Nuclear 

Regulatory Commission to regulate and license fuel fabrication facilities that seek to receive, 

possess, use, or transfer special nuclear material. 

Attainment area: A region that meets the U.S. EPA National Ambient Air Quality Standards 

(NAAQS) for a criteria pollutant under the Clean Air Act. 

Autoclave: A strong, pressurized, steam-heated vessel, as for laboratory experiments, 

sterilization, or cooking. 

Background radiation: Radiation from: (1) naturally occurring radioactive materials, as they 

exist in nature prior to removal, transport, or enhancement or processing by man; (2) cosmic 

and natural terrestrial radiation; (3) global fallout as it exists in the environment; (4) consumer 

products containing nominal amounts of radioactive material or emitting nominal levels of 

radiation; and (5) radon and its progeny in concentrations or levels existing in buildings or the 

environment that have not been elevated as a result of current or past human activities. 

Baghouse: A large chamber or room for holding bag filters used to filter gas streams. 

Berms: A level space, shelf, or raised barrier separating two areas. 

Baseline: A quantitative expression of conditions, costs, schedule, or technical progress to 

serve as a base or standard for measurement during the performance of an effort; the 

established plan against which the status of resources and the progress of a project can be 

measured. 

Basin: A topographic or structurally low area or the area drained by a stream system. 

Basalt: A fine-grained dark igneous (volcanic) rock that is low in silica content and has 

congealed from a molten (magma) state. 
 10-3 

Best Management Practices (BMP): Structural, nonstructural, and managerial techniques 

recognized to be the most effective and practical means to reduce surface water and 

groundwater contamination while still allowing the productive use of resources. 

Beta particle: A charged particle emitted from a nucleus during radioactive decay, with a mass 

equal to 1/1837 that of a proton. A negatively charged beta particle is identical to an electron. 

A positively charged beta particle is called a positron. Large amounts of beta radiation may 

cause skin burns, and beta emitters are harmful if they enter the body. Beta particles may be 

stopped by thin sheets of metal or plastic. 

Bioassay analyses: A method for quantitatively determining the concentration of a substance 

by its effect on the growth of a suitable animal, plant, or microorganism under controlled 

conditions. 

Biomass: The dry mass of living matter, expressed in terms of a given area or volume. 

Bollard: A strong wooden or metal post mounted on a wharf, quay, etc. to protect the 

stationary structure from, and stop, a moving craft or vehicle. 

Boom: As used in this EIS, a temporary floating barrier launched on water to contain material 

such as an oil spill. 

Boron: Semi-metallic chemical element, with atomic number 5, which has the chemical 

symbol B. 

Bounding: That which represents the maximum reasonably foreseeable event or impact. All 

other reasonably foreseeable events or impacts would have fewer and/or less severe 

environmental consequences. 

Buffer area: A designated area of land that is designed to permanently remain vegetated in an 

undisturbed and natural condition in order to protect an adjacent aquatic or wetland site from 

upland impacts and to provide habitat for wildlife. 

Byproduct: A product from a manufacturing process that is not considered the principal 

material. 

Candidate species: A species of plants or animals considered as a candidate for possible 

listing as endangered or threatened by a government agency. 

Carbonaceous: Consisting of, containing, relating to, or yielding the element carbon (carbon is 

element with atomic number 6, and has the chemical symbol C). 

Carbon monoxide: An odorless, colorless, poisonous gas produced by incomplete burning of 

carbon in fuels. Exposure to carbon monoxide reduces the delivery of oxygen to the body's 

organs and tissues. Elevated levels can cause impairment of visual perception, manual 

dexterity, learning ability, and performance of complex tasks. 

Caliche: Calcium carbonate (chemical symbol CaCO3) deposited in the soils of arid or semiarid 

regions. 
 10-4 

Clarifier: A piece of equipment that removes suspended impurities or solid matter by settling, 

heating gently, or filtering. 

Clean Air Act: A Federal law that requires the EPA to set and enforce air pollutant emissions 

standards for stationary sources and motor vehicles. 

Climatology: The science devoted to the study, over time, of the conditions of the natural 

environment (rainfall, daylight, temperature, humidity, air movement) prevailing in specific 

regions of the earth. 

Code of Federal Regulations (CFR): All Federal regulations in force are published in codified 

form in the Code of Federal Regulations. 

Coke: The solid residue of impure carbon obtained from bituminous coal and other 

carbonaceous materials after removal of volatile material by destructive distillation. 

Cold traps: A device that condenses all vapors except the permanent gases into a liquid or 

solid. 

Committed dose equivalent: The predicted dose equivalent to a tissue or organ over a 50-

year period after an intake of a radionuclide into the body. It does not include dose 

contributions from radiation sources external to the body. Committed dose equivalent is 

expressed in units of rem (or sievert) (1 rem = 0.01 sievert). 

Committed effective dose equivalent: The sum of the committed dose equivalents to various 

organs or tissues in the body from radioactive material taken into the body, each multiplied by 

the tissue-specific weighting factor. Committed effective dose equivalent is expressed in units 

of rem (or sievert). 

Community: A group of people (or animals) within a defined area that could be exposed to 

health risks from industrial pollutants or disturbed by noise, dust, and traffic associated with 

development of an industrial facility but that could also benefit from improved employment 

opportunities, higher land values, and infrastructure improvements associated with the project. 

Concentration: The amount of a substance contained in a unit quantity (mass or volume) of a 

sample. 

Conservative: When used with predictions or estimates, leaning on the side of pessimism. A 

conservative estimate is one in which the uncertain inputs are used in the way that provides a 

reasonable upper limit of the estimate of an impact. 

Containment: Retention of a material or substance within prescribed boundaries. 

Contamination: The presence of an unwanted chemical or radiological constituent in or on a 

material, person, property, or structure. 

Cooling water: Water circulated through a nuclear reactor or processing plant to remove heat. 

Cost-benefit analysis: A formal quantitative procedure comparing costs and benefits of a 

proposed project or act under a set of pre-established rules. 
 10-5 

Council on Environmental Quality: The President’s Council on Environmental Quality (CEQ) 

was established by the enactment of National Environmental Policy Act (NEPA). The CEQ is 

responsible for developing regulations to be followed by all Federal agencies in developing and 

implementing their own specific NEPA implementation policies and procedures. 

Criteria pollutants: Six pollutants (ozone, carbon monoxide, total suspended particulates, 

sulfur dioxide, lead, and nitrogen oxide) known to be hazardous to human health and for which 

the EPA sets National Ambient Air Quality Standards under the Clean Air Act. 

Critical habitat: The specific areas within the geographical area occupied by a species at the 

time it is listed as threatened or endangered on which are found those physical or biological 

features that are essential to the conservation of the species and that may require special 

management considerations or protection. It also includes specific areas outside the 

geographical area occupied by the species at the time it is listed if these areas are determined 

to be essential for the conservation of the species. 

Cryogenic: Of, or relating to low temperatures; or requiring low temperatures for storage. 

Cultural resources: Archaeological sites, architectural features, traditional use areas, and 

Native American sacred sites or special use areas. 

Cumulative impacts: Cumulative impacts are those impacts on the environment that result 

from the incremental impact of the action when added to other past, present, and reasonably 

foreseeable future actions regardless of what agency (Federal or non-Federal) or person 

undertakes such other actions. Cumulative impacts can result from individually minor but 

collectively significant actions taking place over a period of time. 

Curie: A unit of radioactivity equal to 37 billion (3.7 x 1010) disintegrations per second. 

Daughter products: The remaining nuclide left over from radioactive decay. 

Decibel (dB): A standard unit for measuring sound-pressure levels based on a reference 

sound pressure of 0.0002 dyne per square centimeter. This is the smallest sound a human can 

hear. In general, a sound doubles in loudness with every increase of slightly more than 3 

decibels. 

Deciduous: Falling off at maturity or tending to fall off and is typically used in reference to trees 

or shrubs that lose their leaves seasonally. 

Decommissioning: The removal of a facility from active service. 

Decontamination: The reduction or removal of an unwanted chemical or radiological 

constituent from a structure, area, object, or person. Decontamination of radiological 

contamination may be accomplished by (1) treating the surface to remove or decrease the 

contamination, (2) letting the material stand so that the radioactivity is decreased as a result of 

natural radioactive decay, or (3) covering the contamination to shield or attenuate the radiation 

emitted. 

Deconversion: As used in this EIS, the process by which uranium hexafluoride (UF6) is 

chemically converted to uranium oxide (UO2) producing anhydrous hydrogen fluoride (HF) and 

other marketable fluoride byproducts. 
 10-6 

Degradation: The process by which organic substances are broken down by living organisms. 

Delaware Basin: An area in southeastern New Mexico and the adjacent parts of Texas where 

the Permian sea deposited a large thickness of evaporites some 220 to 280 million years ago. 

It is partially surrounded by the Capitan Reef. 

Depleted uranium: Uranium having a percentage of uranium-235 smaller than the 0.7 percent 

found in natural uranium. In the context of this EIS, it is the residue or tails from the uranium 

enrichment process. 

Depleted uranium hexafluoride (DUF6): A compound of uranium and fluorine from which 

most of the uranium-235 isotope has been removed. 

Diffusion: Movement of atoms, ions, or molecules of one substance into or through another as 

a result of thermal or concentration gradients. 

Dike: A barrier (typically, an embankment for controlling or holding back water; or, in geology, a 

type of sheet intrusion that cuts discordantly across the geologic body). 

Dispersion: The occurrence in which particles are dispersed in air, water, soil, or other another 

medium. 

Dose equivalent: The product of absorbed dose in rad (or gray) in tissue and a quality factor. 

Dose equivalent is expressed in units of rem (or sievert). 

Dose rate: The radiation dose delivered per unit time (e.g., rem per hour). 

Ecology: The science dealing with the relationship of all living things with each other and with 

the environment. 

Ecoregion: A classification of land based on similar climate, vegetation, and topography. 

Effective dose equivalent: The sum of the products of the dose equivalent received by 

specified organs or tissues of the body and a tissue-specific weighting factor. The effective 

dose equivalent is expressed in units of rem (or sievert). 

Effluent: A gas or fluid discharged into the environment, treated or untreated. Most frequently, 

the term applies to wastes discharged to surface waters. 

EIS: Environmental impact statement; a document required by the National Environmental 

Policy Act for proposed major Federal actions involving potentially significant environmental 

impacts. 

Emissions: Substances that are discharged into the air. 

Endangered species: Plants and animals that are threatened with extinction, serious 

depletion, or destruction of critical habitat. Requirements for declaring a species endangered 

are contained in the Endangered Species Act. 

Endangered Species Act of 1973: An act requiring Federal agencies, with the consultation 

and assistance of the Secretaries of the Interior and Commerce, to ensure that their actions will 
 10-7 

not likely jeopardize the continued existence of any endangered or threatened species or 

adversely affect the habitat of such species. 

Enrichment (process): Increasing the concentration of the uranium isotope U235 to more than 

that which exists in natural uranium ore, for use in atomic energy. 

Environment: The sum of all external conditions and influences affecting the life development 

and, ultimately, the survival of an organism. 

Environmental justice: The fair treatment of people of all races, cultures, incomes, and 

educational levels with respect to the development, implementation, and enforcement of 

environmental laws, regulations, and policies. Fair treatment implies that no population of 

people should be forced to shoulder a disproportionate share of the negative environmental 

impacts of pollution or environmental hazards due to a lack of political or economic strength. 

Environmental monitoring: The act of measuring, either continuously or periodically, some 

quantity of interest, such as radioactive material in the air. 

Ephemeral stream: A stream channel that carries water only during part of the year, 

immediately after periods of rainfall or snowmelt. 

Equilibrium: A state of rest in a chemical or mechanical system. 

ER: Environmental Report required as part of an environmental assessment, which identifies, 

describes and evaluates the likely significant effects on the environment of implementing a plan 

or program. 

Erosion: Removal and transport of materials by wind, ice, or water on the earth’s surface. 

Escarpment: A long, nearly continuous cliff or relatively steep slope facing in one general 

direction, breaking the continuity of the land by separating two level or gently sloping surfaces, 

and produced by erosion or faulting. 

Exposure limit: The level of exposure to a hazardous chemical (set by law or a standard) at 

which or below which adverse human health effects are not expected to occur. 

Exposure pathways: A route or sequence of processes by which a radioactive or hazardous 

material may move through the environment to humans or other organisms. Each exposure 

pathway includes a source or release from a source, an exposure point, and an exposure route. 

Fault: A fracture or a zone of fractures along which there has been displacement parallel to the 

fracture. 

Fauna: The animal life of any particular region or time. 

Floodplain: Low-lying areas adjacent to rivers and streams that are subject to natural 

inundations typically associated with precipitation. 

Flora: The plant life occurring in a particular region, generally the naturally occurring or 

indigenous plant life. 

Fluorocarbon: A halocarbon in which some hydrogen atoms have been replaced with fluorine. 
 10-8 

Fluorine: The chemical element with atomic number 9, represented by the chemical symbol F. 

Formation: A mapable geologic body of rock identified by lithic characteristics and stratigraphic 

position. Formations may be combined into groups or subdivided into members. 

Fuel cycle: The series of steps involved in supplying fuel for nuclear power reactors. It can 

include mining, milling, isotopic enrichment, fabrication of fuel elements, use in a reactor, 

chemical reprocessing to recover the fissionable material remaining in the spent fuel, 

re-enrichment of the fuel material, re-fabrication into new fuel elements, and waste disposal. 

Fugitive dust: Any solid particulate matter (PM) that becomes airborne, other than that emitted 

from an exhaust stack, directly or indirectly as a result of the activities of man. Fugitive dust 

may include emission from haul roads, wind erosion of exposed soil surfaces, and other 

activities in which soil is either removed or distorted. 

Gamma: Short-wavelength electromagnetic radiation (high-energy photons) emitted In the 

radioactive decay of certain nuclides. Gammas are the same as gamma rays or gamma waves. 

Gaussian plume: The distribution of material (a plume) in the atmosphere resulting from the 

release of pollutants from a stack or other source. The distribution of concentrations about the 

centerline of the plume, which is assumed to decrease as a function of its distance from the 

source and centerline (Gaussian distribution), depends on the mean wind speed and 

atmospheric stability. 

Geology: The science that deals with the earth; the materials, processes, environments, and 

history of the planet, especially the lithosphere, including the rocks, their formation, and 

structure. 

Geology and Soils: Those Earth resources that may be described in terms of landforms, 

geology, and soil conditions. 

Greenhouse gas: A gas in an atmosphere that absorbs and emits radiation within the thermal 

infrared range. 

Gross beta: The total rate of emission of beta particles from a sample, without regard to 

energy distributions or source nuclides. 

Groundwater: All subsurface water, especially that contained in the saturated zone below the 

water table. 

Habitat: The part of the physical environment in which a plant or animal lives. 

Hazardous chemical: Under 29 CFR 1910, Subpart Z, "hazardous chemicals" are defined as 

"any chemical, which is a physical hazard or a health hazard." Physical hazards include 

combustible liquids, compressed gases, explosives, flammables, organic peroxides, oxidizers, 

pyrophorics, and reactives. A chemical is a health hazard when there is good evidence that 

acute or chronic health effects occur in exposed individuals. Hazardous chemicals include 

carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, 

hepatotoxins, nephrotoxins, agents that act on the hematopoietic system, and agents that 

damage the lungs, skin, eyes or mucous membranes. 
 10-9 

Hazardous waste: According to the Resource Conservation and Recovery Act, a waste that, 

because of its characteristics, may (1) cause or significantly contribute to an increase in 

mortality or an increase in serious irreversible illness, or (2) pose a substantial hazard to human 

health or the environment when improperly treated, stored, transported, disposed of, or 

otherwise managed. Hazardous wastes possess at least one of the following characteristics: 

ignitability, corrosivity, reactivity, or toxicity. Hazardous waste is nonradioactive. 

Historic Resources: The sites, districts, structures, and objects associated with historic 

events, persons, or social or historic movements. 

Historic and Cultural Resources: Cultural resources include any prehistoric or historic district, 

site, building, structure, or object resulting from, or modified by, human activity. Historic 

properties are cultural resources listed in, or eligible for listing in, the National Register of 

Historic Places. 

Homogenous: Describing a substance or population with uniform composition. 

Hopper: A (usually funnel-shaped) container in which materials, such as chemicals, are stored 

in readiness for dispensing. 

Hydraulic conductivity: A quantity that describes the rate at which water flows through an 

aquifer. It has units of length/time and is equal to the hydraulic transmissivity divided by the 

thickness of the aquifer. 

Hydrofluorocarbons: An organic chemical containing hydrogen, fluorine, and carbon; emitted 

as a byproduct of industrial manufacturing. 

Hydroperiod: The number of days per year that an area of land is inundated with water; or the 

length of time that there is standing water at a location. 

Indirect jobs: Jobs generated or lost in related industries within a regional economic area as a 

result of a change in direct employment. 

Ingestion: To take in by mouth. Material that is ingested enters the digestive system. 

Inhalation: To take in by breathing. Material that is inhaled enters the lungs. 

Integrated Safety Analysis (ISA): A formalized and documented process that identifies 

potential accident sequences in a plant's operations, designates items relied on for safety to 

either prevent such accidents or mitigate their consequences to an acceptable level, and 

describes management measures to provide reasonable assurance of the availability and 

reliability of items relied on for safety. 

Intermittent: As used in this EIS, a drainage feature that contains water for only part of the 

year, typically during wet seasons. An intermittent stream often lacks the biological and 

hydrological characteristics commonly associated with the conveyance of water. 

Ionizing radiation: Radiation capable of displacing electrons from atoms or molecules to 

produce ions. 
 10-10 

Isotope: An atom of a chemical element with a specific atomic number and atomic weight. 

Isotopes of the same element have the same number of protons but different numbers of 

neutrons. Isotopes are identified by the name of the element and the total number of protons 

and neutrons in the nucleus. For example, uranium-235 is an isotope of uranium with 92 

protons and 143 neutrons and uranium-238 is an isotope of uranium with 92 protons and 146 

neutrons. 

Kilovolt (kV): A unit of electrical potential equal to a thousand volts. 

Kilovolt-ampere (kVA): A unit of electrical power equal to 1000 volt-amperes. 

Land use: The way land is developed and used in terms of the kinds of anthropogenic 

activities that occur (e.g., agriculture, residential areas, industrial areas). 

Latent cancer fatalities (LCFs): Deaths resulting from cancer that has become active after a 

latent period following radiation exposure. For radiation exposure, latent cancer fatalities can be 

calculated from collective dose using the risk conversion factor of 6x10-4 LCFs per person rem. 

Lithic: Made of stone. 

Load factor: The ratio of the average electric load to the peak load over a period of time. 

Loam: A rich, friable soil containing a relatively equal mixture of sand and silt, clay, and 

humus. 

Low-level mixed waste: Low-level radioactive waste that also contains hazardous chemical 

components regulated under the Resource Conservation and Recovery Act. 

Low-level radioactive waste: Wastes containing source, special nuclear, or by-product 

material are acceptable for disposal in a land disposal facility. For the purposes of this 

definition, low-level waste has the same meaning as in the Low-Level Radioactive Waste Policy 

Act, that is, radioactive waste not classified as high-level radioactive waste, transuranic waste, 

spent nuclear fuel, or by-product material as defined in section 11e.(2) of the Atomic Energy Act 

(uranium or thorium tailings and waste). 

Low-income population: A population where 25 percent or more of the population is identified 

as living in poverty. 

Magnitude (earthquake): A measure of the total energy released by an earthquake. It is 

commonly measured in numerical units on the Richter scale. Each unit is different from an 

adjacent unit by a factor of 30. 

Maim: To injure, disable or disfigure, usually by depriving of the use of a limb or other part of 

the body. 

Maximally exposed individual (MEI): A hypothetical person who—because of proximity, 

activities, or living habits—could receive the highest possible dose of radiation or of a hazardous 

chemical from a given event or process. 

Meteorological tower: An individual data acquisition point for weather and air related 

information (e.g., wind speed, wind direction, precipitation, opacity, etc.) 
 10-11 

Meteorology: The science dealing with the atmosphere and its phenomena, especially as 

relating to weather. 

Migration: The natural travel of a material through the air, soil, or groundwater. 

Millirem (mrem): One thousandth of a rem (0.001 rem). 

Mitigation: An action or actions implemented to lessen or alleviate impacts to a resource from 

a proposed action or activity. The purpose of mitigative actions is to avoid, minimize, rectify, or 

compensate for any adverse environmental impact. 

Mixed waste: Waste that contains both "hazardous waste" and "radioactive waste" as defined 

in this glossary. 

Modified Mercalli Intensity: A measurement of earthquake intensity based on the effects to 

people and structures. Ranges from I (low) to XII (total destruction), as opposed to the Richter 

scale, which measures the energy of the earthquake. Mercalli scale is often used to classify 

earthquakes that were not recorded on modern seismographs. 

National Ambient Air Quality Standards (NAAQS): Air quality standards established by the 

Clean Air Act, as amended. The primary NAAQS are intended to protect the public health with 

an adequate margin of safety, and the secondary NAAQS are intended to protect the public 

welfare from any known or anticipated adverse effects of a pollutant. 

National Emission Standards for Hazardous Air Pollutants (NESHAP): Emission standards 

for the control of releases of specified hazardous air pollutants, including radionuclides. These 

were implemented in the Clean Air Act Amendments of 1977. 

National Environmental Policy Act (NEPA) of 1969: A Federal law constituting the basic 

national charter for protection of the environment. The act calls for the preparation of an 

environmental impact statement (EIS) for every major Federal action that may significantly 

affect the quality of the human or natural environment. The main purpose is to ensure that 

environmental information is provided to decision makers so that their actions are based on an 

understanding of the potential environmental and socioeconomic consequences of a proposed 

action and the reasonable alternatives. 

National Historic Preservation Act (NHPA): A Federal law providing that property resources 

with significant national historic value be placed on the National Register of Historic Places. It 

does not require permits; rather, it mandates consultation with the proper agencies whenever it 

is determined that a proposed action might impact a historic property. 

National Pollutant Discharge Elimination System (NPDES): Federal permitting system 

mandated by the Clean Water Act required for any discharges to waters of the United States. 

National Register of Historic Places: A list maintained by the National Park Service of 

architectural, historic, archaeological, and cultural sites of local, state, or national importance. 

Native vegetation: Plants that have evolved in a particular region and environment. 

Nocturnal: Of, relating to, or occurring in the night. 
 10-12 

Nonattainment areas: An area that has been designated by the EPA, or the appropriate State 

air quality agency, as exceeding one or more national or State Ambient Air Quality Standards. 

Nonferrous: Not composed of or containing iron. 

NOx : Oxides of nitrogen, primarily nitrogen oxide and nitrogen dioxide. These are produced 

primarily by combustion of fossil fuels, and can constitute an air pollution problem. 

Offgas treatment: An array of technologies to discharge, collect (filter), or destroy (catalyze, 

react, or combust) the vapors removed from soils or other media. 

Order of magnitude: A multiple of ten. When a measurement is made with a result such as 

3 x 107

, the exponent of 10 is the order of magnitude of that measurement. To say that this 

result is known to within an order of magnitude is to say that the true value lies between 3 x 106

and 3 x 108. 

Organic compounds: Of or designating carbon compounds. (Some simple compounds of 

carbon, such as carbon dioxide, are frequently classified as inorganic compounds.) 

Oxide: A compound consisting of an element combined with oxygen. 

Ozone: A molecule of oxygen in which three oxygen atoms are chemically attached to each 

other. 

Package: In the regulations governing the transportation of radioactive materials, the 

packaging together with its radioactive contents as presented for transport. 

Packaging: A shipping container without its contents. 

Particulate matter: Materials such as dust, dirt, soot, smoke, and liquid droplets that are 

emitted into the air by sources such as factories, power plants, automobiles, construction 

activity, fires, and naturally by wind. 

Peak ground acceleration: The maximum acceleration experienced by the particle on the 

ground during the course of the earthquake motion. 

Permeability: The capability of a soil or rock to transmit a fluid. 

Perennial: A drainage feature that contains water year-round during a year of normal rainfall. 

A perennial stream exhibits the typical biological, hydrological, and physical characteristics 

commonly associated with the continuous conveyance of water. 

Personnel monitoring: The use of portable survey meters to determine the amount of 

radioactive contamination on individuals; or, the use of dosimetry to determine an individual's 

occupational radiation dose. 

Person-rem: A measure of the radiation dose to a given population; the sum of the individual 

radiation doses received by that population. 

pH: A measure of the hydrogen ion concentration in aqueous solution. Pure water has a pH of 

7, acidic solutions have a pH less than 7, and alkaline solutions have a pH greater than 7. 
 10-13 

Photosynthesis: The process in green plants and certain other organisms by which 

carbohydrates are synthesized from carbon dioxide and water using light as an energy source. 

Physiographic: Geographic regions based on geologic setting. 

Playa lake: A temporary lake, or its dry often salty bed, in a desert basin. 

Plume: The elongated pattern of contaminated air or water originating at a point source, such 

as a smokestack or a hazardous waste disposal site. 

PM10 : Particulate matter with a 10-micron (micrometer, μm) or less aerodynamic diameter. 

PM10 includes PM2.5. 

PM2.5: Particulate matter with aerodynamic diameter of 2.5 micron or less. Since it is very 

small, PM2.5 is important because it can be inhaled deep into the lungs. 

Point source: A source of effluents that is readily identifiable and can be treated as if it were a 

point. This includes stacks, pipes, conduits, and tanks. A point source can be either a 

continuous source or a source that emits effluents only intermittently. 

Pollutant: Any material entering the environment that has undesired effects. 

Pollution: The addition of an undesirable agent to the environment in excess of the rate at 

which natural processes can degrade, assimilate, or disperse it. 

Population dose: The sum of the radiation doses received by the individual members of a 

population. 

Porosity: Percentage of void space in a material. 

Potable water: Water that is safe for human consumption. 

Potash: A potassium compound often used in agriculture and industry. 

Prehistoric: Predating written history, in North America, also predating contact with 

Europeans. 

Production well: A well used to retrieve water, petroleum, or gas from underground. 

Purge gas: Inert gases used in chemical processes to flush a system of other gases. 

Quaternary: Noting or pertaining to the present period of Earth’s history, forming the latter part 

of the Cenozoic era, originating about 2 million years ago and including the Recent and 

Pleistocene epochs. 

Radiation: Ionizing radiation; e.g., alpha particles, beta particles, gamma rays, X-rays, 

neutrons, protons, and other particles capable of producing ion pairs in matter. As used in this 

document, radiation does not include nonionizing radiation. 

Radiation standards: Exposure standards, permissible concentrations, rules for safe handling, 

regulations for transportation, regulations for industrial control of radiation, and control of 

radioactive material by legislative means. 
 10-14 

Radioactive waste: Materials from nuclear operations that are radioactive or are contaminated 

with radioactive materials and for which there is no practical use or for which recovery is 

impractical. 

Radioactivity: The property or characteristic of radioactive material to undergo spontaneous 

transformations (“disintegrations” or “decay”) with the emission of energy in the form of 

radiation. It means the rate of spontaneous transformations of a radionuclide. The unit of 

radioactivity is the curie (or becquerel). (1 curie = 3.7 x 1010 becquerel). 

Radionuclide: A nuclide that emits radiation by spontaneous transformation. 

Radon: A colorless, radioactive, inert gaseous element formed by the radioactive decay of 

radium. 

Reactant: A substance participating in a chemical reaction, especially a directly reacting 

substance present at the initiation of the reaction. 

Recharge: The downward vertical flow of groundwater to an aquifer. Recharge may be from 

seepage through the unsaturated zone (for unconfined aquifers) or downward flow from 

overlying layers (for confined aquifers). 

Region of influence (ROI): The physical area that bounds the environmental, sociological, 

economic, or cultural features of interest for the purpose of impact analysis. A site-specific 

geographic area that includes the counties where approximately 90 percent of the site’s current 

employees reside. 

Rem: A common (or special) unit of dose equivalent, effective dose equivalent, or committed 

dose equivalent. 

Resource Conservation and Recovery Act (RCRA): This Act was designed to provide 

“cradle to grave” control of hazardous chemical wastes. 

Restricted area: Any area to which access is controlled for the protection of individuals from 

exposure to radiation and radioactive materials. 

Riparian: Associated with stream banks or margins. 

Risk: The likelihood of suffering a detrimental effect as a result of exposure to a hazard. In 

accident analysis, the probability weighted consequence of an accident, defined as the accident 

frequency per year multiplied by the consequence. 

Risk assessment (chemical or radiological): The qualitative and quantitative evaluation 

performed in an effort to define the risk posed to human health and/or the environment by the 

presence or potential presence and/or use of specific chemical or radiological materials. 

Rotary calciner: An industrial processing kiln or oven and a drum using indirect heating and 

mixing. 

Runoff: The portion of rainfall that is not absorbed by soil, evaporated, or transpired by plants, 

but finds its way into streams directly or as overland surface flows. 
 10-15 

Sanitary/industrial waste: Nonhazardous, nonradioactive liquid and solid waste generated by 

normal housekeeping activities. 

Scrubber: An apparatus for purifying a gas. 

Sediment: Eroded soil particles that are deposited downhill or downstream by surface runoff. 

Seismic: Pertaining to any earth vibration, especially an earthquake. 

Seismicity: All of the earthquakes that may occur in a region, regardless of magnitude. 

Semi-conductor: Any of various solid crystalline substances having electrical conductivity 

greater than insulators but less than good conductors. 

Shielding: Any material or obstruction that absorbs radiation and thus tends to protect 

personnel or materials from the effects of ionizing radiation. 

Sievert (Sv): A unit of radiation dose used to express a quantity called equivalent dose. This 

relates the absorbed dose in human tissue to the effective biological damage of the radiation by 

taking into account the kind of radiation received, the total amount absorbed by the body, and 

the tissues involved. Not all radiation has the same biological effect, even for the same amount 

of absorbed dose. One sievert is equivalent to 100 rem. 

Silicon: A nonmetallic element occurring extensively in the earth’s crust in silica and silicates. 

Silt: A sedimentary material consisting of fine mineral particles intermediate in size between 

sand and clay. 

Sink: A natural or artificial means of absorbing or removing a substance or a form of energy 

from a system. 

Slurry pump: A machine composed of an impeller, casing, shaft/bearing assembly, shaft seal 

and sleeve, and drive; to increase the pressure of a liquid and solids mixture (slurry) through 

rotational/centrifugal force and convert electrical energy into kinetic energy; which drives the 

mixture from one location to another. 

Soil association unit: A landscape or soil grouping that has a distinctive proportional pattern 

of soils; it normally consists of one or more major soils and at least one minor soil, and is named 

for the major soil(s). 

Solidification: To make solid, compact, or hard. 

Source material: Uranium or thorium ores containing 0.05 percent uranium or thorium 

regulated under the Atomic Energy Act. In general, this includes all materials containing 

radioactive isotopes in concentrations greater than natural and the by-product (tailings) from the 

formation of these concentrated materials 

Source term: The kinds and amounts of radionuclides in an assumed release of radioactive 

material. 
 10-16 

State Historic Preservation Officer (SHPO): The State officer charged with the identification 

and protection of prehistoric and historic resources in accordance with the National Historic 

Preservation Act. 

Stormwater: The flow of water that results from precipitation and that occurs immediately 

following rainfall or as a result of snowmelt. 

Subcritical: Incapable of sustaining a nuclear fission chain reaction. 

Succulents: Having thick, fleshy, water-absorbing leaves or stems. 

Sumps: A hole at the lowest point of a building or facility into which water is drained in order to 

be pumped out.

Surface water: A creek, stream, river, pond, lake, bay, sea, or other waterway that is directly 

exposed to the atmosphere. 

Surge tank: A tank used to absorb surges in flow. 

Tails: In the uranium enrichment process, tails refers to uranium hexafluoride with a reduced 

concentration of the uranium-235 isotope. 

Tectonic activity: Movement of the earth’s crust, produced by internal forces, such as uplift, 

subsidence, folding, faulting, and seismic activity. 

Teragram: 1012 grams or a million metric tons ("tera" represents a factor of 1012). 

Terrestrial: Living or growing on land; not aquatic. 

Tertiary: The first period of the Cenozoic era (after the Cretaceous period of the Mesozoic era 

and before the Quaternary period), thought to have covered the span of time between 65 million 

years and 3 to 2 million years ago. The Tertiary period is divided into five epochs: the 

Paleocene, Eocene, Oligocene, Miocene, and Pliocene. 

Threatened Species: Any species likely to become an endangered species within the 

foreseeable future throughout all or a significant portion of its range. Requirements for declaring 

a species threatened are contained in the Endangered Species Act. 

Title V: Title V of the 1990 Clean Air Act Amendments requires all major sources and some 

minor sources of air pollution to obtain an operating permit. A title V permit grants a source 

permission to operate. The permit includes all air pollution requirements that apply to the 

source, including emission limits and monitoring, record keeping, and reporting requirements. It 

also requires that the source report its compliance status with respect to permit conditions to the 

permitting authority. 

Topography: The shape of Earth’s surface or the geometry of landforms in a geographic area. 

Top soil: The fertile, surface portion of a soil; usually dark colored and rich in organic material. 

Total effective dose equivalent (TEDE): The sum of the effective dose equivalent from 

radiation sources external to the body during the year plus the committed effective dose 
 10-17 

equivalent from radionuclides taken into the body. A 50-year time interval is assumed for 

determining committed dose. 

Toxic Substances Control Act (TSCA): A Federal law authorizing the U.S. Environmental 

Protection Agency to secure information on all new and existing chemical substances and to 

control any of these substances determined to cause unreasonable risk to public health or the 

environment. This law requires that the health and environmental effects of all new chemicals 

be reviewed by the EPA before such chemicals are manufactured for commercial purposes. 

Transient species: Traveling nonresident, individuals of distinct animal species; migrating 

between seasonal breeding habitat, and overwintering or feeding habitat. 

Transuranic waste: Waste containing more than 100 nanocuries of alpha-emitting transuranic 

(atomic number greater than 92) isotopes per gram of waste with half-lives greater than 

20 years. 

Unconfined aquifer: An aquifer that is not confined by a less-permeable confining unit. An 

aquifer where the water table elevation represents the hydraulic potential. 

Unincorporated area: An area that is not located within the jurisdiction of any local 

government. Such unincorporated areas are governed and taxed by county-level government. 

Uranium: A radioactive element with the atomic number 92 and, as found in natural ores, an 

atomic weight of approximately 238. The two principal natural isotopes are uranium-235 

(0.7 percent of natural uranium), and uranium-238 (99.3 percent of natural uranium). Natural 

uranium also includes a minute amount of uranium-234. 

Viewscape: Those features which provide a range of sight that can be identified as providing a 

community asset such as, but not limited to, pleasing vistas, scenes and views that provide a 

sense of place and character. 

Viewshed: The area on the ground that is visible from a specific location. 

Venturi scrubber: A “wet” scrubber, using gas atomizing spray ejection technology to control 

fine (under 10 micrometers diameter) particulate matter. 

Volatile organic compound: Any compound containing carbon and hydrogen in combination 

with any other element that has a vapor pressure of 77.6 millimeters of mercury (1.5 pounds 

per square inch) absolute or greater under actual storage conditions. 

Waste management: The planning, coordination, and direction of functions related to 

generation, handling, treatment, storage, transportation, and disposal of waste. It also includes 

associated pollution prevention and surveillance and maintenance activities. 

Water deluge system: A sprinkler system employing open sprinklers that are attached to a 

piping system that is connected to a water supply through a valve that is opened by the 

operation of a detection system installed in the same areas as the sprinklers; when this valve 

opens, water flows into the piping system and discharges from all sprinklers attached thereto; 

deluge systems are used where large quantities of water are needed quickly to control a fastdeveloping fire; deluge valves can be electrically, pneumatically or hydraulically operated. 
 10-18 

Water resources: This term includes both freshwater and marine systems, wetlands, 

floodplains, and ground water. 

Wetlands: Land or areas exhibiting the following characteristics: hydric soil conditions; 

saturated or inundated soil during some part of the year and plant species tolerant of such 

conditions; also, areas that are inundated or saturated by surface or groundwater at a frequency 

and duration sufficient to support, under normal circumstances, a prevalence of vegetation 

typically adapted for life in saturated soil conditions. Wetlands generally include swamps, 

marshes, bogs, and similar areas. 

Wildlife corridor: An area of habitat connecting wildlife populations otherwise separated by 

human activities. 

Wind rose: A plot of wind direction and speed showing the distribution of directions that the 

wind blows from at a measurement site. The proportion of the time that a wind blows from any 

given direction is indicated by the length of the “petal” on the wind rose. 

Wind speed: The speed of air movement measured for a set height above ground level (agl) at 

a meteorological observing site. This height may vary depending on the location. Typically, 

anemometers at National Weather Service stations are placed at 32 ft 10 inches (10 m) agl; 

however, some are still found at 20 ft (6 m) agl. 
A-1 

APPENDIX A 

SCOPING SUMMARY 

A-3 

ENVIRONMENTAL IMPACT STATEMENT SCOPING 

PROCESS 

SCOPING SUMMARY REPORT 

PROPOSED INTERNATIONAL ISOTOPES FLUORINE 

PRODUCTS, INC. (IIFP) FLUORINE EXTRACTION PROCESS 

AND DEPLETED URANIUM DE-CONVERSION PLANT 

TO BE LOCATED IN LEA COUNTY, NEW MEXICO

 A-5 

A.1 INTRODUCTION 

On December 30, 2009, International Isotopes Fluorine Products, Inc. (IIFP) submitted an 

application to the U.S. Nuclear Regulatory Commission (NRC) for a license to construct and 

operate a proposed Fluorine Extraction Process (FEP) and Depleted Uranium De-conversion 

Plant (FEP/DUP) to be located at a site 22.5 kilometers (km) (14 miles [mi]) west of the City of 

Hobbs in Lea County, New Mexico. An Environmental Report was also submitted by IIFP at 

that time. If licensed, the FEP/DUP facility would be used for the deconversion of commerciallygenerated depleted uranium hexafluoride (DUF6) inventories into depleted uranium oxide and 

other deconversion products. 

In accordance with NRC regulations in Title 10 of the Code of Federal Regulations (10 CFR) 

Part 51 (10 CFR 51), which implement the National Environmental Policy Act of 1969, as 

amended (NEPA), the NRC staff is preparing an Environmental Impact Statement (EIS) for the 

proposed FEP/DUP facility as part of its decision-making process. The EIS will examine the 

potential environmental impacts associated with the proposed facility. The NRC staff has not 

identified any cooperating agencies for the preparation of this EIS. In addition to the EIS, the 

NRC staff will prepare a Safety Evaluation Report (SER) which will document the staff’s review 

of safety and security issues associated with the proposed facility. 

On July 15, 2010, NRC published in the Federal Register (FR) a Notice of Intent to prepare an 

EIS and to conduct the public scoping process (75 FR 41242). The public scoping comment 

period ended on August 30, 2010. Scoping is an early part of the NEPA process designed to 

help determine the range of actions, alternatives, and potential impacts to be considered in the 

EIS, and to identify significant issues related to the proposed action. In addition to the public 

scoping process, the NRC staff solicits input from State, local and other Federal agencies, and 

potentially affected Native American Tribes in order to focus on issues of genuine concern. 

On July 29, 2010, the NRC staff held a public scoping meeting in Hobbs, New Mexico, to 

receive oral and written comments from interested parties. The public scoping meeting began 

with NRC staff providing a description of the NRC’s roles, responsibilities, and mission. A brief 

overview of the licensing process was followed by a description of the environmental review 

process and a discussion of how the public can participate. The majority of the meeting was 

reserved for the public to ask questions and make comments on the scope of the environmental 

review. 

As part of the environmental review process, the NRC staff has requested information regarding 

the scope of its environmental review from several sources. The NRC staff initiated consultation 

with the New Mexico State Historic Preservation Officer (SHPO), in accordance with the 

procedures in 36 CFR 800 to meet the requirements of Section 106 of the National Historic 

Preservation Act. In accordance with 36 CFR 800.3(f), the NRC staff has requested information 

from Native American Tribal members identified by the SHPO and the NRC staff. The NRC 

staff has also consulted with representatives of the U.S. Fish and Wildlife Service (USFWS) as 

required by Section 7 of the Endangered Species Act. The National Park Service was 

contacted and indicated that no parks would be affected by the project. 

This scoping summary report addresses only comments received through the public scoping 

process and will be included as an Appendix of the EIS. Input from consulting agencies and 

potentially affected Native American Tribes will also be used as a basis for the impact 

assessments performed for each resource area. Correspondence with the SHPO and 

potentially-affected Native American Tribes are included in Appendix B of this EIS. 
 A-6 

Correspondence with the USFWS, the National Park Service, and New Mexico Environment 

Department (NMED) are also included in Appendix B of this EIS. 

This report has been prepared to summarize the comments received during the scoping 

process as required in 10 CFR 51.29(b). After publication of the draft EIS, the public will be 

invited to submit comments on the draft EIS. Availability of the draft EIS, the dates of the public 

comment period, and information about a public meeting to discuss the draft EIS will be 

announced in the Federal Register, on the NRC’s website (http://www.nrc.gov/publicinvolve.html), and in the local news media. After evaluating comments on the draft EIS, the 

NRC staff will issue a final EIS that will serve as the basis for the NRC’s consideration of 

potential environmental impacts in its decision on whether to license the proposed facility. 

This report is organized into four main sections. Section 1 provides an introduction and 

background information on the environmental review process. Section 2 summarizes the 

comments and concerns expressed by government officials, agencies, and the public. Section 

3 identifies the issues that the draft EIS will address and Section 4 describes those issues that 

are not within the scope of the draft EIS. Where appropriate, Section 4 also identifies other 

places in the decision-making process where issues that are outside the scope of the draft EIS 

may be considered. 

A.2 ISSUES RAISED DURING THE SCOPING PROCESS 

A.2.1 Overview 

The public scoping process is an important component in determining the major issues that the 

NRC staff should address in the draft EIS. The comments provided by the public addressed 

several subject areas related to the IIFP proposed facility and the development of the draft EIS. 

Members of the public were able to submit comments on the scope of the IIFP proposed facility 

draft EIS by e-mail, postal mail, and by speaking and/or submitting written comments at the 

public scoping meeting held in Hobbs, New Mexico, on July 29, 2010. The scoping period 

ended on August 30, 2010. 

Approximately 60 individuals not affiliated with the NRC staff attended the July 29, 2010, public 

scoping meeting in Hobbs, New Mexico. During the meeting, one individual asked a specific 

question about the licensing process. Ten individuals offered specific oral comments related to 

the proposed FEP/DUP facility. Including the comments received in the scoping meeting, a total 

of 28 oral and written comments were received from various individuals during the public 

scoping period, which ended on August 30, 2010. The scoping meeting transcript and the 

scoping comment letters received by the NRC are available on the NRC website, electronic 

reading room, at http://www.nrc.gov/reading-rm/adams/web-based.html. The ADAMS 

accession number for the scoping meeting transcript is ML102210424. 

In addition to private citizens, the commenters included: 

• A representative of Senator Tom Udall 

• A Lea County Commissioner 

• A Hobbs City Commissioner 

• The Mayors of the Cities of Hobbs and Eunice 

• The City Manager of Eunice 

• State Senator Carroll Leavell (Letter read on his behalf) 
 A-7 

Individuals providing oral and written comments addressed several subject areas related to the 

environmental review process of the proposed FEP/DUP facility. The following general topics 

categorize the comments received during the public scoping period: 

• General support or opposition 

• Socioeconomics 

• Waste Management 

• Water Resources 

• Geology and Seismicity 

• Transportation 

• Public and Occupational Health 

• Out of Scope 

In addition to raising issues about the potential environmental impacts of the proposed facility, 

some commenters offered opinions and concerns that typically would not be included in an EIS. 

Although noted by the NRC in this summary document, comments of this type are not within the 

scope of environmental issues to be analyzed. 

Other statements may be relevant to the proposed action, but have no direct bearing on the 

evaluation of alternatives or on the decision-making process regarding the proposed action. For 

instance, general statements of support for or opposition to the proposed action fall into this 

category. Comments of this type have been noted but are not used in defining the scope and 

content of the EIS. 

A.2.2 Summary of Issues Raised 

Several individuals provided comments regarding the beneficial potential socioeconomic 

impacts of the proposed facility on the local community. Other comments addressed potential 

impacts or risks posed by the facility due to seismic concerns, availability of water sources, 

transportation and disposal of waste, and possible health impacts associated with nuclear 

facilities. The following summary groups the comments received during the scoping period by 

technical area and issue. 

A.2.2.1 General Support or Opposition 

Several commenters expressed general support for the FEP/DUP facility. One commenter 

expressed opposition to locating the FEP/DUP facility, or any facility that deals with nuclear 

byproducts, in an area with a history of earthquakes and over an aquifer. 

A.2.2.2 Socioeconomics 

Three commenters expressed support for the project, specifically for the jobs that will be created 

by construction and operation of the facility and the positive economic impact it will have on the 

region. 

A.2.2.3 Waste Management 

Two commenters supported the project as a way to use uranium ‘tails’ that will be generated at 

the nearby URENCO USA uranium enrichment plant. One commenter stated that a disposal 
 A-8 

path for waste from the FEP/DUP facility to the Andrews County, Texas, nuclear waste disposal 

facility is an unsafe disposal path. This commenter also requested that the EIS include disposal 

site suitability requirements, as described in 10 CFR 61.50. 

A.2.2.4 Water Resources 

One commenter stated that the EIS should include the aquifer map that has been prepared by 

Mesa Water Company. The same commenter also stated that Lea County lacks an adequate 

water supply for a nuclear project. This commenter expressed concern about a site that may 

potentially be used for disposal of waste from the FEP/DUP facility being located over the 

Ogallala Aquifer. The commenter also stated that the water supply of Hobbs, Eunice, and Jal 

risks being polluted by allowing a nuclear project in the area. 

A.2.2.5 Geology and Seismicity 

One commenter stated that the EIS should include the seismic hazards that have been 

indicated for Lea County by the U.S. Geological Survey. This commenter also stated that the 

Lea County site should not have been selected due to its seismic history. The commenter also 

expressed concerns about possible contamination of the Ogallala Aquifer by nuclear waste 

released during an earthquake. 

A.2.2.6 Transportation 

One commenter expressed concerns about the transportation of waste from the facility in Lea 

County (New Mexico) to the Andrews County, Texas, nuclear waste disposal facility just across 

the state line. 

A.2.2.7 Public and Occupational Health 

One commenter submitted a New Mexico Department of Health report showing elevated cancer 

rates in Lea County compared to other parts of the state and stated concern that allowing 

nuclear industry in the area will raise cancer rates. 

A.2.2.8 Out of Scope 

One commenter stated that the New Mexico Environment Department’s denial of his request to 

set up offsite radiation monitors should be included in the EIS. One commenter stated that 

employees of various federal agencies should waive their liability immunity through the Federal 

Tort Claims Act and be fully liable for any damages, pollution to the water table, and loss of 

livelihood and health of Lea County citizens caused by any future earthquakes. 

A.3 SCOPE OF THE ENVIRONMENTAL IMPACT STATEMENT 

The NEPA (42 U.S.C. 4321, et seq., as amended), and the NRC’s implementing regulations for 

NEPA (10 CFR 51), specify in general terms what should be included in an EIS prepared by the 

NRC staff. Regulations established by the Council on Environmental Quality (40 CFR 1500-

1508), while not binding on the NRC, provide useful guidance. Additional guidance for meeting 

NEPA requirements associated with licensing actions can be found in NUREG-1748, 

“Environmental Review Guidance for Licensing Actions Associated with NMSS Programs.” 
 A-9 

Pursuant to 10 CFR 51.71(a), in addition to public comments received during the scoping 

process, the EIS will also consider matters discussed in the IIFP Environmental Report. In 

accordance with 10 CFR 51.71(b), the EIS will consider major points of view and objections 

concerning the environmental impacts of the proposed action raised by other Federal, State, 

and local agencies, by any affected Indian Tribes/Pueblos, and by other interested persons. 

Pursuant to 10 CFR 51.71(c), the EIS will list all Federal permits, licenses, approvals, and other 

entitlements that must be obtained in implementing the proposed action, and will describe the 

status of compliance with these requirements. Any uncertainty as to the applicability of these 

requirements will be addressed in the EIS. 

In accordance with 10 CFR 51.71(d), the draft EIS will include a preliminary analysis that 

considers and weighs the environmental effects of the proposed action, the environmental 

impacts of the alternatives to the proposed action, and alternatives available for reducing or 

avoiding adverse environmental effects. In the analysis, due consideration will be given to 

compliance with environmental quality standards and regulations that have been imposed by 

Federal, State, regional, and local agencies having responsibilities for environmental 

protections. The environmental impact of the proposed action will be evaluated in the EIS with 

respect to matters covered by such standards and requirements, regardless of whether a 

certification or license from the appropriate authority has been obtained. Compliance with 

applicable environmental quality standards and requirements does not negate the requirement 

for the NRC to weigh all environmental effects of the proposed action, including the degradation, 

if any, of water quality, and to consider alternatives to the proposed action that are available for 

reducing adverse effects. 

While satisfaction of the NRC standards and criteria pertaining to radiological effects is 

necessary to meet the licensing requirements of the Atomic Energy Act, the EIS will also, for the 

purposes of NEPA, consider the radiological and nonradiological effects of the proposed action 

and alternatives. The development of the EIS is closely coordinated with the SER prepared by 

the NRC staff to evaluate the potential health and safety impacts of the proposed action. The 

EIS will also contain a discussion of the potential cumulative impacts of the proposed action. 

Pursuant to 10 CFR 51.71(f), the draft EIS will include a preliminary recommendation by the 

NRC staff with respect to the proposed action. Any such recommendation 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. 

One goal in writing the EIS is to present the impact analyses in a manner that makes it easy for 

the public to understand. This EIS will provide the basis for the NRC decision with regard to 

potential environmental impacts. Those resources with potential significant impacts will be 

discussed in greater detail in the EIS than resources with potential minor or no impacts. This 

should allow readers of the EIS to focus on issues that were determined to be important in 

reaching the conclusions supported by the EIS. The following topical areas and issues will be 

addressed in the EIS. 

Alternatives. The EIS will describe and assess the no-action alternative and other reasonable 

alternatives to the proposed action. Other alternatives may include alternative sites or 

alternative processes to the proposed chemical process. 

Need for the Facility. The EIS will provide a discussion of the need for the proposed FEP/DUP 

facility. 
 A-10 

Compliance with Applicable Regulations. The EIS will list relevant permits and regulations that 

apply to the proposed FEP/DUP facility. These include air, water, and solid waste disposal 

permits. 

Land Use. The EIS will discuss the potential land use impacts associated with the proposed 

site preparation, construction, and operating activities. As appropriate, the assessment will 

include an analysis of mitigation measures to address potential adverse impacts. 

Transportation. The EIS will discuss the potential impacts associated with the transportation of 

the construction materials, feed material, product, and waste during both normal transportation 

and under credible accident scenarios. The potential impacts on local transportation routes due 

to workers, delivery vehicles, and waste removal vehicles will be evaluated. As appropriate, the 

assessment will include an analysis of mitigation measures to address potential adverse 

impacts. 

Geology and Soils. The EIS will assess the potential impacts to the geology and soils of the 

proposed FEP/DUP facility. The potential for earthquakes or any other major ground motion 

considerations will be addressed in the SER and potential environmental impacts of those 

phenomena will be evaluated in the EIS. As appropriate, the assessment will include an 

analysis of mitigation measures to address potential adverse impacts. 

Water Resources. The EIS will assess the potential impacts on surface water and groundwater 

quality and water use due to the proposed action. As appropriate, the assessment will include 

an analysis of mitigation measures to address potential adverse impacts. 

Ecological Resources. The EIS will assess the potential environmental impacts on ecological 

resources, including plant and animal species. Threatened and endangered species and critical 

habitats that may occur in the area will be discussed. The outcomes of consultations with 

resource protection agencies, as required by Section 7 of the Endangered Species Act of 1973 

(16 U.S.C. Section 1536(a)(2)), will be discussed. As appropriate, the assessment will include 

an analysis of mitigation measures to address potential adverse impacts. 

Air Quality. The EIS will make determinations concerning the meteorological conditions of the 

site location, the ambient air quality, the contributions of other sources to air quality, and the 

potential impacts of site preparation, construction, and operation of the proposed FEP/DUP 

facility on local air quality. In addition, the EIS will consider the impact of the proposed facility 

on climate change. As appropriate, the assessment will include an analysis of mitigation 

measures to address potential adverse impacts. 

Noise. The EIS will discuss the potential impacts associated with noise from site preparation, 

construction, operation, and decommissioning of the proposed FEP/DUP facility. As 

appropriate, the assessment will include an analysis of mitigation measures to address potential 

adverse impacts. 

Historic and Cultural Resources. The EIS will address the potential impacts of the proposed 

FEP/DUP facility on the historic and archaeological resources of the area. The outcomes of 

consultations with historic and cultural resource protection agencies, consistent with Section 

106 of the National Historic Preservation Act of 1966 (36 CFR 800) will be discussed. As 

appropriate, the assessment will include an analysis of mitigation measures to address potential 

adverse impacts. 
 A-11 

Visual and Scenic Resources. Potential impacts to the overall visual and scenic character of 

the area will be addressed. As appropriate, the assessment will include an analysis of 

mitigation measures to address potential adverse impacts. 

Socioeconomics. The EIS will address demography, economic base, labor pool, housing, 

utilities, public services, education, and recreation potentially affected by the proposed action 

and alternatives. The hiring of new workers from outside the area could lead to potential 

impacts on regional housing, public infrastructure, and economic resources. Potential 

population changes leading to changes in the housing market and demands on the public 

infrastructure will be assessed. As appropriate, the assessment will include an analysis of 

mitigation measures to address potential adverse impacts. 

Costs and Benefits. The EIS will compile in one place the costs and benefits of the proposed 

project so that a determination can be made of any net positive benefit to Lea County, the 

region, and the Nation. The EIS will compare the potential environmental and monetary costs 

and benefits of constructing and operating the proposed FEP/DUP facility. 

Resource Commitments. The EIS will identify the potential for any unavoidable adverse 

impacts and irreversible and irretrievable commitments of resources. It will also address the 

relationship between local, short-term uses of the environment and the maintenance and 

enhancement of long-term productivity. Associated mitigative measures and environmental 

monitoring requirements will be presented, as applicable. 

Public and Occupational Health. The EIS will include a determination of potentially adverse 

effects on human health that result from chronic and acute exposures to ionizing radiation and 

hazardous chemicals, and from physical safety hazards. Potentially adverse effects on human 

health might occur during site preparation, construction, operation, or decommissioning. 

Potential impacts associated with the implementation of the proposed action will be assessed 

under normal operation and credible accident scenarios. As appropriate, the assessment will 

include an analysis of mitigation measures to address potential adverse impacts. 

Waste Management. The EIS will discuss the management of wastes, including by-product 

materials, generated from the site preparation, construction, and operation of the proposed 

FEP/DUP facility to assess the potential impacts of generation, storage, and disposal. 

Decommissioning. The EIS will provide a discussion of facility decommissioning and associated 

potential impacts. 

Cumulative Impacts. The EIS will address the potential cumulative impacts from past, present, 

and reasonably foreseeable future activities at and near the site, including preconstruction 

activities and a proposed facility expansion. 

Environmental Justice. The EIS will address any potential disproportionately high and adverse 

environmental impacts of the proposed FEP/DUP facility on low-income and minority 

populations. 

A.4 ISSUES CONSIDERED TO BE OUTSIDE THE SCOPE OF THE ENVIRONMENTAL 

IMPACT STATEMENT 

The purpose of an EIS is to assess the potential environmental impacts of a proposed action in 

order to assist in an agency’s decision-making process – in this case, NRC’s licensing process. 
 A-12 

As noted in Section 2.1, some issues and concerns raised during the scoping process are not 

relevant to the EIS because they are not directly related to the assessment of potential 

environmental impacts or the decision-making process. The lack of in-depth discussion in the 

EIS, however, does not mean that an issue or concern lacks value. Issues beyond the scope of 

the EIS either may not yet be at the point where they can be resolved or are more appropriately 

discussed and decided in other venues. 

Some of the issues raised during the public scoping process for the proposed facility are outside 

the scope of the EIS, but are analyzed in the SER. For example, health and safety issues are 

considered in detail in the SER prepared by the NRC staff for the proposed action and are 

summarized in the EIS. The EIS and the SER are related in that they may cover some of the 

same topics and may contain similar information, but the analysis in the EIS is focused on the 

assessment of potential environmental impacts. In contrast, the SER deals primarily with safety 

evaluations and procedural requirements or license conditions to ensure the health and safety 

of workers and the general public. The SER also covers other aspects of the proposed action 

such as demonstrating that the applicant will provide adequate funding for the proposed facility 

in compliance with the NRC’s financial assurance regulations. 

Some of the issues raised during the public scoping process are not addressed in the EIS as 

they are not appropriate for resolution in the EIS. Other issues, including support of or 

opposition to nuclear facilities and the liability of federal workers under the Federal Tort Claims 

Act, are also beyond the scope of the EIS. The mission of the NRC is to license and regulate 

the Nation’s civilian use of byproduct, source, and special nuclear materials in order to protect 

public health and safety, promote the common defense and security, and protect the 

environment. The NRC’s regulations are designed to protect both the public and workers 

against radiation hazards from industries that use radioactive materials. The NRC’s scope of 

responsibility includes regulation of commercial nuclear power plants; research, test, and 

training reactors; nuclear fuel cycle facilities; medical, academic, and industrial uses of 

radioactive materials; and the transport, storage, and disposal of radioactive materials and 

wastes. Activities not within the jurisdiction of the NRC are not subject to NRC regulations nor 

appropriate for consideration in the NRC’s decision making process. 
B-1 

APPENDIX B 

CONSULTATION/CORRESPONDENCE

 

 B-3 
 

 B-4 
 

 B-5 

Identical letters, as the one sent to Apache Tribe of Oklahoma, presented in pages B-3 and B-4, 

were also sent on June 29, 2010, to the following addresses: 
 

 B-6 

 
 

 B-7 
 

 B-8 
 

 B-9 
 

 B-10 
 

 B-11 
 

 B-12 
 

 B-13 
 

 B-14 
 

 B-15 
 

 B-16 
 

 B-17 
 

 B-18 
 

 B-19 
 

 B-20 
 

 B-21 
 

 B-22 
 

 B-23 
 

 B-24 
 

 B-25 
 

 B-26 
 

 B-27 

An identical letter as the one sent to New Mexico Ecological Service Field Office, U.S. Fish & 

Wildlife Service, presented in pages B-25 and B-26, was also sent on July 2, 2010, to the 

following address: 
 

 B-28 
 

 B-29 
 

 B-30 
 

 B-31 
 

 B-32 
 

 B-33 
 

 B-34 
C-1 

APPENDIX C 

AIR EMISSIONS

 

 C-3 

AIR EMISSIONS

C.1 Introduction 

The construction and operation of the proposed IIFP facility would result in an increase in air 

emissions due to construction, operations, and decommissioning workforce commuter vehicles 

and delivery vehicles, and, during construction, construction equipment. This Appendix 

presents the inputs and methodology used to estimate emission rates from vehicles in order to 

compare the estimated pollutant concentrations with National Ambient Air Quality criteria 

(NAAQS). The impacts of emissions on air quality also considered the downwind dispersion 

rates, and the input and methodology for those calculations are included in this Appendix. 

C.2 Air Pollutant Emissions from On-Road Vehicles 

This section discusses on-road vehicle air pollutant emissions, during construction, operation, 

and decommissioning of the proposed IIFP facility. 

C.2.1 Model Input 

The basic calculation to determine a pollutant emission rate is to multiply the number of vehicle 

miles by the pollutant’s emission factor (explained below for pollutants listed in Table C-2). The 

number of commuter vehicles was conservatively estimated based on the size of the 

construction and operations workforces presented applicant’s Environmental Report (IIFP, 

2009). The daily mileage was estimated based on the likely residences of the workforces (see 

this EIS Sections 4.1.1.8 for construction and 4.1.2.8 for the methodology to estimate commuter 

mileage). The estimated numbers of daily deliveries and mileage was also estimated from 

information found in the Environmental Report. This information is summarized in Table C-1. 

Emission factors were determined using the computer code MOVES (EPA, 2010a), an EPA 

emission inventory model. It provides an accurate estimate of emissions from mobile sources 

under a wide range of user-defined conditions. MOVES was used to calculate emission factors 

for volatile organic compounds (VOCs), carbon monoxide (CO), nitrogen oxides (NOx), carbon 

dioxide equivalents (CO2), sulfur dioxide (SO2), particulate matter less than 2.5 microns in 

diameter (PM2.5), particulate matter less than 10 microns in diameter (PM10), benzene, methyl 

tertiary butyl ether (MBTE), 1,3 butadiene, formaldehyde, acetaldehyde, and acrolein for the 

years of interest. Phase 1 construction is expected to start in 2012 and be completed in 2013. 

Phase 2 construction is expected to begin in year 2015 and be completed in 2016 Facility 

operations would begin in 2013, and extend for the 40-year license term. The year 2011 was 

chosen as the model year. 

Different emissions emanate from a vehicle depending on type of activity and time of the day. 

The model accounts for all emissions during normal daily activity. The types of emission 

processes are: 

• Running exhaust—tailpipe emissions during highway travel. 

• Starting exhaust—tailpipe emissions that occur as a result of starting a vehicle. These 

emissions are independent of running exhaust emissions. The magnitude of these 

emissions is dependent on how long the vehicle has been sitting prior to starting. 
 

 C-4 

Table C-1. Worker and Delivery Vehicle Rates Due To Construction, Operation, and 

 Decommissioning Activities of the IIFP Facility 

 (vehicles) (miles/day) (days/phase)* (vehicle miles/phase) 

Preconstruction (3 months) 

workers 70 40 62.5 175,000 

deliveries 10 40 62.5 25,000 

equipment 2 40 62.5 5,000 

Phase 1 Construction (1 year**) 

workers 140 40 250 1,400,000 

deliveries 20 40 250 200,000 

equipment 4.25 40 250 42,500 

Phase 1 Operations (1 year) 

workers 140 40 250 1,400,000 

deliveries 10.6 1512 250 4,006,800 

Phase 2 Construction (1 year) 

workers 180 40 250 1,800,000 

deliveries 20 40 250 200,000 

equipment 2 40 250 20,000 

Phase 2 Operations* (per year) 

workers 40 40 250 400,000 

deliveries 17.2 1512 250 6,501,600 

Decommissioning (3 years) 

workers 40 40 750 1,200,000 

deliveries 0 - 750 0 

*After 2016, both phases of the facility will be operational. The “Phase 1 operations” entries apply only to the 

years 2013 to 2016, when only Phase 1 is operation. “Phase 2 operations” entries include both Phase 1 and 

Phase 2 operations, beginning in year 2016. 

**The work year was taken to be 250 days long. 

Source: IIFP, 2011 

• Tirewear—particulate emissions as friction between tires and the highway wear away 

the tire. 

• Brakewear—particulate emissions from brake use. 

• Evaporation loss—fuel loss through rubber and plastic components while the vehicle 

is sitting . 

• Crankcase exhaust—the exhaust gases that escape around the piston rings and enter 

the crankcase during normal operation. 

Table C-2 presents the results of all the sources of emissions as grams per mile driven, as 

calculated by the MOVES model using the input parameters from Table C-1. 
 

 C-5 

Table C-2. MOVES Emission Factor Outputs for 2011 

Pollutant Emission Factor (gram/mile) 

workers deliveries equipment 

VOCs 7.37x10-1 8.72x10-1 1.02 

CO 7.82 1.02 x10 1.20 x10 

NOx 1.04 4.63 1.71 

SO2 8.28 x10-3 1.12 x10-2 9.96 x10-3

PM10* 3.53 x10-2 2.38x10-1 5.30 x10-2

PM2.5* 1.90 x10-2 1.97x10-1 3.23 x10-2

CO2 - equivalent 4.28 x102 9.57 x102 5.30 x102

benzene 1.67 x10-2 1.92 x10-2 2.57 x10-2

MBTE 0.00 0.00 0.00 

1,3 butadiene 2.86 x10-3 4.34 x10-3 4.56 x10-3

formaldehyde 6.41 x10-3 2.46 x10-2 1.15 x10-2

acetaldehyde 5.93 x10-3 1.27 x10-2 9.72 x10-3

acrolein 2.97 x10-4 1.20 x10-3 5.31 x10-4

*PM totals are the sum of organic carbon, elemental carbon, and sulfate particulate emissions. 

C.2.2 Analysis Methods 

Emission rates of the six criteria pollutants (i.e., CO, NOX, SO2, PM10, PM2.5 and VOCs, an 

ozone precursor), CO2 equivalent, and six hazardous air pollutants (HAPs) (i.e., benzene, 

MBTE, 1,3 butadiene, formaldehyde, acetaldehyde, and acrolein) as calculated by MOVES for 

Lea County in 2011 (Table C-2) were multiplied by the worker and delivery vehicles mileage 

estimates (Table C-1) to arrive at total emissions. 

C.2.3 Results 

Pollutant emission amounts for the span of construction and operation phase are reported in 

this EIS Sections 4.1.1.4 for construction (Tables 4-4 and 4-5), 4.1.2.4 for operations (Tables 4-

15 and 4-16), and 4.2.2.4 for the Phase 2 increment. 

C.3 Air Pollutant Emissions from Construction Activities 

This section discusses air pollutant emissions as a result of construction activities. This 

includes emissions from construction equipment, fugitive dust emissions from land disturbance 

from construction activities, and fugitive emissions from the onsite diesel refueling activities. 

C.3.1 Analysis Methods 

All emissions were calculated using the general equation for emissions estimation 

(EPA, 1995a): 

E = A x EF x (1-ER/100) 
 

 C-6 

where: 

E = emissions 

A = activity rate 

EF = emission factor 

ER = overall emission reduction efficiency, as % 

For construction equipment the activity rate is measured as horsepower-hours. The following 

equation (EPA, 2005a) was used to determine the horsepower-hours: 

HP-hr = (Max HP) x (LF) x (#) x (hrs) 

where: 

HP-hr = horsepower-hours 

Max HP = maximum horsepower 

LF = load factor 

# = number of units used 

hrs = hours that equipment operates 

For fugitive dust emissions in the first equation, the activity rate is the number of acres that 

would be disturbed by construction activities. Because the applicant indicated that watering 

would be used to control fugitive dust emissions, an emission reduction efficiency of 50 percent 

was assumed. 

For fugitive emissions from the onsite diesel refueling activities in the first equation, the activity 

rate is the number of gallons of diesel fuel used. The amount of diesel fuel used was calculated 

using the following equation (EPA, 2010b): 

DB = BSFC x TAF x A 

where: 

DB = diesel burned 

BSFC = brake specific fuel consumption 

TAF = transient adjustment factor 

A = activity rate (HP-hr) 

Carbon dioxide equivalents were calculated using the equation (EPA, 2005b): 

CO2e = CO2 + (21 x CH4) + (310 x N2O) 

where: 

CO2e = carbon dioxide equivalents 

CO2 = carbon dioxide 

CH4 = methane 

N2O = nitrous oxide 
 

 C-7 

The applicant provided equipment lists and schedules showing the hours of equipment 

operation per month for each construction phase (preconstruction, Phase 1 and Phase 2), and 

the amount of disturbed acreage (IIFP, 2011). 

C.3.2 Emission Factors 

Emission factors for CO2, VOCs, CO, NO2, SO2, PM2.5, and PM10 were determined using the 

computer code NONROAD (EPA, 2005b), an EPA emission inventory model. Default values 

for Lea County, New Mexico (i.e., climate/meteorology, equipment age, deterioration factors, 

fuel properties, and growth factors) were used as inputs for the model. The year 2011 was 

chosen at the modeling year. 

Emission factors for the greenhouse gases methane (CH4) and nitrous oxide (N2O) were 

obtained from the EPA guidance document “Climate Leaders Greenhouse Gas Inventory 

Protocol Core Module Guidance Direct Emissions from Mobile Combustion Sources” 

(EPA, 2008). 

Emission Factors for fugitive dust emissions were obtained from Section 13.2.3 of EPA AP-42 

“Compilation of Air Emission Factors” (EPA, 1995a). Emission factors for refueling activities 

were provided by the applicant (IIFP, 2011). 

C.3.3 Results 

The input used in the calculations described in Section C.3.1, and the calculated monthly and 

annual emissions, and maximum emissions rates for each pollutant for each construction phase 

(Table C-2) are reported in this EIS Sections 4.1.1.4 for Phase 1, and 4.2.2.4 for preconstruction 

and Phase 2 construction. 

C.4 Incremental Downwind Air Pollutant Concentration Increases 

C.4.1 Model Input 

Emissions from construction equipment would be dispersed downwind. Dispersion coefficients 

were determined using the computer code SCREEN3 (EPA, 1995b), an EPA single source 

Gaussian plume model. Dispersion coefficients were determined for the maximum 

concentration (at the construction site), the property border (at 900 meters from the construction 

site), and 1 mile (1,600 meters) from the construction site for Phase 1 preconstruction and 

construction, Phase 2 construction, and Phase 1 operations (Table C-3). 

C.4.2 Analysis Methods 

There is a direct correlation between the source emission rate and the dispersion coefficients 

(disp coeff) calculated by SCREEN3. For example, a 5-fold increase in the emission rate input 

to SCREEN3 results in a 5-fold increase in the resulting dispersion concentrations. Therefore, 

setting the source emission rate to 1.0 gram/second/square meter allows scaling of the 

emission rates by multiplying them by SCREEN3’s dispersion coefficients. This was done using 

Eq. C.3-1 for the preconstruction, Phase 1 construction, and Phase 2 construction to determine 

the peak 1-hour concentrations at the site border (900 meters) and at 1 mile (1,600 meters). 

The peak 3-hour, 8-hour, 24-hour, and annual concentrations were derived by multiplying the 
 

 C-8 

peak 1-hour concentration by the conversion factors given in Table C-4 (EPA, 1992). The 

resulting concentrations are provided in Section C.4.3. 

 [ (A + B) x C ] + [ D x E ] = F Eq. C.3-1 

where: 

A = Construction Equipment 1-hour Peak Emission Rate 

B = Construction Vehicles 1=hour Peak Emission Rate 

C = SCREEN3 Volume Dispersion Coefficient 

D = Fugitive Dust 1-hour Peak Emission Rate 

E = SCREEN3 Area Dispersion Coefficient 

F = One-hour Peak Concentration at Site Boundary or 1.6 km (1 mi) 

Table C-3. SCREEN3 Outputs: Dispersion Coefficients 

Preconstruction / 

Phase 1 Construction 

Volume

(μg/m3)/ 

(g/s) 

max (157 m ) 935.9 

900 m 246.4 

1600 m 144.5 

Area

(μg/m3)/ 

(g/s/m2) 

max (223 m) 1.648x108

900 m 2.492x107

1600 m 1.565 x107

Phase 2 Construction 

Volume

(μg/m3)/ 

(g/s) 

max (30 m) 7352 

900 m 593.4 

1600 m 274.7 

Area

(μg/m3)/ 

(g/s/m2) 

max (35 m) 9.386x107

900 m 1.753x106

1600 m 7.636x105

Phase 1 Operations - Utilities 

Point

(μg/m3)/ 

(g/s) 

max (107 m) 608.0 

900 m 145.5 

1600 m 132.9 

Phase 1 Operations - H2 Generation 

Point

(μg/m3)/ 

(g/s) 

max (140 m) 666.5 

900 m 210.0 

1600 m 166.5 
 

 C-9 

Table C-4. EPA Peak Hour Conversion Factors 

3-Hour Conversion Factor 0.90 

8-Hour Conversion Factor 0.70 

24-Hour Conversion Factor 0.40 

Annual Average Conversion Factor 0.10 

Source: (EPA, 1992) 

The 1-hour peak concentrations at site border for each construction phase and operations were 

determined according to Eq. C.3-2. All emission-generating units were conservatively assumed 

to operate continuously. The conversion factors given in Table C-4 were used to determine 

peak 3-hour, 8-hour, 24-hour, and annual concentrations. The resulting concentrations are 

provided in Section C.4.3. 

 [ ( G + H + J ) x K ] + [ L x M ] = N Eq. C.3-2

where: 

G = Boilers 1-hour Peak Emission Rate 

H = Generators 1-hour Peak Emission Rate 

J = Firewater Pump 1-hour Peak Emission Rate 

K = SCREEN3 Utilities Point Dispersion Coefficient 

L = H2 Generator 1-hour Peak Emission Rate 

M = SCREEN3 H2 Generation Point Dispersion Coefficient 

N = One-hour Peak Concentration at Site Boundary or 1.6 km (1 mi) 

C.4.3. Results 

Peak 1-hour, 3-hour, 8-hour, 24-hour, and annual concentrations at the site boundary for each 

construction phase and operations and their percent of the NAAQS that were calculated are 

reported in this EIS Sections 4.1.1.4 for construction (Table 4-6), 4.1.2.4 for operations (Table 4-

17), and 4.2.2.4 for cumulative impacts. 

C.5 References 

(EPA, 1992) U.S. Environmental Protection Agency. 1992. Screening Procedures for Estimating 

the Air Quality Impact of Stationary Sources, Revised, EPA-454/R-92-019, October, 1992. 

Available at http://www.epa.gov/oppt/exposure/presentations/efast/usepa_1992b_sp_ 

for_estim_aqi_of_ss.pdf. Accessed August 9, 2011. 

(EPA, 1995a) U.S. Environmental Protection Agency. 1995. Compilation of Air Pollutant 

Emissions Factors, Fifth Edition and Supplements, AP-42. Office of Air Quality Planning and 

Standards, Research Triangle Park, North Carolina. January 1995. . Available at 

http://www.epa.gov/ttn/chief/ap42/index.html. Accessed May 18, 2011. Relevant sections are 

posted in ADAMS with ADAMS Accession Nos. ML 11194A234, ML11194A236, and ML 

11182C051. 

(EPA, 1995b) U.S. Environmental Protection Agency. 1995. “SCREEN3 Model User’s Guide,” 

EPA-454/B-95-004, Office of Air Quality Planning and Standards, Research Triangle Park, 

North Carolina. September 1995. Available at http://www.epa.gov/ttn/scram/userg/ 

screen/screen3d.pdf. Accessed May 18, 2011. ADAMS Accession No. ML071930125. 
 

 C-10 

(EPA, 2005a) U.S. Environmental Protection Agency. 2005. “User’s Guide for the Final 

NONROAD2005 Model,” EPA420-R-05-013, Office of Transportation and Air Quality. December 

2005. Available at http://www.epa.gov/otaq/models/nonrdmdl/nonrdmdl2005/420r05013.pdf. 

(EPA, 2005b) U.S. Environmental Protection Agency. 2005. Metrics for Expressing 

Greenhouse Gas Emissions: Carbon Equivalents and Carbon Dioxide Equivalents. EPA420-F05-002, February 2005. . Available at http://www.epa.gov/oms/climate/420f05002.pdf. 

Accessed October 14, 2011. 

(EPA, 2008) U.S. Environmental Protection Agency. 2008. Climate Leaders Greenhouse Gas 

Inventory Protocol Core Module Guidance Direct Emissions from Mobile Combustion Sources. 

EPA430-K-08-004, May 2008. Available at http://www.epa.gov/climateleaders/documents/ 

resources/mobilesource_guidance.pdf. Last Accessed on June 2, 2011. 

(EPA, 2010a) U.S. Environmental Protection Agency. 2010. MOVES – Motor Vehicle Emission 

Simulator, August 26, 2010. Available at http://www.epa.gov/otaq/models/moves/index.htm, last 

accessed June 2, 2011. 

(EPA, 2010b) U.S. Environmental Protection Agency. 2010. Exhaust and Crankcase emission 

Factors for Nonroad Engine Modeling -- Compression-Ignition, NR-009d. EPA-420-R-10-018, 

July 2010. Available at http://www.epa.gov/oms/models/nonrdmdl/nonrdmdl2010/ 

420r10018.pdf. Accessed October 14, 2011. 

(IIFP, 2009) International Isotopes Fluorine Products. 2009. Fluorine Extraction Process and 

Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A. ER-IFP001, Revision A. December 27, 2009. ADAMS Accession No. ML 100120758. 

(IIFP, 2011) International Isotopes Fluorine Products, 2011. Fluorine Extraction Process and 

Depleted Uranium De-conversion Plant (FEP/DUP) Official Responses to Environmental Report 

RAIs, Revision A ,Talking Points Regarding the Environmental Report. May 24, 2011. ADAMS 

Accession No. ML111530402. 
 

 D-1 

APPENDIX D 

SOCIOECONOMIC INFORMATION 
 

 
 

 D-3 

SOCIOECONOMIC INFORMATION

D.1 Introduction 

This Appendix presents the bases to establish the region of influence (ROI) for socioeconomic 

conditions, and calculations to assess impacts in the ROI. In addition, this Appendix contains 

the input used for the Environmental Justice analysis.

D.2 Socioeconomic Region of Influence (ROI) 

The identification of a socioeconomic region of influence for a site is dependent on many 

factors, which can include, but are not necessarily limited to: 

• Population and population densities of the counties within 50 miles of the proposed site 

• Population of those counties’ largest population centers 

• Geographic locations of the population centers in relation to the proposed site 

• Estimated travel distance or travel time from the population centers to the proposed site 

• Mean travel time to work for each county 

• Employment data for each county 

• Worker commuting patterns from the surrounding counties to the county containing the 

proposed site (“host county”) 

In identifying the socioeconomic ROI, the initial step was to identify counties that lie primarily 

within the 50-mile radius or counties with only a small portion of their area within the 50-mile 

radius but with a large population center within the 50-mile radius . Two counties in New 

Mexico and three counties in Texas have these characteristics: Lea County and Eddy County, 

New Mexico, and Andrews, Gaines, and Yoakum Counties, Texas. A review of the key 

factors for each county, determined that the proposed action has the potential to impact 

socioeconomic variables (employment, population, income, housing, infrastructure, and 

community services) in the two New Mexico counties only (Lea and Eddy). Therefore, these 

counties were identified as the socioeconomic ROI. For the reasons discussed below, the 

proposed action is unlikely to impact socioeconomic variables in the Texas counties (Andrews, 

Gaines, and Yoakumand these counties were not included in the socioeconomic ROI. Each 

county’s demographics are summarized in Tables D-1 through D-5 and briefly analyzed below. 

Table D-1 provides information on population, income, distances and commuting time for 

counties and population centers. Table D-2 provides employment characteristics by county. 

Table D-3 provides county-to-county worker flows. Table D-4 provides information on 

housing units and staffed hospital beds. Table D-5 provides hospital beds details per 

hospital/medical center. 
D-4 

Table D-1. Population, Income, Distances and Commuting Time for Counties and Population Centers.

County Population 

(2000)a

Population 

Density per 

Square 

mile of 

Land Area 

(2000)a

Population 

Estimate 

(2009)a

Mean 

Travel 

Time to 

Work, 

2000 

(Minutes)a

Median 

Household 

Income 

(2008 

dollars)a

County's 

Largest 

Population 

Center b

Population 

Center 

Population 

(2000)b

Population 

Center 

Population 

(2009)b

Driving 

Miles from 

Population 

Center to 

proposed 

site 

New Mexico  Lea 55,508 12.6 60,232 18.7 $45,813 Hobbs 28,657 30,838 10-15  Eddy 51,658 12.4 52,706 18.3 $43,784 Carlsbad 25,625 26,259 60-65 Texas  Andrews 13,004 8.7 14,057 20.6 $49,043 Andrews 9,652 10,448 70-75  Gaines 14,467 9.6 15,382 17.4 $40,489 Seminole 5,910 6,251 40-45  Yoakum 7,322 9.2 7,698 15.9 $50,317 Denver 

City 

3,985 4,140 45-50 

Sources and Notes: aUSCB, 2010a bUSCB, 2010b 
D-5 

Table D-2. Employment Characteristics by County.

County Number of 

Jobs 

(2008)a

Construction 

Jobs (2008)a

Construction 

Jobs as 

Percent of 

All Jobs 

(2008) a

Professional, 

Scientific, 

and 

Technical 

Services 

Jobs (2008)a

Professional, 

Scientific, 

and 

Technical 

Services 

Jobs as 

Percent of 

All Jobs 

(2008) a

Civilian 

Labor 

Force 

(2009)b

Annual 

Average 

Unemployment 

Rate (2009)b,c 

(%) 

Unemployment 

Rate (June 

2010)b,c (%) 

New Mexico  Lea 37,622 3,460 9.2% 1,019 2.7% 28,890 7.6 8.0  Eddy 30,692 2,597 8.5% 1,315 4.3% 28,700 5.5 6.1 Texas Andrews 7,337 860 11.7% (D) NA 7,008 7.1 6.6  Gaines 8,043 992 12.3% 150 1.9% 7,016 6.4 6.4 Yoakum 4,980 419 8.4% 67 1.3% 4,134 7.7 6.8 Sources: aBEA, 2010a bBLS, 2010a cBLS, 2010b 

(D) - Not shown (by the BLS) to avoid disclosure of confidential information, but the amount is included in the BEA's totals. NA = Not available
D-6 

Table D-3. County-to-County Worker Flows, 2000. 

Res State 

Res 

County 

Res 

(C)MSA

Res 

PMSA

Residence 

State- County 

Name 

Work 

State 

Work 

County 

Workplace 

State-County 

Name Count 

Percent from Resident County 

35 025 9999 9999 Lea Co. NM 035 015 Eddy Co. NM 303 1.5% 35 025 9999 9999 Lea Co. NM 035 025 Lea Co. NM 18,566 93.6% 35 015 9999 9999 Eddy Co. NM 035 015 Eddy Co. NM 19,236 95.3% 35 015 9999 9999 Eddy Co. NM 035 025 Lea Co. NM 195 1.0% 48 003 9999 9999 Andrews Co. TX 035 025 Lea Co. NM 49 1.0% 48 003 9999 9999 Andrews Co. TX 048 003 Andrews Co. TX 3,794 77.2% 48 165 9999 9999 Gaines Co. TX 035 025 Lea Co. NM 179 3.4% 48 165 9999 9999 Gaines Co. TX 048 165 Gaines Co. TX 4,285 80.6% 48 501 9999 9999 Yoakum Co. TX 035 025 Lea Co. NM 135 4.8% 48 501 9999 9999 Yoakum Co. TX 048 501 Yoakum Co. TX 2,383 84.4% Source: USCB, 2003
 

 D-7 

Table D-4. Housing Units and Staffed Hospital Beds 

County, State Housing Units, 

2009 a

Percent of Total 

Units 

Staffed Hospital 

Beds b

Percent of 

Total Staffed 

Beds 

 Lea Co., NM 24,837 40.1% 226* 44.5% 

 Eddy Co., NM 22,645 36.5% 147* 28.9% 

 Andrews Co., TX 5,810 9.4% 88* 17.3% 

 Gaines Co., TX 5,645 9.1% 25* 4.9% 

 Yoakum Co., TX 3,062 4.9% 22* 4.3% 

Total 61,999 508 

Sources: 

a

 USCB, 2010a 

b

 AHA, 2007 

* See Hospital Beds details per Hospital/Medical Center, in Table D.5 below. 

Table D-5. Hospital Beds Details per Hospital/Medical Center

New Mexico Hospital Beds Hospital Beds 

County 

Total 

Eddy County 147 

Carlsbad Medical Center 127 

Artesia General Hospital 20 

Lea County 226 

Lea Regional Medical Center 214 

NOR-Lea General Hospital 12 

Texas Hospital Beds 

Andrews County 88 

Permian Regional Medical Center 88 

Yoakum County 22 

Yoakum County Hospital 22 

Gaines County 25 

Memorial Hospital 25 

Source: AHA, 2007 

D.2.1 Lea County, New Mexico 

Lea County is the host county for the proposed IIFP project. The proposed location is 

approximately 14 miles west of Hobbs, New Mexico. Lea County had a year 2000 population of 
 

 D-8 

55,508 and an estimated 2009 population of 60,232, with 12.6 people per square land mile in 

2000 (Table D-1). The county’s largest population center is Hobbs, with a 2000 population of 

28,657, and an estimated 2009 population of 30,838. Hobbs is the largest city within a 50-mile 

radius (Carlsbad, in Eddy County New Mexico, has about 26,300 residents and lies on the 50-

mile perimeter). Lea County’s mean commute time is 18.7 minutes. 

In 2009, Lea County’s civilian labor force was 28,890 persons (Table D-2). In 2008, 

employment in the construction industry accounted for 9.2 percent of total employment and 

employment in the professional, scientific, and technical services industry (the industry 

classification of the proposed project) accounted for approximately 2.7 percent of the jobs. In 

2009, the annual average unemployment rate was 7.6 percent. The unemployment rate in 

June 2010 was 8.0 percent. 

In 2000, Lea County’s 19,828 commuting residents traveled to a worksite (USCB, 2003). Of 

those, 18,566 (93.6 percent) traveled to a worksite in Lea County. An additional 303 workers 

(1.5 percent) commuted to a worksite in Eddy County. The remaining 4.8 percent traveled to a 

worksite elsewhere. Of the 19,790 jobs in Lea County in 2000, 18,566 (93.8 percent) were held 

by residents of Lea County. Residents of Eddy County held 195 (1.0 percent) of those jobs. No 

other county had residents that filled at least 1 percent of the Lea County jobs (Table D-3). 

Lea County, in the vicinity of the proposed site, in particular, is well served by state and county 

highways and roads. Sufficient community amenities and infrastructure to support additional 

population are in Lea County. In 2009, Lea County had 40.1 percent of the housing inventory in 

the five subject counties (Table D-4). Lea County had 44.5 percent of all the staffed hospital 

beds in the five-county area (Tables D-4 and D-5). 

Based on the proximity to the proposed project site, availability of amenities including 

housing, and the historical county-to-county worker travel patterns, Lea County is the most 

likely county for project workers to reside. Also, Lea County would be the major recipient of 

facility-generated property taxes. Therefore, Lea County , was included in the socioeconomic 

ROI of the proposed project. 

D.2.2 Eddy County, New Mexico 

A substantial portion of Eddy County, New Mexico is within the 50-mile radius of the proposed 

site. Eddy County had a year 2000 population of 51,658 and an estimated 2009 population of 

52,706 with 12.4 people per square land mile in 2000 (Table D-1). The county’s largest 

population center is Carlsbad, with a 2000 population of 25,625 and an estimated 2009 

population of 26,259. Carlsbad is on the perimeter of the 50-mile radius of the proposed site. 

Eddy County’s mean commute time is 18.3 minutes. Carlsbad is approximately 60-65 driving 

miles from the proposed site. 

In 2009, Eddy County’s civilian labor force was 28,700 persons (Table D-2). In 2008, 

employment in the construction industry accounted for 8.5 percent of total employment and 

employment in the professional, scientific, and technical services industry (the industry 

classification of the proposed project) accounted for approximately 4.3 percent of the jobs in the 

county. In 2009, the annual average unemployment rate was 5.5 percent. The unemployment 

rate in June 2010 was 6.1 percent. 
 

 D-9 

In 2000, of Eddy County’s total commuting population, 19,236 (95.3 percent) traveled to a 

worksite in Eddy County and 195 (1.0 percent) commuted to a worksite in Lea County 

(Table D-3). 

Eddy county is served by several state and county highways and roads. U.S. Highway 62 

travels NNE from Carlsbad to the proposed site. Eddy County has sufficient community 

amenities and infrastructure to support its population. In 2000, Eddy County had 36.5 percent 

of all housing inventory in the five subject counties and 28.9 percent of all the staffed hospital 

beds in (Tables D-4 and D-5). 

Eddy County, New Mexico, borders the host county of the proposed project. A substantial 

portion of the county and a portion of its largest population center is within the 50-mile radius. 

The county population center is accessible to the proposed site via a major U. S. Highway. 

Although historically few Eddy County residents have traveled to Lea County for work, 

commuting patterns may change with newly available employment opportunities, particularly in 

the professional, scientific, and technical services industry. Based on the proximity to the 

proposed site, easy vehicle access, and availability of amenities including housing, this analysis 

concludes that some project workers would likely live in Eddy County. Therefore, Eddy County, 

New Mexico, was included in the socioeconomic ROI of the proposed project. 

D.2.3 Andrews County, Texas 

A substantial portion of Andrews County, Texas, is within the 50-mile radius of the proposed 

site. In 2000, Andrews County had a population of 13,004 and an estimated 2009 population of 

14,057with 8.7 persons per square land mile in 2000 (Table D-1). The county’s largest 

population center is Andrews, with a 2000 population of 9,652 and an estimated 2009 

population of 10,448. Andrews is outside the 50-mile radius of the proposed site. Andrews 

County’s mean commute time is 20.6 minutes. The proposed site is approximately 70-75 

driving miles from the city of Andrews. 

In 2009, Andrews County’s civilian labor force was 7,008 persons. In 2008, employment in the 

construction industry accounted for 11.7 percent of total employment (Employment in the 

professional, scientific, and technical services industry was confidential and not disclosed by the 

Bureau of Labor Statistics). In 2009, the annual average unemployment rate was 7.1 percent. 

The unemployment rate in June 2010 was 6.6 percent (Table D-2). 

In 2000, 3,794 (77.2 percent)of Andrews County commuting residents traveled to a workplace 

in Andrews County and 49 residents (1.0 percent) commuted to a worksite in neighboring 

Lea County (Table D-3). 

The rural county is served by state and county highways and roads. In 2000, Andrews County 

had less than 10 percent of all housing inventory in the five subject counties and 17.3 percent of 

all the staffed hospital beds (Tables D-4 and D-5). 

Andrews County, Texas, borders the host county of the proposed project. A substantial portion 

of the county is within the 50-mile radius. However, the county population center is not readily 

accessible to the proposed site via a major transportation artery. Historically, few Andrews 
 

 D-10 

County workers commute to Lea County., Therefore, few project workers would be expected to 

live in Andrews County and it was not included in the socioeconomic ROI. 

D.2.4 Gaines County, Texas 

A substantial portion of Gaines County, Texas, is within the 50-mile radius of the proposed site. 

In 2000, Gaines County had a population of 14,467 and an estimated 2009 population of 

15,382with 9.6 persons per square land mile in 2000 (Table D-1). The county’s largest 

population center is Seminole, with a 2000 population of 5,910 and an estimated 2009 

population of 6,251. Gaines County’s mean commute time is 17.4 minutes. The proposed site 

is approximately 40-45 driving miles from Seminole. 

In 2009, Gaines County’s civilian labor force was 7,016 persons. In 2008, employment in the 

construction industry accounted for 12.3 percent of total employment and employment in the 

professional, scientific, and technical services industry accounted for 1.9 percent of total 

employment. In 2009, the annual average unemployment rate was 6.4 percent. The 

unemployment rate in June 2010 was also 6.4 percent (Table D-2). 

In 2000, 4,285 (80.6 percent) of Gaines County commuting residents traveled to a worksite in 

Gaines County and 179 (3.4 percent) commuted to a worksite in neighboring Lea County. 

The rural county is served by state and county highways and roads. In 2000, Gaines County 

had less than 10 percent of all housing inventory in the five subject counties, and 25 staffed 

hospital beds, less than 5 percent of all the staffed hospital beds (Tables D-4 and D-5). 

Gaines County, Texas, borders the host county of the proposed project. A substantial portion of 

the county and its largest population center are within the 50-mile radius. The county population 

center is accessible to the proposed site via a major transportation artery. However, because 

historically few Gaines County workers commute to work in Lea County and the professional, 

scientific, and technical industry accounts for only 1.9 percent of the relatively small county 

workforce. Therefore, few project workers would be expected to live in Gaines County and it 

was not included in the socioeconomic ROI. 

D.2.5 Yoakum County, Texas 

A substantial portion of Yoakum County Texas is within the 50-mile radius of the proposed site. 

In 2000, Yoakum County had a population of 7,322 and an estimated 2009 population of 

7,698with 9.2 persons per square land mile in 2000 (Table D-1). The county’s largest 

population center is Denver City, with a 2000 population of 3,985 and an estimated 2009 

population of 4,140. Yoakum County’s mean commute time is 15.9 minutes. The proposed site 

is approximately 45-50 driving miles from Denver City. 

In 2009, Yoakum County’s civilian labor force was 4,134 persons. In 2008, employment in the 

construction industry accounted for 8.4 percent of total employment and employment in the 

professional, scientific, and technical services industry accounted for 1.3 percent of total 

employment. In 2009, the annual average unemployment rate was 7.7 percent. The 

unemployment rate in June 2010 was 6.8 percent (Table D-2). 
 

 D-11 

In 2000, 2,383 (84.4 percent) of Yoakum County commuting residents traveled to a workplace 

in Yoakum County and 135 (4.8 percent) commuted to a worksite in neighboring Lea County 

(Table D-3). 

The rural county is served by state and county highways and roads. In 2000, Yoakum County 

had approximately 4.9 percent of all housing inventory in the five subject counties and less than 

5 percent of all the staffed hospital beds (Tables D-4 and D-5). 

Yoakum County, Texas, borders the host county of the proposed project. A substantial portion 

of the county and its largest population center are within the 50-mile radius. The county 

population center is accessible to the proposed site via a major road. However, because 

historically few Yoakum County workers commute to work in Lea County and the professional, 

scientific, and technical industry accounts for only 1.3 percent of the relatively small county 

workforce, few project workers would be expected to live in Yoakum County. Therefore, 

Yoakum County, Texas, was not included in the socioeconomic ROI. 

D.2.6 Workflow Patterns Summary 

Historical patterns of commuting are the strongest proxy available to predict residential 

settlement patterns for workers migrating to an area for new employment opportunities. Countyto-county worker flow patterns are established by commuters based on their demonstrated 

preferences for residential areas. These demonstrated preferences are thought to include 

commuting times, housing, amenities, and other opportunities for employment. In this analysis, 

workers in Lea County demonstrated a preference for working in Lea County and residents of 

the surrounding counties demonstrated a reluctance to drive to a worksite in Lea County. 

Despite the limited employment opportunities in Andrews, Gaines, and Yoakum County, few 

residents of those counties have elected to drive to Lea County, with its larger employment 

base. Eddy’s County’s relatively large employment in the professional, scientific, and technical 

service sector reflects the presence of WIPP (Waste Isolation Pilot Plant) and related industries. 

These variables, coupled with the availability of highway access between Carlsbad and Hobbs, 

indicate a strong worker exchange between Lea and Eddy Counties. 

D.3 Environmental Justice 

This discussion supports the identification of minority and low-income populations within 

50 miles of the proposed project location, as shown in this EIS Chapter 3, Figures 3-20 

through 3-25. 

Procedures for the determination of minority and low-income populations are discussed in this 

section. Appendix C of the Environmental Review Guidance for Licensing Actions Associated 

with NMSS Programs (NRC, 2003), provides the current NRC guidance for identifying minority 

and low-income populations. The guidance was used in identifying minority and low-income 

populations in this EIS.

The area potentially impacted by environmental issues was determined to be within a 50-mile 

radius of the site, which is the area that was evaluated for impacts of potential facility accidents. 

Therefore, the minority populations and low-income populations were determined for all census 

block groups that fell entirely or partially within 50 miles of the project location. Block groups 
 

 D-12 

were used because census blocks (smaller than block groups) do not report income data and 

census tracts (larger than block groups) might not delineate minority or low-income populations 

within the larger general population (NRC, 2003). U.S. Census Bureau (USCB) Summary File 1 

containing race data (USCB 2000a; USCB 2000b) and Summary File 3 containing household 

poverty data (USCB 2000c; USCB 2000d) were obtained for all block groups in New Mexico 

and Texas since the 50-mile radius encompasses parts of both states. 

For each race/ethnicity minority category (Black or African American, American Indian and 

Alaska Native, Asian, Native Hawaiian and Other Pacific Islander, Other Race, Two or More 

Races [Multi-Racial], and Hispanic Ethnicity), and for each block group the percentage of the 

total population made up of the minority/ethnicity was calculated. The Aggregate category was 

also determined. The Aggregate is the sum of all the minorities within a block group. The 

percentage of low-income households was also calculated for each block group. 

The Hispanic Ethnicity category is NOT included in the aggregate of minorities because the 

USCB considers race and Hispanic origin (ethnicity) as two separate and distinct concepts. 

People who are Hispanic may be of any race. People in any race group may be either Hispanic 

or Not Hispanic. Each person has two attributes, their race (or races) and whether or not they 

consider themselves Hispanic. Because each person is counted in a race category and in 

either the Hispanic or not Hispanic category, including the Hispanic ethnicity in the “aggregate 

race” category would double count a number of individuals. As such, the race categories and 

the Hispanic Ethnicity categories are considered separately. 

The minority demographic data and low-income data were then attributed to block group 

spatial data in ArcGIS® 9.3 to develop a comprehensive shapefile dataset containing 

demographic and low-income data for every block group in the state. ArcGIS® is a geographic 

information system (GIS) modeling software which is used to access and query mapped 

demographic and low-income data (ESRI, 2008). 

In order to identify whether a minority or low-income population exists, an area larger than the 

proposed site and immediately surrounding environs, and that encompasses the entire area of 

potential impact must be identified for comparative analysis (NRC, 2003). This area is called 

a geographic area. Because the 50-mile radius used in this analysis includes parts of 

New Mexico and Texas, the geographic area used as the basis for identifying individual block 

groups with minority or low-income populations was the states of New Mexico and Texas. 

Block group low-income and minority populations in New Mexico were compared to the total 

low-income and minority populations in New Mexico, and block groups low-income and minority 

populations in Texas were compared to the total Texas low-income and minority populations. 

A significant minority population is considered to be present if (1) the minority population in the 

census block group exceeds 50 percent or (2) the minority population percentage of the block 

group is significantly greater (typically at least 20 percentage points) than the minority 

population percentage in the geographic area (NRC, 2003). A significant low-income population 

is considered to be present if: (1) the low-income household population in the census block 

group exceeds 50 percent or (2) the percentage of households below the poverty level in an 

environmental impact area is significantly greater (typically at least 20 percentage points) than 

the low-income household percentage in the geographic area (NRC, 2003). 
 

 D-13 

State and county percentages for minority and low-income populations were obtained using 

summary statistics in ArcGIS® 9.3 and then compared to the USCB information (USCB, 2000e; 

USCB, 2000f). The low-income and minority populations of all block groups wholly or partially 

within the 50-mile radius were identified if that block group contained a significant “minority 

population” or a “low-income population” as defined by NRC (2003). The results of the GIS 

modeling are shown on Table D.7, which indicates state and county percentages of racial 

composition and low income status for comparison. 

Table D6 provides the number of block groups entirely or partially in the 50 mile radius with 

minority or low-income populations. 

Table D-7 contains the state and county percentages of low-income and minority populations. 

These data were compared to the percentages of low income households and minority 

populations in each block group in the 50-mile radius to arrive at the information in Table D-6. 

Ninety-six block groups are within 50 miles of the project. Block groups within 50 miles of the 

proposed project location have Black, Some Other Race, Aggregate, Hispanic and low-income 

populations (Table D-6). 

D.4 Construction and Operation Workforce Characteristics Calculations 

The tables below present the assumptions used for construction and operation workforce 

assessments presented in Chapter 4 of this EIS. Table D-8 presents the construction workforce 

characteristics during construction of the proposed facility (IIFP, 2011) and assumptions based 

on NRC studies of workforces in substantially similar situations (BMI, 1981).

Table D-9 presents the operations workforce estimated number of on-site employees during the 

Phase I operation of the proposed IIFP facility (IIFP, 2011), and assumptions based on NRC 

studies of workforces in substantially similar situations (BMI, 1981). 

D.5 Socioeconomic Calculations Used in Chapter 4 – Environmental 

 Consequences

Table D-10 presents the calculations used to support the conclusions presented in Chapter 4 of 

this EIS related to population, employment, income, housing, public utilities, and education. 
D-14 

Table D-6. Race and Low-income Population Block Groups within 50 miles of the Proposed Project. 

State County 

County 

FIPS 

Number 

Number 

of 

Block 

Groups Black 

American 

Indian or 

Alaskan 

Native Asian 

Native 

Hawaiian 

or Other 

Pacific 

Islander 

Some 

Other 

Race 

Two or 

More 

Races Aggregate Hispanic 

Low-Income 

Households 

New Mexico 

Chaves 5 2 0 0 0 0 0 0 0 1 0 

New Mexico 

Eddy 15 3 0 0 0 0 0 0 0 1 0 

New Mexico 

Lea 25 64 1 0 0 0 14 0 10 24 10 

Texas Andrews 3 3 0 0 0 0 0 0 0 0 0 Texas Cochran 79 1 0 0 0 0 0 0 0 0 0 Texas Gaines 165 13 0 0 0 0 0 0 1 3 0 Texas Loving 301 1 0 0 0 0 0 0 0 0 0 Texas Terry 445 1 0 0 0 0 0 0 0 0 0 Texas Winkler 495 1 0 0 0 0 0 0 0 0 0 Texas Yoakum 501 7 0 0 0 0 1 0 0 3 0 

Totals: 96 1 0 0 0 15 0 11 32 10 

Source: ESRI, 2008; USCB, 2000a; USCB, 2000b; USCB, 2000c; USCB, 2000d; USCB, 2000e; USCB, 2000f; USCB, 2000g; USCB, 2000h
D-15 

Table D-7. State and County Percentages of Race and Low-Income Populations 

State County Black(%) American 

Indian or 

Alaskan 

Native 

(%) 

Asian 

(%) 

Native 

Hawaiian 

or Other 

Pacific 

Islander 

(%) 

Some 

Other 

Race 

(%) 

MultiRacial 

(%) 

Aggregate 

(%) 

Hispanic 

(%) 

LowIncome 

Households 

(%) 

New Mexico (state only) 

NA 1.89 9.54 1.06 0.08 17.04 3.65 33.25 42.08 16.78 

New Mexico Chaves 1.97 1.13 0.53 0.06 21.25 3.12 28.05 43.83 19.12 New Mexico Eddy 1.56 1.25 0.45 0.09 17.67 2.64 23.66 38.76 16.72 New Mexico Lea 4.37 0.99 0.39 0.04 23.81 3.27 32.87 39.65 19.90 Texas (state only) NA 11.53 0.57 2.70 0.07 11.69 2.47 29.03 31.99 13.98 Texas Andrews 1.65 0.88 0.71 0.02 16.79 2.87 22.92 40.00 16.74 Texas Cochran 4.53 0.83 0.21 0.05 27.35 2.55 35.52 44.13 21.67 Texas Gaines 2.28 0.76 0.15 0.01 14.17 2.35 19.72 35.77 19.08 Texas Loving 0.00 0.00 0.00 0.00 8.96 1.49 10.45 10.45 0.00 Texas Terry 5.00 0.53 0.22 0.02 14.28 3.40 23.45 44.09 20.53 Texas Winkler 1.85 0.45 0.20 0.00 20.35 2.34 25.19 44.00 18.58 Texas Yoakum 1.39 0.71 0.12 0.01 25.48 1.65 29.38 45.93 18.20 Source: USCB, 2000a; USCB, 2000b; USCB, 2000c; USCB, 2000d; USBC, 2000g; USCB, 2000h 
 

 D-16 

Table D-8. Workforce Characterization During IIFP Phase 1 Construction 

WORKFORCE CHARACTERIZATION 

Peak number of workers on-site during construction (IIFP, 2011) 140 

WORKFORCE MIGRATION 

Percent of construction workforce migrating into ROI 20% 

Total of construction workers migrating into ROI during construction peak 28 

FAMILIES 

Percent of construction workers who bring families (BMI, 1981) 70% 

Percent of construction workers who do not bring families 30% 

Average construction worker family size (worker, spouse, children) (BMI, 1981) 3.25 

Number of construction workers who would move into ROI and bring families 20 

Number of construction workers who would move into ROI and not bring families 8 

TOTAL IN-MIGRATION - FAMILIES AND UNACCOMPANIED WORKERS 

Number of construction workers who would bring families into ROI (total new families in 

ROI) 20 

Number of in-migrating workers' family members 44 

Number of in-migrating workers accompanied by family, plus family members 64 

Number of in-migrating workers who would not bring families into ROI 8 

Number of in-migrating workers and family members (= new population in ROI) 72 

SCHOOL-AGE CHILDREN 

Number of school-age children per construction family (BMI, 1981) 0.8 

Number of in-migrating school-age children 16 

POST-CONSTRUCTION WORKFORCE RETENTION 

Percent of in-migrating construction workers that would leave, post-construction (BMI, 

1981) 50% 

Number of in-migrating construction workers that would leave ROI, post-construction 14 

Number of in-migrating construction workers and their families plus in-migrating workers 

without families that would leave ROI, post-construction 36 

Number of school-age children of in-migrating construction workers that would migrate to 

ROI 16 

Number of in-migrating school-age children that would leave ROI, post-construction 8 

EMPLOYMENT 

Construction workforce peak 140 

Number of construction workers who migrate into ROI (20% of construction workforce 

peak) 28 

Employment multiplier for construction workers in ROI (indirect portion only) (BEA, 

2010b) 0.4324 

Indirect jobs resulting from in-migrating construction workers 12 

Sources: BEA .2010b; BMI. 1981; IIFP. 2011 

 
 

 D-17 

Table D-9. Workforce Characterization During IIFP Phase 1 Operation 

WORKFORCE CHARACTERIZATION 

Peak number of workers on-site during operation (IIFP, 2011) 140 

WORKFORCE MIGRATION 

Percent of operation workforce migrating into ROI 20% 

Number of operation workers migrating into ROI during operation peak 28 

FAMILIES 

Percent of operation workers who bring families (BMI, 1981) 100% 

Percent of workers who do not bring families 0% 

Average New Mexico family size, 2009 (USCB, 2010c) 3.23 

Number of operation workers who would move into ROI and bring families 28 

Number of operation workers who would move into ROI and not bring families 0 

TOTAL IN-MIGRATION - FAMILIES AND UNACCOMPANIED WORKERS 

Number of operation workers who would bring families into ROI (= total new families in ROI) 28 

Number of in-migrating operation worker family members 62 

Number of in-migrating operation workers accompanied by family, plus family members 90 

Number of operation workers who would not bring families into ROI 0 

Number of operation workers and family members migrating into ROI (= new population in 

ROI) 

90 

SCHOOL-AGE CHILDREN 

Number of school-age children per family (BMI, 1981) 0.8 

Number of in-migrating school-age children 22 

EMPLOYMENT

Operation workforce peak 140 

Number of operation workers who migrate into ROI (20% of workforce peak) 28 

Employment multiplier for operation workers in ROI (indirect portion only) (BEA, 2010b) 1.8173 

Indirect jobs resulting from in-migrating operation workers 51 

Number of persons unemployed in ROI, June 2010 (BLS, 2010a) 3,993 

Sources: BEA, 2010b; BLS, 2010a; BMI., 1981; IIFP, 2011; USCB, 2010c. 
 

 D-18 

 

Table D-10. Socioeconomic Calculations 

 Phase 1 

Construction 

Phase 1 

Operation 

POPULATION 

2009 ROI Population (USCB, 2010e) 112,938 112,938 

Total In-migration Associated with Phase 1 of the IIFP 

Project 72 90 

Percent ROI Population Increase related to IIFP Project 

Phase 1 0.06% 0.08% 

EMPLOYMENT AND INCOME 

June 2010 ROI Labor Force (BLS, 2010a) 56,945 56,945 

Estimated Number of people, who would become IIFP 

Phase 1 Employees, Currently Living within the ROI (80% 

of workforce) 

112 112 

Number of In-migrating IIFP Phase 1 Workers 28 28 

June 2010 ROI Labor Force Plus In-migrating IIFP Phase 

1 Workers 56,973 56,973 

Percent Jobs Filled by In-migrants Represent of June 

2010 ROI Labor Force 0.05% 0.05% 

June 2010 ROI, Unemployment Rate (BLS, 2010a) 7.0% 7.0% 

June 2010 ROI, Number of People Employed (BLS, 

2010a) 52,952 52,959 

June 2010 ROI, Number of People Unemployed (BLS, 

2010a) 3,993 3,993 

Number of Indirect Jobs Created (BEA, 2010b) 12 51 

Percent Indirect Jobs Represent of the June 2010 ROI 

Labor Force 0.02% 0.09% 

HOUSING 

Vacant Housing Units in the ROI (USCB, 2010d) 5,823 5,823 

Housing Units Needed for In-migrating IIFP Workers 28 28 

Percent of Needed Housing Units Represent of Vacant 

Housing Units 0.48% 0.48% 

 
 

 D-19 

Table D-10. Socioeconomic Calculations (Continued)

 Phase 1 

Construction 

Phase 1 

Operation 

PUBLIC UTILITIES

People Served by Major Public Water Suppliers in 2007-

2009 (NMED, 2010a) 88,643 88,643 

Number of IIFP Phase 1 Workers and their Family 

Members Who Would Migrate into the ROI 72 90 

Percent Increase of People to be Served by Major Public 

Water Suppliers 0.08% 0.10% 

Number of People Served by Major Public Wastewater 

Systems, 2009 (NMED, 2010b; Artesia, 2010; Carlsbad, 

2010; Appendix A; Lovington, 2010) 

78,917 78,917 

Percent Increase of People to be Served by Major 

Wastewater Systems 0.09% 0.11% 

EDUCATION 

2008 Public School Enrollment (NCES, 2010) 22,847 22,847 

Number of School-Aged children of IIFP In-migrants 

Eligible for Public School Enrollment 16 22 

Percent Increase School-aged Children In-migrants 

Represent of 2008 ROI Public School Enrollment 0.07% 0.10% 

Source: Artesia, 2010; BEA, 2010b; BLS, 2010a; Carlsbad, 2010; Appendix A, Lovington, 2010; NCES, 2010; 

NMED, 2010a; NMED, 2010b; USCB, 2010d; USCB, 2010e

D.6 References 

(Artesia, 2010) City of Artesia Water and Wastewater Department. 2010. Personal 

Communication between M. Stroud, (City of Artesia Water and Wastewater Department) and 

P. Baxter (TtNUS). September 28, 2010. ADAMS Accession No. ML112840402.

(BEA, 2010a) U.S. Department of Commerce, Bureau of Economic Analysis. 2010. 

Table CA25N-Total full-time and part-time employment in NAICS industry, Eddy County New 

Mexico, Lea County New Mexico, Andrews County Texas, Gaines County Texas, and Yoakum 

County Texas. Update April. Available at http://bea.gov/. Accessed August 20, 2010. ADAMS 

Accession No. ML112920317.

(BEA, 2010b) U.S. Department of Commerce, Bureau of Economic Analysis. 2010. RIMS II 

Multipliers for Eddy, NM and Lea, NM. Economic and Statistics Administration, Washington, 

D.C. September, 2010. ADAMS Accession No. ML112720418. 
 

 D-20 

(BLS, 2010a) U S Department of Labor, Bureau Labor Statistics. 2010.. Local Area 

Unemployment Statistics (LAUS), 2010 to 2011, New Mexico, Lea County and Eddy County 

New Mexico” Available at http://data.bls.gov/. Accessed August 23 and 31, 2010. ADAMS 

Accession No. ML103430031.

(BLS, 2010b) U.S. Department of Labor, Bureau of Labor Statistics. 2010. Local Area 

Unemployment StatisticsAndrews County Texas, Gaines County Texas, Yoakum County Texas. 

Available at hhtp://data.bls.gov/. Accessed August 23 and 31, 2010. ADAMS Accession 

No. 112710648.

(Carlsbad, 2010) City of Carlsbad Waste Water Treatment Plant. 2010. Personal 

Communication between A. Sena (City of Carlsbad Waste Water Treatment Superintendent) 

and P. Baxter (TtNUS). November 17, 2010. ADAMS Accession No. ML112840422

(ESRI, 2006) Environmental Systems Research, Inc. 2006. U.S. Census Block Groups. 

Tele Atlas North America, Inc. Redlands, CA. 

(IIFP, 2011) International Isotopes Fluorine Products, Inc. 2011. Fluorine Extraction Process 

and Depleted Uranium De-conversion Plant (FEP/DUP) Official Responses to Environmental 

Report RAIs, Revision A. March 31, 2011. ADAMS Accession No. ML110970481.

(Lovington, 2010) City of Lovington Wastewater Treatment Plant. 2010. Personal 

Communication between M. De La Cruz (City of Lovington Wastewater Treatment Plant) and 

P. Baxter (TtNUS). September 30, 2010. ADAMS Accession No. ML112840439.

(NCES, 2010) National Center for Education Statistics. 2010. Search for Public School 

Districts, Lea and Eddy Counties, New Mexico. Available at 

http://nces.ed.gov/ccd/districtsearch/. Accessed August 30, 2010. ADAMS Accession 

No. ML103430054. 

(NMED, 2010a) New Mexico Environment Department. 2010. “RE: FOIA Request.” Personal 

Communication between M. Huber (New Mexico Environment Department) and N. Hill (TtNUS). 

September 22, 2010. ADAMS Accession No. ML112850086.

(NMED, 2010b) New Mexico Environment Department, Ground Water Quality Bureau. 2010. 

Ground Water Regulated Facilities, List of Current Discharge Permits, updated 07/29/2010. 

Available at http://www.nmenv.state.nm.us/gwb/NMED-GWQB-Permits.htm. Accessed 

August 31, 2010. ADAMS Accession No. ML112710484.

(NRC, 2003). U.S. Nuclear Regulatory Commission. 2003. Environmental Review Guidance 

for Licensing Actions Associated with NMSS Programs. Final Report. NUREG 1748. 

August 2003. Division of Waste Management, Washington, D.C. ADAMS Accession 

No. ML032450279.

(USCB, 2000a) U. S. Census Bureau 2000. Summary File 1 for New Mexico: Census 2000. 

Available at http://www2.census.gov/census_2000/datasets/Summary_File_1/New_Mexico/. 

Accessed July 23, 2010. ADAMS Accession No. ML112710551.
 

 D-21 

(USCB, 2000b) U. S. Census Bureau 2000.Summary File 1 for Texas: Census 2000. Available 

at http://www2.census.gov/census_2000/datasets/Summary_File_1/Texas/. Accessed 

July 23, 2010. ADAMS Accession No. ML112710551.

(USCB, 2000c) U. S. Census Bureau 2000.Summary File 3 for New Mexico: Census 2000. 

Available at http://www2.census.gov/census_2000/datasets/Summary_File_3/New_Mexico/. 

Accessed July 23, 2010. ADAMS Accession No. ML112710554.

(USCB, 2000d) U. S. Census Bureau 2000.Summary File 3 for Texas: Census 2000. Available 

at http://www2.census.gov/census_2000/datasets/Summary_File_1/Texas/. Accessed 

July 23, 2010. ADAMS Accession No. ML112710554.

(USCB, 2000e) U. S. Census Bureau 2000. Texas Fact Sheet. Census 2000 Demographic 

Profile Highlights. American Fact Finder. Available at http://factfinder.census.gov/. Accessed 

july 27, 2010. 

(USCB, 2000f). U. S. Census Bureau 2000. New Mexico Fact Sheet. Census 2000 

Demographic Profile Highlights. American Fact Finder. Available at 

http://factfinder.census.gov/. Accessed July 27, 2010.

(USCB, 2000g) U. S. Census Bureau 2000. P92. Poverty Status in 1999 of Households by 

Household Type by Age of Householder. Detailed Tables. Census 2000 Summary File 3 

(SF 3) Sample Data. Available at http://factfinder.census.gov/. Accessed July 26, 2010.

(USCB, 2000h) U. S. Census Bureau 2000. P3. Race and P4. Hispanic or Latino, and Not 

Hispanic or Latino by Race (Total Population). Detailed Tables. Census 2000 Summary File 1 

(SF 1) 100-Percent Data. Available at http://factfinder.census.gov/. Accessed 

September 7, 2010.

(USCB, 2010a) U. S. Census Bureau. 2010. State and County Quick Facts, “Lea County and 

Eddy County New Mexico.” Revised August 16. Available at http://quickfacts.census.gov/. 

Accessed September 21, 2010. ADAMS Accession No. ML103430121. 

(USCB, 2010b) U. S. Census Bureau 2010. Table 4. Annual Estimate of the Resident 

Population for Incorporated Places, April 1 2000 to July 1 2009. New Mexico and Texas. 

Release date June 2010. Available at http://www.census.gov/. Accessed August 23, 2010.

(USCB, 2010c) U S Census Bureau. 2010. American FactFinder. New Mexico Fact Sheet. 

2005-2009 American Community Survey 5-Year Estimates. Data Profile Highlights. Available 

online at http://factfinder.census.gov. Accessed April 11, 2011. ADAMS Accession 

No. ML112720609.

(USCB, 2010d) U. S. Census Bureau. 2010. American FactFinder, Fact Sheet, American 

Community Survey 2006 - 2008, Eddy County, New Mexico, Carlsbad City, New Mexico, Hobbs 

City, New Mexico, and Lea County New Mexico. Revised August 16, 2010. Available at 

http://quickfacts.census.gov/. Accessed September 21, 2010. ADAMS Accession 

No. ML112920332.
 

 D-22 

(USCB,2010e) U. S. Census Bureau. 2010. U. S. Census Bureau. 2010. State and County 

Quick Facts, New Mexico and Lea County, New Mexico, Revised August 16. Available at 

http://quickfacts.census.gov/. Accessed September 21, 2010. ADAMS Accession 

No. ML103430126.

(USCB, 2003) U. S. Census Bureau. 2003. Table 3: County-To-County Worker Flow, 2000, 

Residence County to Workplace County Flows for New Mexico and Texas. New Mexico and 

Texas. Available at http://www.census.gov/. Accessed August 23, 2010. ADAMS Accession 

No. ML112920337.
 E-1 

APPENDIX E 

TRANSPORTATION OF RADIOACTIVE MATERIALS 
 
E-3 

TRANSPORTATION OF RADIOACTIVE MATERIALS 

E.1 Introduction 

This Appendix summarizes calculations that were used in making determinations within the EIS, 

related to the transportation of radioactive materials. The proposed IIFP Depleted Uranium 

Deconversion Plant/Fluorine Extraction Process Facility would be located in Hobbs, New 

Mexico. The facility would receive depleted uranium (DU) in the chemical form of DUF6 and 

convert it to a more stable and disposable chemical form of DUO2. The process would recover 

fluorine which would be available for sale on the market. The deconversion process requires 

transportation of the DU cylinders (full) from current storage locations at enrichment 

facilities, disposal of low-level radioactive waste (LLW), and possible transportation of empty 

DU cylinders. 

E.2 Radioactive Materials Transportation Analysis 

The DUF6 would be transported to the IIFP facility in 48Y cylinders designed for storage and 

transportation of DUF6. All current or proposed U.S. commercial enrichment facilities were 

identified as representative origins for shipments of DUF6. These are (1) Urenco USA facility 

just east of Eunice, New Mexico, (2) the GE-Hitachi Global Laser Enrichment (GLE) Facility 

north of Wilmington, North Carolina, and (3) the Areva Eagle Rock Enrichment Facility west of 

Idaho Falls, Idaho. The cylinders would be shipped one per 18-wheel truck. The empty DUF6

cylinders would be shipped back to the location of origin. In the event that cylinders are not 

returned, they could be disposed as LLW or filled with DUO2 and disposed as LLW. The empty 

cylinders are conservatively assumed to be shipped one per truck, consistent with IIFP data; 

however, two per truck is also a likely scenario. 

The DUO2 is assumed to be waste. It would be packaged into 55-gallon drums and loaded 

40 per truck (subject to weight limitations). Shipment destinations selected for analysis are 

the EnergySolutions Clive, Utah facility and the Waste Control Specialists (WCS) facility 

on the Texas-New Mexico border west of Andrews, Texas (immediately east of the 

Urenco USA facility). 

Process LLW (low-level waste resulting from the deconversion process) and miscellaneous 

LLW (low-level waste incidental to the deconversion process) volumes would be small 

compared to the DUO2 waste. The radioactivity in most of this waste would likely be less 

concentrated than the DUO2 waste. The process and miscellaneous LLW also would be 

packaged into 55-gallon drums, loaded 40 per truck, and shipped to the same disposal facilities 

as the DUO2 waste. Decommissioning waste would be similar to miscellaneous LLW and would 

be packaged into 55-gallon drums, loaded 40 per truck, and shipped to the same disposal 

facilities as the LLW and DUO2 waste. 

Routing characteristics, including distances travelled, population density along the route, and 

stop time for crew breaks and inspecting the cargo were generated by the TRAGIS Code, 

Version 1.5.4 (Johnson and Michelhaugh, 2003). Radiological impacts from radioactive material 

shipments were calculated using the RADTRAN Code, Version 5.6 (Wiener et. al, 2006). 

Input parameters for the transportation analysis were obtained from IIFP (IIFP, 2011), 

NUREG-0170 (NRC, 1977), and the Louisiana Energy Services (LES) Gas Centrifuge Facility 

License Application (REF) and are provided in Tables E-1 and E-3. The numbers of shipments 
E-4 

and relative travel distances were provided by IIFP (IIFP, 2011a)) and accident frequency and 

severity were provided by NUREG–0170 (NRC, 1977). Dimensions of packages and similar 

information presented in Tables E-1 and E-2 were from the LES Environmental Impact 

Statement (NRC, 2005). State-specific accident and fatality rates are from Table 4 of the study, 

State-Level Accident Rates for Surface Freight Transportation: A Reexamination (Saricks and 

Tompkins, 1999). 

The RADTRAN results and the Microsoft Excel calculations are provided in E-4 through E-9. 

Table E-1A. Input Parameters for 48Y Cylinders (Part 1 of 3) 

Parameter Description Input Parameters

Title of Project Truck transport of Empty/Full 48Y DUF6 Cylinder to Destination 

Accident Options Incident Free, Accident 

Output Level 1 

Health Effects Rem/Person-rem 

Package Parameters Source 

Package Name 48Y-Cylinder Appendix D, Table D-4, LES 

EIS

Long Dimension (m) 3.73 Appendix D, Table D-4, LES 

EIS

Dose Rate (mrem/h) 

 Full DUF6 Cylinders 2.80 x 10-1 mrem/hr @ 1 meter Appendix D, Table D-7, LES 

EIS

 Empty DUF6 Cylinders 1.00 mrem/hr @ 1 meter Appendix D, Table D-7, LES 

EIS

Gamma Fraction 1 RADTRAN Default

Neutron Fraction 0 RADTRAN Default

Radionuclide Parameters 

Package Name 48Y-Cylinder 

Radionuclide See Inventory 

Physical/Chemical Group Powder for solids and Gas for 

Radon 

Curies See Inventory 

Vehicle Parameters Source 

Vehicle Name Vehicle-1 

Number of Shipments 1 User Defined Value 

Vehicle Size (m) 3.73 same as package size 

Vehicle Dose Rate (mrem/h) same as package dose rate 

Gamma Fraction 1 RADTRAN Default 

Neutron Fraction 0 RADTRAN Default 

Crew Size 2 NUREG 0170 

Crew Distance 3.1 NUREG 0170 

Crew Shielding Factor 1 NUREG 0170 

Crew View 1.22 Appendix D, Table D-4, LES 

EIS 

Exclusive Use Yes RADTRAN Default 

Package 48Y-Cylinder User Defined Value 

Number of Packages 1 User Defined Value 
E-5 

Table E-1B. Input Parameters for 48Y Cylinders (Part 2 of 3) 

Parameter Description Input Parameters

Link Parameters Source 

Link Name

Vehicle Name Vehicle-1 Vehicle-1 Vehicle-1 

Length (km) Route specific, see TRAGIS output TRAGIS output

Speed (km/h) 88.49 40.25 24.16 NUREG 0170

Population Density 

(persons/km2

)

Route specific, see TRAGIS output TRAGIS output

Vehicle Density (Vehicles/h) 470 780 2800 NUREG 0170

Persons per Vehicle 2 2 2 NUREG 0170

Accident Rate (accidents/veh-km) State specific values Saricks and Tompkins, 1999, 

Table 4

Fatalities Per Accident State specific values Saricks and Tompkins, 1999, 

Table 4

Zone Rural Suburban Urban RADTRAN Default 

Type Primary Highway Primary Highway 

Primary Highway 

RADTRAN Default

Farm Fraction 0 0 0 RADTRAN Default

Stop Parameters Source 

Stop Name Stop-1 

Vehicle Name Vehicle-1

Minimum Distance 20 NUREG 0170

Maximum Distance 20 NUREG 0170

People or People/km2 50 NUREG 0170

Shielding Factor 1 RADTRAN Default 

Time (h) 4 TRAGIS output

Handling Parameters

Handle Name Handle-1 

Vehicle Name Vehicle-1 

Number of Handlers 4 NUREG 0170 (2 handlers at 

the shipping and 2 handlers 

receiving end of the route) 

Distance (m) 1 NUREG 0170 

Time (h) 0.25 NUREG 0170 (15 minutes) 
 E-6 

Table E-1C. Input Parameters for 48Y Cylinders (Part 3 of 3) Parameter Description Input ParametersAccident Parameters 

Probability Parameters 

Probability Index 0 1 2 3 4 5 6 7 NUREG 0170 Probability Fraction 0.55 0.36 0.07 0.016 0.0028 0.0011 8.50 

x 10 -5

1.50 x 10 -5

NUREG 0170

Deposition Velocity Parameters

Physical/Chemical Group Powder Gas Deposition Velocity (m/s) 0.01 0 

Release Parameters 

Physical/Chemical Group Powder Probability Index 0 1 2 3 4 5 6 7 NUREG 0170 Release Fraction 0 0.01 0.1 1 1 1 1 1 NUREG 0170 

Gas 

Probability Index 0 1 2 3 4 5 6 7 NUREG 0170Release Fraction 0 1 1 1 1 1 1 1 User defined 

value 

Aerosol Parameters

Physical/Chemical Group Powder and Gas Probability Index 0 1 2 3 4 5 6 7 NUREG 0170Aerosol Fraction 1 1 1 1 1 1 1 1 NUREG 0170

Respirable Parameters

Physical/Chemical Group Powder and Gas Probability Index 0 1 2 3 4 5 6 7 NUREG 0170Respirable Fraction 1 1 1 1 1 1 1 1 NUREG 0170Balance of RADTRAN Inputs RADTRAN Defaults 
 E-7 

Table E-2A. Input Parameters for 55-Gallon Drums (Part 1 of 3) 

Parameter Description Input Parameters

Title of Project Truck transport of 55-Gallon-Drums of DUO2/Other Waste to 

Destination 

Accident Options Incident Free, Accident 

Output Level 1 

Health Effects Rem/Person-rem 

 

Package Parameters 

Package Name 55-Gallon-Drum 

Long Dimension (m) 0.88 

Dose Rate (mrem/h) 

 DUO2 Waste 1.93 x 10-1 mrem/hr @ 

1 meter 

Response to RAI 5, Table RAI 

5-e-1

 Other Waste 3.05 x 10-2 mrem/hr @ 

1 meter 

Response to RAI 5, Table RAI 

5-e-1 (weighted average of all 

except DUO2) 

 Other Waste 9.45 x 10 -4 mrem/hr @ 

1 meter 

Response to RAI 5, Table RAI 

5-e-1 (Minimum dose rate)

Gamma Fraction 1 RADTRAN Default

Neutron Fraction 0 RADTRAN Default

Radionuclide Parameters 

Package Name 55_Gallon_Drum 

Radionuclide See Inventory 

Physical/Chemical Group Powder for solids and Gas for 

Radon 

Curies See Inventory 

Vehicle Parameters 

Vehicle Name Vehicle_1 

Number of Shipments 1 User Defined Value 

Vehicle Size (m) 12.2 the length of 20 55-gallon 

drums (assuming the drums 

are arranged 20 x 2) 

Vehicle Dose Rate (mrem/h) 6.00 x 10-2 same as package dose rate 

Gamma Fraction 1 RADTRAN Default 

Neutron Fraction 0 RADTRAN Default 

Crew Size 2 NUREG 0170 

Crew Distance 3.1 NUREG 0170 
 E-8 

Table E-2A. Input Parameters for 55-Gallon Drums (Part 1 of 3) (Continued) 

Parameter Description Input Parameters

Vehicle Parameters (con’t.)

Crew Shielding Factor 1 NUREG 0170 

Crew View 1.22 the width of 2 55-gallon drums 

Exclusive Use Yes RADTRAN Default 

Package 55 Gallon Drum User Defined Value 

Number of Packages 40 User Defined Value 

Table E-2B. Input Parameters for 55-Gallon Drums (Part 2 of 3) 

Parameter Description Input Parameters

Link Parameters 

Link Name

Vehicle Name Vehicle-1 Vehicle-1 Vehicle-1

Length (km) Route specific, see TRAGIS output TRAGIS output

Speed (km/h) 88.49 40.25 24.16 NUREG 0170

Population Density 

(persons/km2

)

Route specific, see TRAGIS output TRAGIS output

Vehicle Density (Vehicles/h) 470 780 2800 NUREG 0170

Persons per Vehicle 2 2 2 NUREG 0170

Accident Rate (accidents/veh-km) State specific values Saricks and Tompkins, 1999, 

Table 4

Fatalities Per Accident State specific values Saricks and Tompkins, 1999, 

Table 4

Zone Rural Suburban Urban RADTRAN Default 

Type Primary 

Highway 

Primary 

Highway 

Primary 

Highway 

RADTRAN Default

Farm Fraction 0 0 0 RADTRAN Default

Stop Parameters 

Stop Name Stop-1 

Vehicle Name Vehicle-1

Minimum Distance 20 NUREG 0170

Maximum Distance 20 NUREG 0170

People or People/km2 50 NUREG 0170

Shielding Factor 1 RADTRAN Default 

Time (h) 4 TRAGIS output

Handling Parameters

Handle Name Handle-1 

Vehicle Name Vehicle-1 

Number of Handlers 4 NUREG 0170 (2 handlers at 

the shipping and 2 handlers 

receiving end of the route) 

Distance (m) 1 NUREG 0170 

Time (h) 0.25 NUREG 0170 (15 minutes) 
E-9 

Table E-2C. Input Parameters for 55-Gallon Drums (Part 3 of 3) Parameter Description Input ParametersAccident Parameters 

Probability Parameters 

Probability Index 0 1 2 3 4 5 6 7 NUREG 0170 Probability Fraction 0.55 0.36 0.07 0.016 0.0028 0.0011 8.50 

x 10 -5

1.50 x 10 -5

NUREG 0170

Deposition Velocity Parameters

Physical/Chemical Group Powder Gas Deposition Velocity (m/s) 0.01 0 

Release Parameters 

Physical/Chemical Group Powder Probability Index 0 1 2 3 4 5 6 7 NUREG 0170 Release Fraction 0 0.01 0.1 1 1 1 1 1 NUREG 0170 

Gas 

Probability Index 0 1 2 3 4 5 6 7 NUREG 0170Release Fraction 0 1 1 1 1 1 1 1 User defined 

value 

Aerosol Parameters

Physical/Chemical Group Powder and Gas Probability Index 0 1 2 3 4 5 6 7 NUREG 0170Aerosol Fraction 1 1 1 1 1 1 1 1 NUREG 0170

Respirable Parameters

Physical/Chemical Group Powder and Gas Probability Index 0 1 2 3 4 5 6 7 NUREG 0170Respirable Fraction 1 1 1 1 1 1 1 1 NUREG 0170Balance of RADTRAN Inputs RADTRAN Defaults 
E-10 

Table E-3. Number of Shipments 

Phase 1 Phase 2 Cumulative 

Full DUF6 Cylinders each from Urenco USA, GLE Facility, and Areva Eagle 

Rock 293 635 928 

Empty DUF6 Cylinders each to Urenco USA, GLE Facility, and Areva Eagle 

Rock 293 496 789 

DUO2 each to Energy Solutions and WCS 155 295 476 Miscellaneous Waste each to EnergySolutions and WCS 31 20 51 Decommissioning Waste each to EnergySolutions and WCS 64 Values from Table 3-2 of IIFP, 2011 Table E-4. Incident Free RADTRAN Output 

Incident Free Transportation Impacts (Person-Rem) 

Crew Off Link On Link Totals Handling Stops 

Full DUF6 Cylinders from Urenco USA 1.03 x 10 -4 9.95 x 10 -7 1.09 x 10 -5 1.15 x 10 -4 8.02 x 10 -4 a Full DUF6 Cylinders from GLE Facility 6.96 x 10 -3 2.88 x 10 -4 2.01 x 10 -3 9.26 x 10-3 8.02 x 10 -4 1.01 x 10 -3Full DUF6 Cylinders from Areva Eagle Rock 6.13 x 10 -3 1.66 x 10 -4 1.63 x 10 -3 7.93 x 10 -3 8.02 x 10 -4 1.01 x 10 -3Empty DUF6 Cylinders to Urenco USA 3.68 x 10 -4 3.55 x 10 -6 3.88 x 10 -5 4.10 x 10 -4 2.86 x 10 -3 a Empty DUF6 Cylinders to GLE 2.49 x 10 -2 1.03 x 10 -3 7.18 x 10 -3 3.31 x 10 -2 2.86 x 10 -3 3.59 x 10 -3Empty DUF6 Cylinders to Areva Eagle Rock 2.19 x 10 -2 5.92 x 10 -4 5.84 x 10 -3 2.83 x 1 0 -2 2.86 x 10 -3 3.59 x 10 -3DUO2 to EnergySolutions 3.95 x 10 -3 3.32 x 10 -4 3.60 x 10 -3 7.88 x 10 -3 1.11 x 10 -2 1.86 x 10 -3DUO2 to WCS 7.09 x 10 -5 2.15 x 10 -6 2.35 x 10 -5 9.66 x 10 -5 1.11 x 10 -2 a Miscellaneous Waste to EnergySolutions 1.93 x 10 -5 1.63 x 10 -6 1.76 x 10 -5 3.86 x 10 -5 5.44 x 10 -5 9.13 x 10 -6Miscellaneous Waste to WCS 3.47 x 10 -7 1.05 x 10 -8 1.15 x 10 -7 4.73 x 10 -7 5.44 x 10 -5Miscellaneous Waste to EnergySolutions 6.24 x 10 -4 5.25 x 10 -5 5.69 x 10 -4 1.25 x 10-3 1.76 x 10-3 2.95 x 10 -4Miscellaneous Waste to WCS 1.12 x 10 -5 3.40 x 10 -7 3.71 x 10 -6 1.53 x 10 -5 1.76 x 10-3 a a: A stop was not assumed since the route was short. Note: The Decommissioning Waste is the same as Miscellaneous Waste. 
E-11 

Table E-5. Accident RADTRAN Output 

Accident Transportation Impacts (Person-Rem) 

Ground Inhaled Resuspended Cloudshine Total 

Full DUF6 Cylinders from Urenco USA 2.89 x 10 -8 4.25 x 10 -6 5.37 x 10 -9 3.84 x 10 -12 4.29 x 10 -6Full DUF6 Cylinders from GLE Facility 9.84 x 10 -5 1.45 x 10-2 1.83 x 10 -5 1.31 x 10 -8 1.46 x 10 -2Full DUF6 Cylinders from Areva Eagle Rock 7.30 x 10 -5 1.07 x 10-2 1.35 x 10 -5 9.67 x 10 -9 1.08 x 10 -2Empty DUF6 Cylinders to Urenco USA 2.90 x 10 -10 1.54 x 10 -8 2.31 x 10 -11 3.32 x 10 -12 1.57 x 10 -8Empty DUF6 Cylinders to GLE 9.79 x 10 -7 5.19 x 10 -5 7.80 x 10 -8 1.12 x 10 -8 5.29 x 10 -5Empty DUF6 Cylinders to Areva Eagle Rock 7.31 x 10 -7 3.87 x 10 -5 5.83 x 10 -8 8.36 x 10 -9 3.95 x 10 -5DUO2 to EnergySolutions 1.39 x 10 -4 2.17 x 10-2 2.61 x 10 -5 1.96 x 10 -8 2.19 x 10 -2DUO2 to WCS 5.18 x 10 -8 8.12 x 10 -6 9.74 x 10 -9 7.32 x 10 -12 8.18 x 10 -6Miscellaneous Waste to EnergySolutions (Low TI) 1.32 x 10 -6 1.05 x 10 -4 8.73 x 10 -7 7.44 x 10 -11 1.07 x 10 -4Miscellaneous Waste to WCS (Low TI) 4.95 x 10 -10 3.91 x 10 -8 3.27 x 10 -10 2.78 x 10 -14 3.99 x 10 -8Miscellaneous Waste to EnergySolutions 1.32 x 10 -6 1.05 x 10 -4 8.73 x 10 -7 7.44 x 10 -11 1.07 x 10 -4Miscellaneous Waste to WCS 4.95 x 10 -10 3.91 x 10 -8 3.27 x 10 -10 2.78 x 10 -14 3.99 x 10 -8Note: The Decommissioning Waste is the same as Miscellaneous Waste 
E-12 

Table E-6. Phase 1 Collective Doses to Various Receptors from Radiological Transportation 

 General Public 

Drivers and 

Passengers Persons at Stops Truck Drivers Package Handlers 

PersonSv Person- rem Person- Sv Person- rem Person- Sv Person- rem Person- Sv Person- rem Person- Sv Person- rem 

Full DUF6 Cylinders from Urenco USA 2.9 x 10 -6 2.9 x 10 -4 3.2 x 10 -5 3.2 x 10 -3 a a 3.0 x 10 -4 3.0 x 10 -2 2.3 x 10 -3 2.3 x 10 -1Full DUF6 Cylinders from GLE Facility 8.4 x 10 -4 8.4 x 10 -2 5.9 x 10 -3 5.9 x 10 -1 3.0 x 10 -3 3.0 x 10 -1 2.0 x 10 -2 2.0 2.3 x 10 -3 2.3 x 10 -1Full DUF6 Cylinders from Areva Eagle Rock 4.9 x 10 -4 4.9 x 10 -2 4.8 x 10 -3 4.8 x 10 -1 3.0 x 10 -3 3.0 x 10 -1 1.8 x 10 -2 1.8 2.3 x 10 -3 2.3 x 10 -1Empty DUF6 Cylinders to Urenco USA 1.0 x 10 -5 1.0 x 10 -3 1.1 x 10 -4 1.1 x 10 -2 a a 1.1 x 10 -3 1.1 x 10 -1 8.4 x 10 -3 8.4 x 10 -1Empty DUF6 Cylinders to GLE 3.0 x 10 -3 3.0 x 10 -1 2.1 x 10- 2 2.1 1.1 x 10 -2 1.1 7.3 x 10 -2 7.3 8.4 x 10 -3 8.4 x 10 -1Empty DUF6 Cylinders to Areva Eagle Rock 1.7 x 10 -3 1.7 x 10 -1 1.7 x 10 -2 1.7 1.1 x 10 -2 1.1 6.4 x 10 -2 6.4 8.4 x 10 -3 8.4 x 10 -1DUO2 to EnergySolutions 5.1 x 10 -4 5.1 x 10 -2 5.6 x 10 -3 5.6 x 10 -1 2.9 x 10 -3 2.9 x 10 -1 6.1 x 10 -3 6.1 x 10 -1 1.7 x 10 -2 1.7 DUO2 to WCS 3.3 x 10 -6 3.3 x 10 -4 3.6 x 10 -5 3.6 x 10 -3 a a 1.1 x 10 -4 1.1 x 10 -2 1.7 x 10 -2 1.7 Miscellaneous Waste to EnergySolutions 1.6 x 10 -5 1.6 x 10 -3 1.8 x 10 -4 1.8 x 10 -2 9.1 x 10 -5 9.1 x 10-3 1.9 x 10 -4 1.9 x 10 -2 5.5 x 10 -4 5.5 x 10 -2Miscellaneous Waste to WCS 1.1 x 10 -7 1.1 x 10 -5 1.2 x 10 -6 1.2 x 10 -4 a a 3.5 x 10 -6 3.5 x 10 -4 5.5 x 10 -4 5.5 x 10 -2DUO2 and Misc to EnergySolutions 5.3 x 10 -4 5.3 x 10 -2 5.8 x 10 -3 5.8 x 10 -1 3.0 x 10-3 3.0 x 10-1 6.3 x 10-3 6.3 x 10 -1 1.8 x 10 -2 1.8 DUO2 and Misc to WCS 3.4 x 10 -6 3.4 x 10 -4 3.8 x 10 -5 3.8 x 10 -3 a a 1.1 x 10 -4 1.1 x 10 -2 1.8 x 10 -2 1.8 Greatest risk scenario 4.4 x 10-3 4.4 x 10-1 3.3 x 10-2 3.3 1.6 x 10-2 1.6 1.0 x 10-1 1.0 x 10 2.8 x 10-2 2.8 
E-13 

Table E-7. Phase 2 Incremental Collective Doses to Various Receptors from Radiological Transportation 

General Public Drivers and Passengers Persons at Stops Truck Drivers Package Handlers 

Person-Sv 

Personrem Person-Sv Person-rem Person-Sv Person- rem Person-Sv Person-rem Person-Sv Person- rem 

Full DUF6 Cylinders from Urenco USA 6.3 x 10 -6 6.3 x 10 -4 6.9 x 10 -5 6.9 x 10-3 A a 6.5 x 10 -4 6.5 x 10-2 5.1 x 10 -3 5.1 x 10 -1Full DUF6 Cylinders from GLE Facility 1.8 x 10 -3 1.8 x 10-1 1.3 x 10 -2 1.3 6.4 x 10 -3 6.4 x 10-1 4.4 x 10 -2 4.4 5.1 x 10 -3 5.1 x 10 -1Full DUF6 Cylinders from Areva Eagle 

Rock 1.1 x 10 -3 1.1 x 10-1 1.0 x 10 -2 1.0 6.4 x 10 -3 6.4 x 10-1 3.9 x 10 -2 3.9 5.1 x 10 -3 5.1 x 10 -1

Empty DUF6 Cylinders to Urenco USA 1.8 x 10 -5 1.8 x 10-3 1.9 x 10 -4 1.9 x 10-2 A a 1.8 x 10 -3 1.8 x 10-1 1.4 x 10 -2 1.4 Empty DUF6 Cylinders to GLE 5.1 x 10 -3 5.1 x 10-1 3.6 x 10 -2 3.6 1.8 x 10 -2 1.8 1.2 x 10 -1 1.2 x 10 1.4 x 10 -2 1.4 Empty DUF6 Cylinders to Areva Eagle 

Rock 2.9 x 10 -3 2.9 x 10-1 2.9 x 10 -2 2.9 1.8 x 10 -2 1.8 1.1 x 10 -1 1.1 x 10 1.4 x 10 -2 1.4 

DUO2 to EnergySolutions 9.8 x 10 -4 9.8 x 10-2 1.1 x 10 -2 1.1 5.5 x 10 -3 5.5 x 10-1 1.2 x 10 -2 1.2 3.3 x 10 -2 3.3 DUO2 to WCS 6.3 x 10 -6 6.3 x 10 -4 6.9 x 10 -5 6.9 x 10-3 A a 2.1 x 10 -4 2.1 x 10-2 3.3 x 10 -2 3.3 Miscellaneous Waste to EnergySolutions 1.1 x 10 -5 1.1 x 10-3 1.1 x 10 -4 1.1 x 10-2 5.9 x 10 -5 5.9 x 10-3 1.2 x 10 -4 1.2 x 10-2 3.5 x 10 -4 3.5 x 10 -2Miscellaneous Waste to WCS 6.8 x 10 -8 6.8 x 10 -6 7.4 x 10 -7 7.4 x 10 -5 a a 2.2 x 10 -6 2.2 x 10 -4 3.5 x 10 -4 3.5 x 10 -2
E-14 

Table E-8. Cumulative Collective Doses to Various Receptors from Radiological Transportation 

General Public Drivers and Passengers Persons at Stops Truck Drivers Package Handlers 

Person-Sv 

Personrem Person-Sv Person-rem Person-Sv Person- rem Person-Sv Person- rem Person- Sv Person- rem 

Full DUF6 Cylinders from Urenco USA 9.2 x 10 -6 9.2 x 10 -4 1.0 x 10 -4 1.0 x 10-2 a a 9.6 x 10 -4 9.6 x 10-2 7.4 x 10-3 7.4 x 10-1Full DUF6 Cylinders from GLE Facility 2.7 x 10-3 2.7 x 10-1 1.9 x 10-2 1.9 9.4 x 10-3 9.4 x 10-1 6.5 x 10-2 6.5 7.4 x 10-3 7.4 x 10-1Full DUF6 Cylinders from Areva Eagle 

Rock 1.5 x 10-3 1.5 x 10-1 1.5 x 10-2 1.5 9.4 x 10-3 9.4 x 10-1 5.7 x 10-2 5.7 7.4 x 10-3 7.4 x 10-1

Empty DUF6 Cylinders to Urenco 

USA 2.8 x 10 -5 2.8 x 10-3 3.1 x 10 -4 3.1 x 10-2 a a 2.9 x 10-3 2.9 x 10-1 2.3 x 10-2 2.3 

Empty DUF6 Cylinders to GLE 8.1 x 10-3 8.1 x 10-1 5.7 x 10-2 5.7 2.8 x 10-2 2.8 2.0 x 10-1 2.0 x 10 2.3 x 10-2 2.3 Empty DUF6 Cylinders to Areva Eagle 

Rock 4.7 x 10-3 4.7 x 10-1 4.6 x 10-2 4.6 2.8 x 10-2 2.8 1.7 x 10-1 1.7 x 10 2.3 x 10-2 2.3 

DUO2 to Energy Solutions 1.6 x 10-3 1.6 x 10-1 1.7 x 10-2 1.7 8.9 x 10-3 8.9 x 10-1 1.9 x 10-2 1.9 5.3 x 10-2 5.3 DUO2 to WCS 1.0 x 10 -5 1.0 x 10-3 1.1 x 10 -4 1.1 x 10-2 a a 3.4 x 10 -4 3.4 x 10-2 5.3 x 10-2 5.3 Miscellaneous Waste to EnergySolutions 2.7 x 10 -5 2.7 x 10-3 2.9 x 10 -4 2.9 x 10-2 1.5 x 10 -4 1.5 x 10-2 3.2 x 10 -4 3.2 x 10-2 9.0 x 10 -4 9.0 x 10-2Miscellaneous Waste to WCS 1.7 x 10 -7 1.7 x 10 -5 1.9 x 10 -6 1.9 x 10 -4 a a 5.7 x 10 -6 5.7 x 10 -4 9.0 x 10 -4 9.0 x 10-2Decommissioning Waste to EnergySolutions 3.4 x 10 -5 3.4 x 10-3 3.6 x 10 -4 3.6 x 10-2 1.9 x 10 -4 1.9 x 10-2 4.0 x 10 -4 4.0 x 10-2 1.1 x 10-3 1.1 x 10-1Decommissioning Waste to WCS 2.2 x 0 -7 2.2 x 10 -5 2.4 x 10 -6 2.4 x 10 -4 a a 7.2 x 10 -6 7.2 x 10 -4 1.1 x 10-3 1.1 x 10-1DUO2 and Misc to EnergySolutions 1.6 x 10-3 1.6 x 10-1 1.7 x 10-2 1.7 9.0 x 10-3 9.0 x 10-1 1.9 x 10-2 1.9 5.4 x 10-2 5.4 DUO2 and Misc to WCS 1.0 x 10 -5 1.0 x 10-3 1.1 x 10 -4 1.1 x 10-2 a a 3.4 x 10 -4 3.4 x 10-2 5.4 x 10-2 5.4 Greatest risk scenario 1.2 x 10--2 1.2 9.3 x 10--2 9.3 4.7 x 10--2 4.7 2.8 x 10-1 2.8 x 10 8.4 x 10--2 8.4 
E-15 

Table E-9. Annual Accident Dose-Risk and LCF-Risk From Radiological Transportation 

 Dose-Risk LCF Risk 

Person-Sv Person-rem 

Full DUF6 Cylinders from Urenco USA 1.3 x 10 -5 1.3 x 10-3 7.5 x 10 -7Full DUF6 Cylinders from GLE Facility 4.3 x 10-2 4.3 2.6 x 10-3Full DUF6 Cylinders from Areva Eagle Rock 3.2 x 10-2 3.2 1.9 x 10-3Empty DUF6 Cylinders to Urenco USA 4.6 x 10 -8 4.6 x 10 -6 2.8 x 10 -9Empty DUF6 Cylinders to GLE 1.5 x 10 -4 1.5 x 10-2 9.3 x 10 -6Empty DUF6 Cylinders to Areva Eagle Rock 1.2 x 10 -4 1.2 x 10-2 6.9 x 10 -6DUO2 to EnergySolutions 6.4 x 10-2 6.4 3.9 x 10-3DUO2 to WCS 2.4 x 10 -5 2.4 x 10-3 1.4 x 10 -6Miscellaneous Waste to EnergySolutions 3.1 x 10 -4 3.1 x 10-2 1.9 x 10 -5Miscellaneous Waste to WCS 1.2 x 10 -7 1.2 x 10 -5 7.0 x 10 -9Decommissioning Waste to EnergySolutionsa 3.1 x 10 -4 3.1 x 10-2 1.9 x 10 -5Decommissioning Waste to WCSa 1.2 x 10 -7 1.2 x 10 -5 7.0 x 10 -9Greatest Risk Scenario 1.1 x 10-1 1.1 x 10 6.4 x 10-3aRepresents total campaign—not annualNote: latent cancer fatalities per person rem (ISCORS, 2002) = 6.00 x 10 -4
 E-16 

E.3 References 

(IIFP, 2011) International Isotopes Fluorine Products. 2011. Fluorine Extraction Process and 

Depleted Uranium De-conversion Plant (FEP/DUP) Official Responses to Environmental Report 

RAIs, Revision A. March 31, 2011. ADAMS Accession No. ML110970481. 

(ISCORS, 2002) Interagency Steering Committee on Radiation Standards. 2002. “A Method 

for Estimating Radiation Risk from Total Effective Dose Equivalent (TEDE),” ISCORS Technical 

Report 2002-02, Final Report, Washington, D.C. ADAMS Accession No. ML112720579. 

(Johnson and Michelhaugh, 2003) Johnson, P. E. and R. D. Michelhaugh. 2003. 

Transportation Routing Analysis Geographic Information System (TRAGIS) User’s Manual. Oak 

Ridge National Laboratory, Oak Ridge, Tennessee. June 2003. 

(NRC, 1977) U.S. Nuclear Regulatory Commission. 1977. Final Environmental Statement on 

the Transportation of Radioactive Material by Air and Other Modes, NUREG-0170. Office of 

Standards Development. December 1977. 

(NRC, 2005) U.S. Nuclear Regulatory Commission. 2005. Final Environmental Impact 

Statement for the Proposed National Enrichment Facility in Lea County, New Mexico/ 

NUREG–1790, June 2005. ADAMS Accession No. ML051730238. 

(Saricks and Tompkins, 1999) Saricks, C.L. and M.M. Tompkins. 1999 State-Level Accident 

Rates for Surface Freight Transportation: A Reexamination, ANL/ESD/TM-150, Argonne 

National Laboratory, April 1999. ADAMS Accession No. ML112720605. 

(Wiener et. al, 2006) Wiener R. F., D. M. Osborn, G.S. Mills, D. Hinojosa, T. L. Heames, and 

D. J. Orcutt. 2006. “RadCat 2.3 User Guide.” SAND2006-6315, Sandia National Laboratories, 

Albuquerque, New Mexico. 
F–1 

APPENDIX F 

PUBLIC PARTICIPATION AND 

NRC RESPONSE TO COMMENTS 

ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT 

F–3 

PUBLIC PARTICIPATION AND 

NRC RESPONSE TO COMMENTS 

ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT 

F.1 INTRODUCTION 

This appendix summarizes the public participation process the U.S. Nuclear Regulatory 

Commission (NRC) staff conducted for the environmental review and preparation of the 

Environmental Impact Statement (EIS) for the proposed construction, operation, and 

decommissioning of an International Isotopes Fluorine Products, Inc. (IIFP) fluorine extraction 

process and depleted uranium deconversion plant. If built, the proposed IIFP facility would be 

located in Lea County, New Mexico. This appendix also presents all of the comments NRC 

received on the draft EIS and the staff’s response to those comments. NRC has considered 

and addressed 410 comments received from 103 members of the public, government officials 

and agencies, and nongovernmental organizations. Comments from 28 individuals were 

submitted under a single cover; three members of the public each submitted two separate 

comment documents, and four members of the public submitted both written and oral 

comments. A total of 109 documents were considered, including the transcript of oral 

comments that six individuals provided at the public meeting the NRC staff conducted on 

February 2, 2012. The transcript of the public meeting is available in the NRC Agencywide 

Documents Access and Management System (ADAMS) database (Accession Number 

ML120390370) on the NRC Web site (http://www.nrc.gov/reading-rm/adams.html). 

F.2 PUBLIC PARTICIPATION 

This section describes the public participation process during the NRC staff’s development of 

the EIS for the proposed IIFP facility. Public participation is an essential part of the NRC 

environmental review under the National Environmental Policy Act of 1969 (NEPA), as 

amended. NRC conducted an open, public EIS development process consistent with NEPA 

and the NRC’s regulations under 10 CFR Part 51. 

F.2.1 Initial Notification and Notice of Formal Proceeding 

Upon receipt of IIFP’s license application for the proposed facility and completion of an initial 

acceptance review, NRC published on April 5, 2010, a Notice of Opportunity to Request a 

Hearing in the Federal Register (FR) (75 FR 17170). On July 15, 2010, the NRC staff 

published a Notice of Intent (NOI) to Prepare an Environmental Impact Statement in the Federal 

Register (75 FR 41242). The NRC’s environmental review began following acceptance and 

docketing of the environmental report pursuant to the requirements of 10 CFR 70.65 and 

10 CFR 51.60, respectively. 

F.2.2 Public Scoping 

The NRC is required under 10 CFR 51.20(b)(10) to prepare an EIS, and under 10 CFR 51.26 to 

issue an NOI to prepare the EIS and conduct a scoping process for the EIS. The NRC’s public 

scoping process for the EIS began on July 15, 2010, with the publication in the Federal Register

(75 FR 41242) of an NOI to prepare an EIS. The NOI summarized the NRC’s plans to prepare 

an EIS and presented background information on the proposed IIFP facility. The NOI also 

invited comments on the appropriate scope of issues to be considered and announced NRC’s 
F–4 

plan to hold a public scoping meeting. The public scoping comment period ended on 

August 30, 2010. 

On July 29, 2010, the NRC staff held a public scoping meeting in Hobbs, New Mexico, to 

receive oral and written comments from interested parties. In addition to the announcement of 

the meeting in the Federal Register (75 FR 41242) on July 15, 2010, the meeting was publicized 

on the NRC Web site, in a local newspaper, and on local radio. At the public scoping meeting, 

the NRC staff described NRC’s roles, responsibilities, and mission; gave a brief overview of its 

environmental and safety review processes; discussed how the public could participate 

effectively in the environmental review process; and solicited input from the public on 

environmental concerns related to the proposed IIFP facility. Approximately 60 members of the 

public participated in the meeting. The ADAMS Accession Number for the scoping meeting 

transcript is ML102210424. Most of the meeting was reserved for attendees to ask questions 

and provide comments on the scope of the environmental review. Prior to the public scoping 

meeting, the NRC staff hosted an informal “open house” for those who wished to attend. The 

open house provided members of the public with an opportunity to speak informally with 

individual NRC staffers. Appendix A (Scoping Summary) includes the scoping summary report 

that summarizes the comments received during the scoping process. 

F.2.3 Issuance and Availability of the Draft EIS 

Pursuant to 10 CFR 51.74, on January 13, 2012, the NRC staff published a Notice of Availability 

(NOA) of the draft EIS in the Federal Register (77 FR 2096). In this notice, the NRC staff 

described how to access and obtain a copy of the draft EIS. The U.S. Environmental Protection 

Agency issued a Notice of Availability on the same day (77 FR 2060). The NRC provided a 45 

day public comment period which ended on February 27, 2012. The NRC distributed the draft 

EIS to approximately 55 individuals including Federal, State, and local government agencies, 

tribal governments, and members of the public. Electronic versions of the draft EIS and 

supporting information were made accessible through the NRC’s project-specific Web site 

(http://www.nrc.gov/materials/fuel-cycle-fac/inisfacility.html) and through the NRC ADAMS 

database Web site (http://www.nrc.gov/reading-rm/adams.html). The public also had the 

opportunity to examine and request a copy of the draft EIS and other related publicly available 

documents from the NRC Public Document Room. A copy of the draft EIS was also made 

available at the Hobbs Public Library. 

F.2.4 Draft EIS Public Comment Meeting 

The NRC staff conducted a public meeting on February 2, 2012, to receive comments on the 

draft EIS. The NRC staff selected the City of Hobbs as the location for the meeting because it is 

the closest city to the proposed IIFP facility. The NRC staff advertised these meetings in a local 

newspaper and on radio stations. Six individuals provided comments during the meeting. A 

court reporter recorded the oral comments and prepared a written transcript (ADAMS Accession 

Number ML120390370). The meeting transcripts are also available in the NRC’s public Web 

site for the proposed IIFP facility, at http://www.nrc.gov/materials/fuel-cycle-fac/inisfacility.html. 

The transcript is part of the public record for the proposed project and was used in developing 

the applicable comment summaries contained in this appendix. 
F–5 

F.3 COMMENTS RECEIVED ON THE DRAFT EIS 

As discussed above, the NRC staff received both oral and written comments on the draft EIS 

during the comment period. The 45-day public comment period ended on February 27, 2012. 

The NRC staff considered and addressed approximately 410 comments received from 

103 members of the public, government officials and agencies, and nongovernmental 

organizations. A total of 109 documents were considered, including the transcript of oral 

comments that 6 individuals provided at the public meeting the NRC staff conducted on 

February 2, 2012. 

F.3.1 Commenter and Comment Identification 

The NRC staff reviewed the public meeting transcript, letters, and emails (documents) to identify 

and extract the individual comments on the draft EIS. These comments are presented in 

Section F.4. 

The NRC staff identified each individual or entity that submitted a comment or document. The 

NRC staff then assigned a unique identification number to each document, to aid the readers of 

this appendix in locating the comments and the NRC staff’s corresponding responses. The 

meeting transcript was given its own designation (i.e., TA is the first commenter in the meeting 

transcript; TB is the second commenter in the meeting transcript, and so on). Table F3–1 lists 

all of the commenters on the draft EIS alphabetically by last name, their affiliation (if provided), 

their associated document number, the ADAMS accession number(s) of the document(s) in 

which each comment appears, and the section(s) in this appendix that address the individual’s 

comments. On the NRC public Web site identified in Section F.2.3, readers can use the 

ADAMS accession numbers provided in these tables to electronically search for specific 

individual’s comments. 

The NRC staff reviewed each comment and assigned it a unique number for identification in 

Section F.4. For documents submitted by only one author, each specific comment in that 

document is identified by a number using the format xx-yy. The first number (xx) identifies the 

document. The second number (yy) identifies a comment within the document. For example, 

comment 02-05 would identify the fifth comment (xx-05) in the second document (02-yy) NRC 

received. For documents submitted by multiple authors, each specific comment is identified by 

a number using the format xx-zz-yy. As before, the first and last numbers (xx and yy) identify 

the document and specific comment, respectively. The middle number (zz) identifies the author 

within the document. For example, 54-03-01 identifies the first comment (xx-zz-01) in the third 

letter (xx-03-yy) of the 54th document (54-zz-yy) that NRC received. The only comment 

document with more than one letter for this draft EIS was comment document 54 for which each 

letter was from a different author. 

F.3.2 Comment Organization, Review, and Response 

In addition to the numbering, each identified comment was assigned a topic category based on 

the content and issues raised. This allowed the NRC staff to facilitate sorting and reviewing 

comments on similar topics. The NRC staff sorted and reviewed all comments within specific 

topic categories, developed comment summaries and responses, and where appropriate, made 

changes to the EIS. 
 F–6 

Table F.3–1. Public Commenter Names With Affiliation, When Provided; Comment Document Number; 

ADAMS Accession Number; and Subsections Containing Comments and Responses 

Name Affiliation 

Document 

Number 

ADAMS 

Accession Number 

Subsections 

Containing Comments 

and Responses 

Allgood, Lane Partnership for Science and Technology 63 ML12060A027 F.4.1, F.4.9, F.4.12 Anonymous Member of the Public 01 ML12019A115 F.4.6 Anonymous Member of the Public 23 ML12038A024 F.4.1, F.4.15 Barr, Clifford Member of the Public 02, 04 ML12019A117 

ML12019A116 

F.4.5, F.4.6 

Barr, Phil Member of the Public 03, 05 ML12023A053 

ML12023A054 

F.4.5, F.4.6, F.4.9 

Beall, Troy B&D Industries 07 

ML12027A143 F.4.1, F.4.9, F.4.12 

Bearden, Kathi Tactical Security Solutions, LLC 36 ML12040A042 F.4.1, F.4.9, F.4.12 Black, Ron Lea County Commissioner 31 ML12040A037 F.4.1, F.4.9, F.4.12 Borlenghi, Giorgio Member of the Public 18 ML12033A165 F.4.1, F.4.9, F.4.12 Brunson, Hal Hobbs City Commissioner 43 ML12040A049 F.4.1, F.4.9, F.4.12 Bryan, Cindy Accounting and Consulting Group, LLC 22 ML12034A108 F.4.1, F.4.9, F.4.12 Buie, Garry Pemco of New Mexico 28 ML12040A034 F.4.1, F.4.9, F.4.12 Burns, Marilyn J. Mayor, Town of Tatum, New Mexico 73 ML12072A071 F.4.1, F.4.9, F.4.12 Campbell, Paul Forrest Tire Company 27 ML12040A032 F.4.1, F.4.9, F.4.12 Chedekel, Miles Member of the Public TI ML120390370 F.4.15 Cisneros, Sara B. Hobbs Hispano Chamber of Commerce 38 ML12040A044 F.4.1, F.4.9Clifton, Trent Steel Depot 59 

ML12059A289 F.4.1, F.4.9, F.4.12 

Diaz, Regina Member of the Public 54-18 ML12048A272 F.4.1, F.4.9, F.4.12 Dunlap, Tami Member of the Public 54-26 ML12048A272 F.4.1, F.4.9, F.4.12 Ebel, Sylvia Member of the Public 54-3 ML12048A272 F.4.1, F.4.9, F.4.12 Ensey, Michelle New Mexico State Historical 

Preservation District 

66 ML12060A283 F.4.4 

Ensminger, Joe Glen Member of the Public 54-14 ML12048A272 F.4.1, F.4.9, F.4.12 Ensminger, Sharon Member of the Public 54-16 ML12048A272 F.4.1, F.4.9, F.4.12 Estrada, Dana Member of the Public 54-28 ML12048A272 F.4.1, F.4.9, F.4.12 Fairman, Carl Member of the Public 54-8 ML12048A272 F.4.1, F.4.9, F.4.12 Fisher, Darrell Washington State University, Health 

Physics Society 

09 ML12027A145 F.4.1, F.4.9, F.4.12 

Frentzel, Chris International Brotherhood of Electrical 

Workers, Local 611 

46 ML12048A382 F.4.1, F.4.9, F.4.12 
 F–7 

Table F.3–1. Public Commenter Names With Affiliation, When Provided; Comment Document Number; 

and ADAMS Accession Number; and Subsections Containing Comments and Responses (continued) 

Name Affiliation 

Document 

Number 

ADAMS 

Accession Number 

Subsections 

Containing Comments 

and Responses 

Gallagher II, Michael P. Lea County Board of County Commissioners 41, TF ML12040A047 

ML120390370 

F.4.1, F..4.5, F.4.7, F.4.9, F.4.12 

Garcia, Maribel Member of the Public 54-24 ML12048A272 F.4.1, F.4.9, F.4.12 Gardner, Rose Member of the Public TH ML120390370 F.4.7, F.4.12, F.4.15 Green, Barbara Sullivan Green Seavy LLC 68 ML12062A107 F.4.12 Gonzalez, Mayolo Member of the Public 54-20 ML12048A272 F.4.1, F.4.9, F.4.12 Haddad, Lara Member of the Public 54-5 ML12048A272 F.4.1, F.4.9, F.4.12 Hager, Douglas Member of the Public 54-6 ML12048A272 F.4.1, F.4.9, F.4.12 Hager, Michael Member of the Public 54-7 ML12048A272 F.4.1, F.4.9, F.4.12 Heier, Kevin Member of the Public 54-23 ML12048A272 F.4.1, F.4.9, F.4.12 Hardison, Lisa Economic Development Corporation of 

Lea County 

42, TC ML12040A048 

ML120390370 

F.4.1, F.4.9, F.4.12 

Hayes, Robert Member of the Public TE, TG ML120390370 F.4.1, F.4.11, F.4.12 Herring, J. Stephen Member of the Public 67 ML12062A106 F.4.1, F.4.9, F.4.12 Hoyl, Mike Western Commerce Bank 49 ML12048A386 F.4.1, F.4.9, F.4.12 Hulsey, Chris Member of the Public 54-27 ML12048A272 F.4.1, F.4.9, F.4.12 Keane, James Member of the Public 20 ML12033A200 F.4.1, F.4.9, F.4.12 Jacli, Jack Member of the Public 70 ML12067A040 F.4.1, F.4.9, F.4.12 Jamison, Janice Member of the Public 44 ML12040A050 F.4.1, F.4.9, F.4.12 Jeff, David G. Development Corporation of Lea County 29 ML12040A035 F.4.1, F.4.9, F.4.12 Jianto, Linda Member of the Public 54-15 ML12048A272 F.4.1, F.4.9, F.4.12 Kernan, Gay G. New Mexico State Senate 40 ML12040A046 F.4.1, F.4.9 Lea County Commissioners Lea County Board of County Commissioners 45 ML12044A129 F.4.1, F.4.5, F.4.7, 

F.4.9, F.4.12 

Leavell, Carroll H. New Mexico State Senate 26 ML12040A031 F.4.1, F.4.9 Legg, Ladona Member of the Public 54-17 ML12048A272 F.4.1, F.4.9, F.4.12 Leighton, Michael Lovington City Manager 37 ML12040A043 F.4.1, F.4.9, F.4.12 Magette, Thomas E. EnergySolutions 60 ML12059A290 F.4.1, F.4.9, F.4.12Manning, Dennis Boron Products, LLC 11 ML12032A025 F.4.1, F.4.9, F.4.12 Marschke, Kerry Member of the Public 54-25 ML12048A272 F.4.1, F.4.9, F.4.12 Martin, Charles R. Charles Martin Custom Homes 53 ML12048A392 F.4.1, F.4.9, F.4.12 Mayer, M Member of the Public 16 ML12033A163 F.4.1, F.4.9, F.4.12 McCleery, Steve New Mexico Junior College 35 ML12040A041 F.4.1, F.4.9, F.4.12 McCool, Jeff New Mexico Junior College 21 ML12033A201 F.4.1, F.4.9, F.4.12 
 F–8 

Table F.3–1. Public Commenter Names With Affiliation, When Provided; Comment Document Number; 

and ADAMS Accession Number; and Subsections Containing Comments and Responses (continued) 

Name Affiliation 

Document 

Number 

ADAMS 

Accession Number 

Subsections 

Containing Comments 

and Responses 

McKenzie-Carter, Michael A. Member of the Public 65 ML12060A282 F.4.1, F.4.9, F.4.12 Medina, Patricia Member of the Public 54-13 ML12048A272 F.4.1, F.4.9, F.4.12 Milner, Sandra Member of the Public 54-2 ML12048A272 F.4.1, F.4.9, F.4.12 Moore, Jodi Member of the Public 54-10 ML12048A272 F.4.1, F.4.9, F.4.12 Moran, Kathleen A. Member of the Public 39 ML12040A045 F.4.1, F.4.5, F.4.9 N, Mitchell Member of the Public 14 ML12033A161 F.4.1, F.4.9, F.4.12 Nadel, Marshall Member of the Public 08 ML12027A144 F.4.1, F.4.9, F.4.12 Nash, Sandy Steel Depot 33 ML12040A039 F.4.1, F.4.9, F.4.12 Nelson, Audrey Member of the Public 06 ML12023A055 F.4.1, F.4.9, F.4.12 Nesser, Brad NPSR Architects 56 ML12059A286 F.4.1, F.4.9, F.4.12 Neuwirth, Paul D. Member of the Public 74 ML12072A073 F.4.1, F.4.9, F.4.12 Neuwirth, Richard Member of the Public 52 ML12048A391 F.4.1, F.4.9, F.4.12 Newman, Monty D. Newman & Company 25 ML12040A030 F.4.1, F.4.9, F.4.12 Newsome, William Southwest Capital, LLC 17 ML12033A164 F.4.1, F.4.9, F.4.12 Nisula, Amanda L. Bureau of Land Management Carlsbad 

Field Office 

69 ML12066A143 F.4.15 

Nunley, Dana Member of the Public 54-4 ML12048A272 F.4.1, F.4.9, F.4.12 Parker, Pj City of Jal Special Projects Administrator 48 ML12048A384 F.4.1, F.4.9, F.4.12Pettigrew, Randy Lovington Economic 

Development Corporation 

30 ML12040A036 F.4.1, F.4.9, F.4.12 

Pless, Rebecca Member of the Public 54-12 ML12048A272 F.4.1, F.4.9, F.4.12 Prestwich, Erika Member of the Public 10 ML12030A092 F.4.1, F.4.9, F.4.12 Pucio, Connie Member of the Public 54-11 ML12048A272 F.4.1, F.4.9, F.4.12 Reagan, Gary Don City of Hobbs 51, TB ML12048A388 

ML120390370 

F.4.1, F.4.9, F.4.12 

Riley, Hollis International Brotherhood of 

Electrical Workers 

71 ML12067A041 F.4.1, F.4.9, F.4.12 

Roybal, Julie New Mexico Environment Department 62 ML12059A292 

F.4.2, F.4.5, F.4.10, F.4.12 

Schubert, Gary Member of the Public 47 ML12048A383 F.4.1, F.4.9, F.4.12 Sena, Jonathan Hobbs City Commissioner 34, 55 ML12040A040 

ML12059A285 

F.4.1, F.4.9, F.4.12 

Sharif, Farok URS Washington Resolutions (WIPP) TA ML120390370 F.4.1, F.4.9, F.4.12 Smith, Kurt Member of the Public 12 ML12033A072 F.4.1, F.4.9, F.4.12 
 F–9 

Table F.3–1. Public Commenter Names With Affiliation, When Provided; Comment Document Number; 

and ADAMS Accession Number; and Subsections Containing Comments and Responses (continued) 

Name Affiliation 

Document 

Number 

ADAMS 

Accession Number 

Subsections 

Containing Comments 

and Responses 

Smith, Rhonda U.S. Environmental Protection Agency 72 ML12067A096 F.4.3, F.4.4, F.4.5, 

F.4.6, F.4.7, F.4.9, F.4.11, F.4.12 

Spence, Novlette Member of the Public 54-9 ML12048A272 F.4.1, F.4.9, F.4.12 Spencer, Samuel S. Lea County State Bank 32, TD ML12040A038 

ML120390370 

F.4.1, F.4.9, F.4.12 

Spencer, Stephen R. U.S. Department of the Interior 61 ML12059A291 F.4.13, F.4.15 Stovall, David G. SGA, LLP 57 ML12059A287 F.4.1, F.4.9, F.4.12 Suprenant, Jamie Member of the Public 54-1 ML12048A272 F.4.1, F.4.9, F.4.12 Tanner, John Member of the Public 24 ML12040A029 F.4.1, F.4.9, F.4.12 Taylor, Grant Hobbs Chamber of Commerce 19 ML12033A167 F.4.1, F.4.9 Tomar, Sally Member of the Public 50 ML12048A387 F.4.1, F.4.9, F.4.12 Tomborello, Justin Member of the Public 13 ML12034A026 F.4.1, F.4.9, F.4.12 Torres, Katrina Member of the Public 54-19 ML12048A272 F.4.1, F.4.9, F.4.12 Tuttle-Wurth, Judy Member of the Public 54-22 ML12048A272 F.4.1, F.4.9, F.4.12 Unknown Individual Member of the Public 15 ML12033A162 F.4.1, F.4.9, F.4.12 Wallace, Krystal Member of the Public 54-21 ML12048A272 F.4.1, F.4.9, F.4.12 Wallach, Robert Wallach Concrete, Inc 58 ML12059A288 F.4.1, F.4.9, F.4.12 Wunder, Matthew New Mexico Department of Game & Fish 64 ML12060A281 F.4.8, F.4.14 
F–10 

The NRC staff consolidated the same or similar comments received either from a specific 

commenter or from multiple commenters within each topic to develop responses, as allowed by 

NRC regulations in 10 CFR 51.91. This grouping is also consistent with the Council on 

Environmental Quality’s NEPA regulations at 40 CFR 1503.4(b). This approach allowed 

multiple comments to be addressed with a single response, avoided duplication of effort, and 

enhanced readability of this appendix. Each comment or group of similar comments is 

introduced with a brief summary by the NRC staff. The summary is followed by the comment 

identification number(s), commenter name(s) and then the text of the comment(s). This is then 

followed by the NRC response. For cases in which comments have resulted in a modification to 

the draft EIS, those changes are noted in the staff’s response and are included in the Final EIS. 

All other comments resulted in no modifications to the draft EIS. 

F.3.3 Major Issues and Topics 

The majority of the comments received specifically addressed the scope of the environmental 

reviews, analysis, and issues contained in the draft EIS, including statutory and regulatory 

requirements, NRC outreach activities, historic and cultural resources, air quality, geology and 

soils (seismic hazards), water resources, ecological resources, socioeconomics and 

environmental justice, noise, public and occupational health, waste management, and accidents 

(wildfires), and cumulative impacts. However, other comments addressed topics and issues 

that were not part of the review process for the proposed action. Those comments included 

questions about the NRC’s safety evaluation of the proposed IIFP facility, emergency response, 

and general statements of support for nuclear power. 

F.3.4 Comments on Out-of-Scope Topics 

The scope of the EIS analysis is defined in 10 CFR 51.71(a); 10 CFR 51.91; NUREG–1748, 

‘‘Environmental Review Guidance for Licensing Actions Associated With NMSS Programs’’ 

(NRC, 2003); and the Scoping Summary Report in Appendix A of this EIS. Some comments 

addressed issues that were not specifically related to the NRC’s environmental review of IIFP’s 

application to construct, operate, and decommission the proposed deconversion facility. 

Because these comments did not directly relate to the environmental impacts of the 

proposed action and were outside the scope of the NEPA review, the NRC did not prepare 

detailed responses. 

F.4 COMMENT SUMMARIES AND RESPONSES 

All of the comments NRC received on the draft EIS and the NRC staff's responses to those 

comments are presented in this section. The comments are arranged by topic and multiple 

comments that address a similar issue/topic have been grouped together for a common 

response. If multiple individuals provided a similar comment, the comment is presented once, 

preceded by the names of all the commenters. Text received from commenters in several 

cases contained more than one issue/topic. In some cases deletion of text to separate topics 

would have altered the message in the text. In these cases the text has been kept intact, but 

has been repeated in as many sections as needed to ensure all the issues are addressed. 

Written comments are reproduced in this appendix “as received” (i.e., the NRC staff did not 

correct spelling or grammatical errors in these comments). Also, NRC acknowledges the 

possibility of transcription errors by the court reporters during the public comment meetings, and 

regrets any oral comment text that does not exactly match what was said at the public meeting. 
F–11 

F.4.1 General Support for the Project 

The comments addressed in this subsection express general support for the proposed IIFP 

facility. Some supporting comments which include topics within the scope of the EIS are not 

included in this subsection, but are instead included and addressed in the subsections relevant 

to the specific topics discussed. 

Comment Summary: The following comments express general support for the proposed IIFP 

project. 

[06-01, Audrey Nelson; 07-01, Troy Beall; 08-01, Marshall Nadel; 10-01, Erika Prestwich; 

11-01, Dennis Manning; 12-01, Kurt Smith; 13-01, Justin Tomborello; 14-01, Mitchell N.; 

15-01, Unknown Individual; 16-01, M. Mayer; 17-01, William Newsome; 18-01, 

Giorgio Borlenghi; 20-01, James Keane; 22-01, Cindy Bryan; 25-01, Monty D. Newman; 

27-01, Paul Campbell; 28-01, Garry Buie; 29-01, David G. Jeff; 30-01, Randy Pettigrew; 

31-01, Ron Black; 33-01, Sandy Nash; 34-01, 55-01, Jonathan Sena; 36-01, Kathi Bearden; 

37-01, Michael Leighton; 38-01, Sara B. Cisneros on behalf of the Hobbs Hispano 

Chamber of Commerce Board of Directors; 43-01, Hal Brunson; 44-01, Janice Jamison; 

46-01, Chris Frentzel on behalf of the International Brotherhood of Electrical Workers 

(IBEW), Local 611; 47-01, Gary Schubert; 48-01, Pj Parker; 49-01, Mike Hoyl; 50-01, 

Sally Tomar; 51-01, TB-01, Gary Don Raegan; 52-01, Richard H. Neuwirth; 53-01, Charles 

R. Martin; 54-01-01, Jamie Suprenant; 54-02-01, Sandra Milner; 54-03-01, Sylvia Ebel; 

54-04-01, Dana Nunley; 54-05-01, Lara Haddad; 54-06-01, Douglas Hager; 54-07-01, 

Michael Hager; 54-08-01, Carl Fairman; 54-09-01, Novlette Spence; 54-10-01, Jodi Moore; 

54-11-01, Connie Pucio; 54-12-01, Rebecca Pless; 54-13-01, Patricia Medina; 54-14-01, 

Joe Glen Ensminger; 54-15-01, Linda Jianto; 54-16-01, Sharon Ensminger; 54-17-01, 

LaDona Legg; 54-18-01, Regina Diaz; 54-19-01, Katrina Torres; 54-20-01, Mayolo 

Gonzalez; 54-21-01, Krystal Wallace; 54-22-01, Judy Tuttle-Wurth; 54-23-01, Kevin Heier; 

54-24-01, Maribel Garcia; 54-25-01, Kerry Marschke; 54-26-01, Tami Dunlap; 54-27-01, 

Chris Hulsey; 54-28-01, Dana Estrada; 56-01, Brad Nesser; 57-01, David G. Stovall; 58-01, 

Robert Wallach; 59-01, Trent Clifton; 63-01, Lane Allgood on behalf of the Partnership for 

Science and Technology; 70-01, Jack Jacli; 71-01, Hollis Riley; and 73-01, Marilyn Burns] 

I support this project (the construction of a depleted uranium deconversion plant as proposed by 

International Isotopes, Inc.) and believe that it will be a positive contribution to Lea County. 

[06-02, Audrey Nelson; 07-02, Troy Beall; 08-02, Marshall Nadel; 09-01, Darrell Fisher; 

10-02, Erika Prestwich; 11-02, Dennis Manning; 12-02, Kurt Smith; 13-02, 

Justin Tomborello; 14-02, Mitchell N.; 15-02, Unknown Individual; 16-02, M. Mayer; 17-02, 

William Newsome; 18-02, Giorgio Borlenghi; 20-02, James Keane; 22-02, Cindy Bryan; 

 25-02, Monty D. Newman; 26-01, Carroll H. Leavell; 27-02, Paul Campbell; 28-02, 

Garry Buie; 29-02, David G. Jeff; 30-02, Randy Pettigrew; 31-02, Ron Black; 32-01, 

Samuel S. Spencer; 33-02, Sandy Nash; 34-02, 55-02, Jonathan Sena;; 36-02, 

Kathi Bearden; 37-02, Michael Leighton; 38-02, Sara B. Cisneros on behalf of the Hobbs 

Hispano Chamber of Commerce Board of Directors; 43-02, Hal Brunson; 44-02, 

Janice Jamison; 46-02, Chris Frentzel on behalf of the International Brotherhood of 

Electrical Workers (IBEW), Local 611; 47-02, Gary Schubert; 48-02, Pj Parker; 

49-02, Mike Hoyl; 50-02, Sally Tomar; 51-02, TB-02, Gary Don Reagan; 52-02, 

Richard H. Neuwirth; 53-02, Charles R. Martin; 54-01-02, Jamie Suprenant; 54-02-02, 

Sandra Milner; 54-03-02, Sylvia Ebel; 54-04-02, Dana Nunley; 54-05-02, Lara Haddad; 

54-06-02, Douglas Hager; 54-07-02, Michael Hager; 54-08-02, Carl Fairman; 54-09-02, 

Novlette Spence; 54-10-02, Jodi Moore; 54-11-02, Connie Pucio; 54-12-02, Rebecca Pless; 
F–12 

54-13-02, Patricia Medina; 54-14-02, Joe Glen Ensminger; 54-15-02, Linda Jianto; 

54-16-02, Sharon Ensminger; 54-17-02, LaDona Legg; 54-18-02, Regina Diaz; 54-19-02, 

Katrina Torres; 54-20-02, Mayolo Gonzalez; 54-21-02, Krystal Wallace; 54-22-02, 

Judy Tuttle-Wurth; 54-23-02, Kevin Heier; 54-24-02, Maribel Garcia; 54-25-02, 

Kerry Marschke; 54-26-02, Tami Dunlap; 54-27-02, Chris Hulsey; 54-28-02, Dana Estrada; 

56-02, Brad Nesser; 57-02, David G. Stovall; 58-02, Robert Wallach; 59-02, Trent Clifton; 

60-01, Thomas E. Magette; 63-02, Lane Allgood on behalf of the Partnership for Science 

and Technology; 67-01, J. Stephen Herring; 70-02, Jack Jacli; 71-02, Holis Riley; 73-02, 

Marilyn Burns; and TA-01, Farok Sharif] The draft Environmental impact Statement 

thoroughly reviews all of the potential environmental impacts from the proposed facility and I/we 

agree with the conclusions reached by the NRC staff that the impact to Lea County would be 

small/minimal. 

[08-03, Marshall Nadel] Our nation needs nuclear power for energy reliability, efficiency and 

energy independence. We must work to ensure the nuclear fuel cycle is operated in a most 

efficient and environmentally clean manner. Deconverting UF6 close to its source, in this case, 

the Urenco facility in Eunice, is the most efficient and environmentally friendly route to pursue. 

[09-02, Darrell Fisher] This document is comprehensive and well-written. It provides strong 

scientific content. The information presented and conclusions reached support construction and 

operation of the deconversion facility. Our country needs constructive solutions to the problem 

of uranium hexafluoride storage, and I believe that the company's proposal to build and safely 

operate the deconversion plant provides an excellent approach to UF6 management and 

long-term disposal of excess depleted uranium. 

The Environmental Impact Statement shows that International Isotopes can provide a safe and 

environmentally sound approach for treatment of depleted uranium hexafluoride. This 

document thoroughly reviews all of the potential impacts. from the proposed facility, and I agree 

with the conclusions reached by the NRC staff that those impacts would be small, and that 

licenses should be granted to proceed with construction and operation. 

[19-01, Grant Taylor on behalf of the Hobbs Chamber of Commerce] I write in unequivocal 

support of the proposed International Isotopes fluorine products facility in Lea County, 

New Mexico. I speak for the membership and the board of directors of the Hobbs Chamber of 

Commerce. We collectively and enthusiastically support the broadening base of Lea County's 

nuclear industry, which complements the established energy base of our communities. 

International Isotopes has already proven itself to be a good corporate citizen of Lea County, 

and we support this venture with full confidence in the company's commitment to safety and 

environmental stewardship during the treatment of depleted uranium hexafluoride. 

This proposed project has been thoroughly vetted and reviewed, and the Hobbs Chamber of 

Commerce concurs with the draft Environmental Impact Statement in regards to the minimal 

impacts anticipated in the MRC's staff conclusions. 

Please know that this project has the full support of the Hobbs Chamber of Commerce. 

[21-01, Jeff McCool] As Dean of Training and Outreach at New Mexico Junior College, 

I wholeheartedly support the construction and operation of the International Isotopes fluorine 

products facility. The construction and operation of this facility is a giant step to continue the 
F–13 

United States' commitment to responsible and viable projects as these projects relate to the 

Nuclear Fuel Cycle. 

I agree with the conclusions of the Environmental Impact Statement. 

[24-01, John Tanner] I support the construction of a depleted uranium deconversion plant as 

proposed by International Isotopes Inc., and believe that it will be a positive contribution to 

Lea County and will fulfill an important role in the safe and environmentally sound treatment of 

depleted uranium hexafluoride, as well as producing valuable fluoride byproducts. I am not 

aware of any harmful environmental effects caused by the uranium deconversion process. 

[35-01, Steve McCleery] As President of New Mexico Junior College, I wholeheartedly 

support the construction and operation of the International Isotopes fluorine products facility. 

The construction and operation of this facility is a giant step to continue the United States’ 

commitment to responsible and viable projects as these projects relate to the Nuclear 

Fuel Cycle. 

I agree with the conclusions of the Environmental Impact Statement. 

[22-03, Cindy Bryan; 27-03, Paul Campbell; 28-03, Garry Buie; 29-03, David G. Jeff; 30-03, 

Randy Pettigrew; 33-03, Sandy Nash; 34-03, 55-03, Jonathan Sena; 36-03, Kathi Bearden; 

38-03, Sara B. Cisneros on behalf of the Hobbs Hispano Chamber of Commerce Board of 

Directors; 43-03, Hal Brunson; 48-03, Pj Parker; 49-03, Mike Hoyl; 50-03, Sally Tomar; 

56-03, Brad Nesser;; 58-03, Robert Wallach; 71-03, Holis Riley; 73-03, Marilyn Burns] As a 

local resident(s) of Lea County, I/we fully support the International Isotopes project. 

[25-03, Monty D. Newman] As a former mayor, businessman and resident of Lea County, 

I fully support the International Isotopes project. 

[26-02, Carroll Leavell] I serve Senate District 41, Lea and Eddy Counties, New Mexico. 

There is strong support for the project throughout Senate District 41. 

Mr. Steve Laflin, President & CEO, and his management team have done a great job of 

educating Southeast New Mexico of all aspects of the project. I have received no negative input 

from the constituents in Senate District 41. This project has my strong support. 

[32-02, Samuel S. Spencer on behalf of Lea County State Bank] As a locally owned 

business located in Lea County, the International Isotopes project has our full support. 

[39-01, Kathleen A. Moran] I also agree with the conclusion stated in the Draft EIS that any 

potential negative impacts will be small with regard to the thirteen (13) areas listed (land, 

historical and cultural, visual and scenic, etc.). 

Moreover, it is important to find new ways to get more from the nuclear material that is already 

generated. The license should be granted and the project should be allowed to move forward. 

[40-01, Gay G. Kernan] I am confident that the draft Environmental Impact Statement 

thoroughly reviews all of the potential environmental impacts from the proposed facility and I 

agree with the conclusions reached by the NRC staff. The minimal impact on our area allows 

me to fully support this project. 
F–14 

[41-01, Michael P. Gallagher II on behalf of the Lea County Board of County 

Commissioners] The Board of County Commissioners supports this project and believes that 

it will be a positive contribution to Lea County. 

[42-01, TC-01, Lisa Hardison on behalf of the Economic Development Corporation of 

Lea County (EDCLC)] The Economic Development Corporation of Lea County (EDCLC) is in 

full support of the International Isotopes (INIS) planned fluorine extraction facility in Lea County. 

The draft Environmental Impact Statement thoroughly reviews all of the potential environmental 

impacts from the proposed facility and the EDCLC agrees with the conclusions reached by the 

NRC staff that the impacts would be minimal. 

The EDCLC supports the construction and licensure of the INIS facility in Lea County, 

[45-01, Lea County Commissioners and TF-01, Michael P. Gallagher II] RESOLUTION IN 

SUPPORT OF THE PROPOSED INTERNATIONAL ISOTOPES FLUORINE PRODUCTS 

FACILITY IN LEA COUNTY 

WHEREAS International Isotopes Fluorine Products, Inc. seeks to build a fluorine products 

facility in Lea County, and 

WHEREAS, the economic benefit to Southeastern New Mexico will be stability, growth, job 

creation, and industry diversification; and 

WHEREAS, the facility will process depleted uranium and fluorine extraction to produce 

important fluoride products for U.S. markets and will be an asset to U.S. chemical 

manufacturing capabilities; and 

WHEREAS, the facility will be licensed and regulated by the Nuclear Regulatory Commission, 

along with appropriate state agencies; and 

WHEREAS, the facility will have regulated air and water emissions at or below state and federal 

limits, as allowed by the NRC and New Mexico Environment Department; and 

WHEREAS, Lea County Board of Commissioners approved the issuance of Lea County 

Taxable Industrial Revenue Bonds (International Isotopes Project) Series 2010 in the amount of 

$72,000,000 in August 2011. 

NOW, THEREFORE, BE IT RESOLVED, that the Lea County Board of Commissioners 

supports locating the International Isotopes Fluorine Products Facility in Lea County. 

PASSED, APPROVED AND ADOPTED IN OPEN MEETING on this 24th day of January 2012. 

[46-03, Chris Frentzel on behalf of the International Brotherhood of Electrical Workers 

(IBEW), Local 611] Please note that I fully support the International Isotopes project and look 

forward to seeing it move forward. 

[59-03, Trent Clifton] As a local resident of Eddy County, I fully support the International 

Isotopes project. 
F–15 

[60-02, Thomas E. Magette on behalf of EnergySolutions] EnergySolutions supports the 

proposed International Isotopes Fluorine Products Facility in Lea County, New Mexico. 

[65-01, Michael McKenzie-Carter] I believe the potential environmental impacts of the 

proposed action and alternatives are reasonably and conservatively assessed. I agree with the 

conclusion of the Draft EIS that the potential negative impacts of the proposed action would be 

small or moderate at most. 

I support the licensing of the IIFP facility as described in the Draft EIS, and believe that the 

facility can be built and operated in a safe and environmentally sound manner. The benefits 

considerably outweigh the small potential negative environmental impacts. 

[74-01, Paul D. Neuwirth] The project will benefit Lea County. 

I agree the conclusions of the NRC staff that any such impacts will not be material. 

For all of the above reasons, I support the project. 

[TA-02, Farok Sharif] I am in full support of the International Isotopes fluorine facility. 

[TD-01, Samuel S. Spencer] I believe that the economic impact to this area will far outweigh any 

small environmental impact and I concur with your analysis. 

[TE-01, Robert Hayes] If there does come up anything that would put a stop to this or slow it 

down...I'm an engineer...I would personally encourage you and all concerned, as an engineer there 

is a way around that, if there is anything that comes up. I don't know what it might be, I'm not going 

to even try to guess what it is, but I believe whatever that might be, if it comes up, can be 

addressed. We can design and we can operate safely as long as it's done correctly. 

And so just that's just the caveat: if there does come up something, please consider any kind of 

design changes that the vendor, International Isotopes, comes up with so that we can go forward. 

I echo what has been said before: as a resident, I strongly encourage the location of this plant 

here, we really want the jobs, it will be fantastic. 

Response: The NRC staff acknowledges these commenters and appreciates the public 

participation. These comments express general support for the licensing of the proposed IIFP 

facility; however, they do not provide specific information that requires a response from the 

NRC. These comments are outside the scope of the EIS analysis because they do not directly 

relate to the content of the EIS. 

F.4.2 Statutory and Regulatory Requirements 

Comment Summary: The comment addressed in this subsection discusses permitting 

requirements. 

[62-01, Julie Roybal on behalf of the New Mexico Environment Department] 

Surface Water Quality Bureau 

The U.S. Environmental Protection Agency (EPA) requires National Pollutant Discharge 

Elimination System (NPDES) Construction General Permit (CGP) coverage for storm water 

discharges from construction projects (common plans of development) that will result in the 

disturbance (or re-disturbance) of one or more acres, including expansions, of total land area. 
F–16 

Because this project exceeds one acre (including staging areas, etc.), it may require appropriate 

NPDES permit coverage prior to beginning construction (small, one - five acre, construction 

projects may be able to qualify for a waiver in lieu of permit coverage - see Appendix D). 

Among other things, this permit requires that a Storm Water Pollution Prevention Plan (SWPPP) 

be prepared for the site and that appropriate Best Management Practices (BMPs) be installed 

and maintained both during and after construction to prevent, to the extent practicable, 

pollutants (primarily sediment, oil & grease and construction materials from construction sites) 

in storm water runoff from entering waters of the U.S. This permit also requires that permanent 

stabilization measures (revegetation, paving, etc.), and permanent storm water management 

measures (storm water detention/retention structures, velocity dissipation devices, etc.) be 

implemented post construction to minimize, in the long term, pollutants in storm water runoff 

from entering these waters. In addition, permittees must ensure that there is no increase in 

sediment yield and flow velocity from the construction site (both during and after construction) 

compared to pre-construction, undisturbed conditions (see Subpart 10.E.1.b). 

You should also be aware that EPA requires that all “operators” (see Appendix A) obtain 

NPDES permit coverage for construction projects. Generally, this means that at least two 

parties will require permit coverage. The owner/developer of this construction project who has 

operational control over project specifications, the general contractor who has day-to-day 

operational control of those activities at the site, which are necessary to ensure compliance with 

the storm water pollution plan and other permit conditions, and possibly other "operators" will 

require appropriate NPDES permit coverage for this project. 

The CGP was re-issued effective June 30, 2008. The CGP, Notice of Intent (NOI), 

Fact Sheet, and Federal Register notice can be downloaded at http://cfpub.epa.gov/ 

npdes/stormwater/cp.cfim. 

In addition, EPA requires NPDES Storm Water Multi-sector General Permit (MSGP) coverage 

for facilities that engage in "industrial activities" as defined at 40 Code of Federal Regulations 

Part 122.26(b)(14). Although the type of business to be operated is not entirely clear in the 

submittal, if this business meets the definition of regulated industrial activity, it will require 

appropriate NPDES permit coverage prior to beginning operations. 

Among other things, this permit also requires that a SWPPP be prepared for the site and that 

appropriate Best Management Practices (BMPs) be installed and maintained to prevent, to the 

extent practicable, pollutants in storm water runoff from entering waters of the U.S. A SWPPP 

should include such things as: 

A description of potential pollutant sources—includes such things as a site map, an 

identification of the types of pollutants that are likely to be present in storm water discharges, an 

inventory of the types of materials handled at the site that potentially may be exposed to 

precipitation, a list of significant spills and leaks of oil, toxic or hazardous pollutants, sampling 

data, a narrative description of the potential pollutant sources from specific activities at the 

facility (i.e., pumping operations, road construction, raw material storage and handling, material 

transportation, fueling and other equipment maintenance), and identification of specific potential 

pollutants (i.e., dust, total suspended solids, total dissolved solids, turbidity, pH; nitrates, oil, 

grease, ethylene glycol, heavy metals, radionuclides, and others); and 

A description of appropriate measures and controls—includes the type and location of 

existing and proposed non-structural and structural best management practices (BMPs) 

selected for each of the areas where industrial materials or activities are exposed to storm 
F–17 

water. Non-structural and structural BMPs to be described and implemented include such 

things as good housekeeping, preventive maintenance, spill prevention and response 

procedures, periodic inspections, employee training, record keeping, non-storm water 

evaluations and certifications, sediment and erosion control, as well as 

implementation/maintenance of traditional storm water management practices 

(i.e., sediment/settling ponds, check dams, silt fences, straw bale barriers, perimeter 

berms, runon diversion structures), where appropriate. The MSGP also requires preparation 

and implementation of a reclamation plan for the site. 

The NPDES Storm Water Multi-Sector General Permit for Industrial Activities (MSGP) was 

re-issued effective September 29, 2008 (see Federal Register/Vol. 73, No. 189/Monday, 

September 29, 2008, p. 56572). The MSGP, Notice of Intent (NOD, Fact Sheet, and Federal 

Register notice can be downloaded at: http://cfpub.epa.gov/npdes/stormwater/msgp.cfm). 

Finally, EPA requires individual NPDES permit coverage for discharges of process 

wastewaters. These permits typically contain both technology and water quality based effluent 

limits, sampling requirements, etc. NPDES regulations at 40 CFR Part 122.44(d) require that 

NPDES permits include effluent limits necessary to achieve water quality standards established 

under §303 [33 U.S.C. 1313 - Water Quality Standards and Implementation Plans] of the federal 

Clean Water Act (CWA), including State narrative criteria for water quality. 40 CFR Part 122.4(i) 

requires that a discharge not “cause or contribute to the violation of water quality standards.” 

The New Mexico Water Quality Control Commission (WQCC) has adopted surface water quality 

standards under authority of the New Mexico Water Quality Act [Chapter 74, Article 6 NMSA] 

pursuant to CWA § 303, which are codified as Standards for Interstate and Intrastate Surface 

Waters, 20.6.4 NMAC. 

Regardless of whether or not an NPDES permit has been issued, state surface water quality 

standards must be met at all times and violation of these standards are enforced by the New 

Mexico Environment Department under authority of the New Mexico Water Quality Act. 

Ground Water Quality Bureau 

New Mexico Environment Department (NMED) Ground Water Quality Bureau (GWQB) staff 

reviewed the above-referenced letter as requested, focusing specifically on the potential effect 

to ground water resources in the area of the proposed project. 

The letter from the U.S Nuclear Regulatory Commission (NRC) provides notification and 

requests comments on the Draft Environmental Impact Statement (EIS) for the proposed 

International Isotopes Fluorine Products Facility to be located in Lea County, NM. The 

proposed facility would deconvert depleted uranium hexafluoride to fluorine gas products and 

uranium oxide compounds for long-term disposal offsite. This memo should be regarded as a 

preliminary response to the EIS notification. Formal comments to the EIS will be provided in a 

separate letter. 

If constructed, International Isotopes Fluorine Products, Inc. (IIFP) will be required to obtain a 

ground water discharge permit for this facility. GWQB met with IIFP on September 8, 2010 for a 

preliminary review of the proposed facility. On February 11, 2011, GWQB replied to an IIFP 

request dated January 27, 2011, with a letter providing a preliminary description of ground water 

monitoring requirements that would be required for the facility under a discharge permit. 

The GWQB strongly recommends that IIFP submit a Discharge Permit Application at least 

180 days prior to construction of the facility to allow adequate time for processing and required 
F–18 

public notification. During the public notice period, if a public hearing is requested and granted 

by the NMED Secretary, the issuance of a discharge permit may be further delayed or denied. 

Please note that construction of the facility will involve the use of heavy equipment, thereby 

leading to a possibility of contaminant releases (e.g., fuel, hydraulic fluid, etc.) associated with 

equipment malfunctions. The GWQB advises all parties involved in the project to be aware of 

notification requirements for accidental discharges contained in 20.6.2.1203 NMAC. 

Compliance with the notification and response requirements will further ensure the protection of 

ground water quality in the vicinity of the project. 

Air Quality Bureau 

From the project description, it is difficult to discern what the potential is for fluorine emissions. 

However, fluorine is listed as a Toxic Air Pollutant (TAP) in New Mexico under 20.2.72.502 

NMAC and potential emissions must be included in the NEPA analysis. Radionuclides are also 

identified and are subject to National Emission Standards for Hazardous Air Pollutants 

(NESHAP) in the Clean Air Act under 40 CFR Part 61. 

Construction activities identified in this proposal have the potential to create temporary 

increases in emissions due to combustion-related construction activities and the use of 

earth-moving equipment. All asphalt, concrete, quarrying, crushing and screening facilities 

contracted in conjunction with the proposed project must have current and proper air quality 

permits. For more information on air quality permitting and modeling requirements, please refer 

to 20.2.72 NMAC. 

Dust associated with vehicular use and earth-moving activities may also impact local air quality. 

However the increases should not result in non-attainment of air quality standards. Dust control 

measures should be considered to minimize the release of particulates due to vehicular traffic 

and ground disturbances. If activities result in significant ground disturbance, the project area 

should be reclaimed to avoid long-term problems with erosion and fugitive dust. 

To further ensure air quality standards are met, applicable local or county regulations requiring 

noise and/or dust control must be followed; if none are in effect, controlling construction-related 

air quality impacts during projects should be considered to reduce the impact of fugitive dust 

and/or noise on community members. 

Hazardous Waste Bureau 

Comment #2: Depending on whether the facility is a Large Quantity Generator (LQG) or Small 

Quantity Generator (SQG); how much hazardous waste they intend to accumulate; and the 

length of time they intend to accumulate it, the facility may need a Resource Conservation and 

Recovery Act (RCRA) permit to store hazardous waste. 

Comment #3: Table 1-3 infers that Form 8700-12 to notify NMED HW13 of EPA waste 

activity and obtain an EPA ID Number would be submitted in 3rd Quarter of 2011. As of 

January 18, 2012, there is no EPA ID Number in the RCRA Info database. 

Radiation Control Bureau 

The draft EIS (NUREG–2113) should meet or exceed New Mexico, Title 20: Environmental 

Protection Chapter 3: Radiation Protection, Part 4: Standards for the Protection against 

Radiation and the equivalent federal regulations in I0 CFR 20, Standards for the Protection 

against Radiation. 
F–19 

Response: By law, IIFP is required to obtain all required Federal, State, and local permits and 

approvals to conduct construction and operation activities. Also, 10 CFR 51.71(c) requires that 

the EIS provide a list of all Federal permits, licenses, approvals, and other entitlements that 

must be obtained in implementing the proposed action and will describe the status of 

compliance with these requirements. Section 1.5 describes the statutory and regulatory 

requirements that are applicable to the proposed IIFP facility. In addition, Table 1-1 describes 

the laws, regulations, and agreements that apply to the facility and the regulatory basis for these 

items. Finally, Section 1.5.3 was updated to provide the status of the permits for the proposed 

IIFP facility, should NRC grant the license. 

F.4.3 NRC Outreach Activities

Comment Summary: The following comment requests clarification of the facts associated with 

the public scoping meeting held in Hobbs, New Mexico, on July 29, 2010, and the public 

meeting held on February 2, 2012, to receive comments on the draft EIS. 

[72-01, Rhonda Smith on behalf of the U.S. Environmental Protection Agency] The Draft 

EIS describes that approximately 60 individuals not affiliated with the NRC staff attended the 

July 29, 2010, public scoping meeting in Hobbs, New Mexico. A news article from the 

Hobbs News-Sun stated about a dozen citizens and elected officials attended the July 29th

meeting. The DEIS does not clearly explain what outreach efforts were made to announce the 

Scoping meeting and the open house held July 29, 2010, in Hobbs, New Mexico. Please clarify 

in the DEIS. 

The International Isotopes Inc., Web site announced that the NRC was holding a public meeting 

in Hobbs, New Mexico, on February 2, 2012, and stated comments will be taken until 

February 27, 2012. The website does not mention a location of this public meeting nor 

additional information regarding the submission of comments. Through internet surfing a NRC 

News flyer, dated January 9, 2012, explains the NRC is seeking public comments on DEIS for a 

proposed Uranium Deconversion Facility in New Mexico. It is unclear where the general public 

will see a NRC News bulletin such as this. Please clarify in the FEIS. 

Response: Public participation is an essential part of the NRC’s environmental review process 

under NEPA. As indicated in Sections F.2.2 and F.2.3 of this appendix, the NRC staff 

conducted an open, public EIS development process consistent with NEPA and the NRC’s 

NEPA implementing regulations under 10 CFR Part 51. 

The NRC’s public scoping process began on July 15, 2010, with the publication in the Federal 

Register of a Notice of Intent (NOI) to prepare an EIS (75 FR 41242). This notice also invited 

members of the public to provide comments on issues to be considered in the EIS and 

announced the NRC’s public scoping meeting and open house on July 29, 2010. The notice 

described the different vehicles members of the public could use to provide scoping comments 

as well as information on how to access the applicant’s ER. A copy of the applicant’s ER was 

also made available at the Hobbs Public Library for public inspection. An electronic version of 

the ER and supporting information was made available through the NRC’s project-specific Web 

site at http://www.nrc.gov/materials/fuel-cycle-fac/inisfacility.html and through the NRC’s 

ADAMS database at http://www.nrc.gov/reading-rm/adams.html. 

The NRC staff also published a meeting notice on June 29, 2010, in its Web site at 

http://www.nrc.gov/public-involve/public-meetings/index.cfm announcing the July 29, 2010, 

public scoping meeting and open house. An NRC press release was issued on July 23, 2010, 
F–20 

which can be found in the NRC’s Web site at: http://www.nrc.gov/reading-rm/doccollections/news/2010/. 

The NRC staff advertised the scoping meeting and open house in a regional daily newspaper 

(The Hobbs News-Sun) on July 20 and July 25, 2010, and on local radio station (KYKK) from 

July 27 through July 29, 2010. 

During the week of July 26, 2010, the NRC staff met with the Lea County Sheriff’s Department, 

the Monument Volunteer Fire Department, the City of Hobbs Fire Department, the City of Hobbs 

Planner and Manager, the Lea County Interim Manager, Lea County Assessor, Lea County 

Attorney, the Economic Development Corporation of Lea County, and the NMED Drinking Water 

Bureau to discuss the NRC’s roles and responsibilities, provide an overview of the 

environmental review process, and to gather information as part of the scoping process in 

support of the environmental review for the proposed IIFP facility. 

Based on the attendance cards completed during the scoping meeting held July 29, 2010, in 

Hobbs, New Mexico, NRC staff determined that 62 members of the public attended the scoping 

meeting. 

The draft EIS public comment period began with the Environmental Protection Agency’s Notice 

of Availability (NOA) published in the FR on January 13, 2012 (77 FR 2060). The NRC staff’s 

NOA announcing the issuance of the draft EIS for public comment and providing notice of the 

public meeting was also published on January 13, 2012 (77 FR 2096). The NRC staff 

advertised the draft EIS public meeting in The Hobbs News-Sun on January 26 and February 2, 

2012, and on a local radio station (KIXN) on January 26 and February 2, 2012. 

The NRC staff also published a meeting notice on January 4, 2012, in its Web site at 

http://www.nrc.gov/public-involve/public-meetings/index.cfm, announcing the February 2, 2012, 

draft EIS public meeting and open house. An NRC press release was issued on January 9, 

2012, which can be found in the NRC’s Web site at http://www.nrc.gov/reading-rm/doccollections/news/2012/. 

Copies of the draft EIS were mailed to Federal, Tribal, State, and local government officials as 

well as members of the public. Additionally, an electronic version of the draft EIS was 

made available through the NRC’s project-specific Web site ( http://www.nrc.gov/materials/fuelcycle-fac/inisfacility.html) and through the NRC’s ADAMS database (http://www.nrc.gov/ 

reading-rm/adams.html). No change was made to the EIS as a result of this comment. 

Comment Summary: The following comment requests information on how the public will be 

informed and educated about potential dangers during operation of the proposed IIFP facility. 

[72-02, Rhonda Smith on behalf of the U.S. Environmental Protection Agency] The FEIS 

should provide information as to how the IIFP or the NRC will disseminate or reach out to the 

community keeping residents informed and educated about any potential dangers during the 

operation of this facility after the license is approved. Please explain in the FEIS. 

Response: The applicant, IIFP, submitted an emergency plan as part of the license application 

that describes the actions IIFP will take in response to emergencies. IIFP also coordinated the 

development of the emergency plan with offsite response organizations expected to respond in 

the event of an accident at the proposed IIFP facility. Emergency response plans are not within 

the scope of the EIS, but are addressed in the Safety Evaluation Report (SER) (NRC, 2012). 
F–21 

The methods that IIFP will use to disseminate information to or educate community residents 

about any potential dangers during facility operations are discussed in the SER (NRC, 2012), 

which presents the NRC’s staff safety review of the license application. These methods are 

specifically addressed in Section 8.3.8, “Responsibilities,” Section 8.3.9, “Notification and 

Coordination,” and Section 8.3.10, “Information to be Communicated.” In the ER, IIFP identified 

and described the emergency notification procedures that enable the organization to correctly 

classify emergencies, notify emergency response personnel, and initiate or recommend 

appropriate actions in a timely manner. 

In addition, if a license is issued to IIFP, the NRC staff will also implement oversight (inspection) 

and enforcement programs during construction, operation, and decommissioning of the 

proposed IIFP facility to assure safe functions and compliance with NRC requirements. The 

NRC’s oversight program for fuel cycle facilities includes inspections focused on reviews of 

safety, safeguards, and environmental protection. Inspections at fuel cycle facilities occur 

several times a year and typically cover activities such as chemical safety, emergency 

preparedness, fire safety, and radiation safety. The results of the inspections are documented 

in reports that are generally publicly available through the NRC’s ADAMS library at: 

http://www.nrc.gov/reading-rm/adams.html. No change was made to the EIS as a result of 

this comment. 

F.4.4 Historical and Cultural Resources 

Comment Summary: The following comment is a concurrence of a letter sent to the New 

Mexico State Historic Preservation Officer by the NRC staff that provided a copy of the draft EIS 

and information in response to the New Mexico State Historic Preservation Officer’s 

recommendation that a cultural resources survey of the IIFP property be conducted and that 

consultations be held with Native American Tribes. 

[66-01, Michelle Ensey on behalf of the New Mexico State Historic Preservation Officer] 

Concur. No Historic Properties Affected.

Response: The NRC accepts the concurrence from the New Mexico State Historic 

Preservation Division that the proposed action will not adversely affect any historic properties. 

No change was made to the EIS as a result of this comment. 

Comment Summary: The following comment requests that a copy of the Final EIS be sent to a 

government office in Texas because of Texas’ close proximity to the IIFP site. 

[72-03, Rhonda Smith on behalf of the U.S. Environmental Protection Agency] With 

regard to historic preservation and close proximity to the State of Texas, EPA recommends that 

a copy of the FEIS be sent to Texas State Historical Office for their review and comment.

Response: NRC intends to send a copy of the Final EIS to the Texas State Historical Office 

when the Final EIS is published. No change was made to the EIS as a result of this comment. 

F.4.5 Air Quality 

Comment Summary: The following comments express concerns that offsite air monitoring is 

not planned for the proposed IIFP facility. 
F–22 

[03-01, Phil Barr] Note that the State of Texas wanted an health survey filled out by 

citizens in Lea county nm because of a nuclear waste dump in Andrews county Texas. But as 

I understand it the New Mexico environmental department will not install rad monitors in Eunice 

and Hobbs; New Mexico. One Congressman has told me that it is NMED's responsibility to 

monitor the air in regards to nuclear facilities in Lea county. I don’t believe any nuclear facility 

should be allowed in Lea county NM with this kind of approach by NMED. 

[04-01, Clifford Barr and 05-01, Phil Barr] Requested several times that the New Mexico 

Environmental Department install radiation monitors in Hobbs and eunice, new mexico. For 

safety..... Got turned down each time. Got turned down by a Lea county commissioner as well. 

But one U.S. Congressman has told me by email that NMED has the responsibility of monitoring 

the air here. Contrast this to the Texas commission of environmental quality who wanted 

Lea county nm citizens to participate in a health survey because of a nuclear waste dump 

20 miles away in Texas. Its my belief that NMED and the State of New Mexico are more 

interested in avoiding liability from nuclear industry than safety to Lea county citizens. With this 

approach I don't believe any nuclear industry should be located here in Lea county nm. 

Response: Potential radiological releases during facility operation are analyzed in 

Section 4.1.2.11. In addition, IIFP is responsible for complying with the provisions in 

10 CFR Part 20, “Standards for Protection Against Radiation,” which requires monitoring for 

airborne radioactivity both in the workplace and at the site boundary downwind from the facility 

in the predominant wind direction. Sections 6.1.1 and 6.1.2 discuss the gaseous effluent 

monitoring and radiological environmental monitoring programs, respectively. IIFP must comply 

with all applicable Federal, State, and local laws and regulations, including obtaining all 

appropriate construction and operating permits. A discussion of applicable laws and regulations 

is included in Section 1.5. Under New Mexico State regulations, IIFP is required to satisfy all air 

quality regulatory and permitting requirements. No change was made to the EIS as a result of 

these comments. 

Comment Summary: The following comment expresses an opinion that NRC overestimated 

the environmental impact of the IIFP on air quality. 

[39-02, Kathleen A. Moran] As someone who is familiar with the amount of dust that gets 

blown across the region during one of the frequent windy days in southeast New Mexico, 

I seriously question whether the dust generated during construction of the facility fourteen miles 

west of the nearest town will be noticed by anyone or cause any air quality issues, and I would 

characterize the impact on existing Air Quality as being small rather than moderate. 

Response: The NRC staff takes a reasonable and conservative approach to assessing the 

environmental impacts from nuclear facilities to ensure that impacts are not underestimated. 

Based on independent verification of the information the applicant provided, the NRC staff 

has determined that the environmental impact on air quality from the proposed IIFP facility is 

SMALL to MODERATE. No change was made to the EIS as a result of this comment. 

Comment Summary: The following comment supports air monitoring at the proposed IIFP 

facility project. 

[45-02, Lea County Commissioners and TF-02, Michael P. Gallagher, II] ... WHEREAS, the 

facility will have regulated air and water emissions at or below state and federal limits, as 

allowed by the NRC and New Mexico Environment Department; ... 
F–23 

Response: The NRC staff acknowledges these commenters and appreciates the public 

participation. This comment expresses general support for the licensing of the proposed IIFP 

facility; however, they do not provide specific information that requires a response from the 

NRC. This comment is outside the scope of the EIS analysis because it does not directly relate 

to the content of the EIS. 

Comment Summary: The following comment describes those regulations that pertain to 

dust control. 

[62-02, Julie Roybal on behalf of the New Mexico Environment Department] 

Air Quality Bureau 

Dust associated with vehicular use and earth-moving activities may also impact local air quality. 

However the increases should not result in non-attainment of air quality standards. Dust control 

measures should be considered to minimize the release of particulates due to vehicular traffic 

and ground disturbances. If activities result in significant ground disturbance, the project area 

should be reclaimed to avoid long-term problems with erosion and fugitive dust. 

To further ensure air quality standards are met, applicable local or county regulations requiring 

noise and/or dust control must be followed; if none are in effect, controlling construction-related 

air quality impacts during projects should be considered to reduce the impact of fugitive dust 

and/or noise on community members. 

Response: By law, IIFP is required to obtain all applicable Federal, State, and local permits 

and approvals to conduct construction and operations activities. Also, 10 CFR 51.71(c) requires 

that the EIS provide a list of all Federal permits, licenses, approvals, and other entitlements for 

the proposed action and describe the status of compliance with these requirements, including 

requirements for dust control (air quality). Section 1.5 of this EIS describes the statutory and 

regulatory requirements that are applicable to the proposed IIFP facility. In addition, Table 1-1 

describes laws, regulations, and agreements that apply to the facility; the regulatory basis and 

requirements for these items. . Finally, Section 1.5.3 was updated to provide the status of the 

permits, licenses, authorizations, and approvals for construction and operation of the proposed 

IIFP facility, should NRC grant the license. 

The NRC staff acknowledges the importance of using BMPs. As noted in Chapter 5, IIFP 

identified the use of BMPs as mitigation measures for minimizing air quality impacts during road 

construction, land clearing, and building construction. Also, construction equipment and related 

vehicles would be equipped with standard pollution control devices and maintained in good 

working order. 

Comment Summary: The following comment outlines EPA recommendations that involve 

vehicular air emissions. 

[72-04, Rhonda Smith on behalf of the U.S. Environmental Protection Agency] Any 

demolition, construction, rehabilitation, repair, dredging or filling activities have the potential to 

emit air pollutants. EPA recommend best management practices be implemented to minimize 

the impact of any air pollutants. Furthermore, construction and waste disposal activities should 

be conducted in accordance with applicable local, State and Federal statutes and regulations. 

EPA recommends the use of clean, lower-emissions equipment and technologies to reduce 

pollution. EPA's final Highway Diesel and Nonroad Diesel Rules mandate the use of 
F–24 

lower-sulfur fuels in nonroad and marine diesel engines beginning in 2007. Please address 

these concerns in the FEIS. 

Response: By law, IIFP is required to obtain all applicable Federal, State, and local permits 

and approvals to conduct construction and operations activities. Also, 10 CFR 51.71(c) requires 

the EIS to provide a list of all Federal permits, licenses, approvals, and other entitlements for the 

proposed action and describe the status of compliance with these requirements. Section 1.5 of 

the EIS describes the statutory and regulatory requirements that are applicable to the proposed 

IIFP facility. In addition, Table 1-1 describes laws, regulations, and agreements that apply to 

the facility and the regulatory basis and the requirements for these items. Finally, Section 1.5.3 

was updated to provide the status of the permits, licenses, authorizations, and approvals for 

construction and operation of the proposed IIFP facility, should NRC grant the license. 

The NRC staff acknowledges the importance of using BMPs. As noted in Chapter 5, IIFP 

identified the use of BMPs as mitigation measures for reducing or minimizing air quality impacts 

during road construction, land clearing, and building construction. Also, construction equipment 

and related vehicles would be equipped with standard pollution control devices and maintained 

in good working order. 

The NRC does not regulate implementation of the Highway Diesel and Nonroad Diesel Rules. 

However, the NRC staff informed IIFP on the EPA's final Highway Diesel and Nonroad Diesel 

Rules that mandate the use of lower-sulfur fuels in nonroad and marine diesel engines 

beginning in 2007 as one of the issues raised in the EPA letter (ADAMS Accession 

Number ML12067A096).

F.4.6 Seismicity 

Comment Summary: The following comments express concern that the hazards associated 

with seismic activity were not adequately addressed in the draft EIS. 

[01-01, Anonymous] Lea County sits in an seismic hazard zone. Locating any nuclear 

industry is unsafe (http://earthquake.usgs.gov/earthquakes/states/texas/hazards.php). 

[02-01, Clifford Barr] USGS says Lea County is in earthquake hazard area/here is a copy of 

file the geology should be looked at again http://earthquake.usgs.gov/earthquakes/states/ 

texas/hazards.php. I think anything nuclear located over an earthquake zone is unsafe 

[04-02, Clifford Barr and 05-02, Phil Barr] See attachment labeled UTIG from the Jackson 

school of geosciences showing hazard zone under nuclear waste dump site in Andrews county 

Texas. Which would indicate an unsafe disposal path for any nuclear waste produced locally. 

Response: The NRC staff acknowledges that there is some risk of seismic activity in all 

regions of the United States. Regions are identified by the potential to experience earthquakes 

based on the probability and severity of the earthquake. The U.S. Geological Survey (USGS) 

and Jackson School of Geosciences maps (as provided by the commenters) both identify Lea 

and Andrews Counties to be in a seismically quiet region, with local earthquakes of relatively 

small magnitude (moment magnitudes less than 2 on the Modified Mercalli-Revised 1931 scale 

[MM]). Section 3.6.2 of the EIS discusses seismicity in New Mexico. Additional information on 

seismic hazards of the IIFP site are discussed in Section 1.3.3.5 “Site Geology” of the SER for 

the proposed IIFP facility, (NRC, 2012. As summarized in the SER, the applicant provided 

adequate and appropriate seismic description of the region and seismic design basis 
F–25 

information for the proposed facility. No change was made to the EIS as a result of 

these comments. 

Comment Summary: The following comment, which is applicable to multiple sections including 

seismicity, requests clarification on issues identified during the scoping meeting.

[72-05, Rhonda Smith on behalf of the U.S. Environmental Protection Agency] Page A–7, 

Paragraph A.2.2, Summary of Issues Raised: ... several comments from citizens express 

concerns regarding impacts or risks posed by the facility due to seismic concerns... . It was 

unclear where in the DEIS these specific concerns were addressed. Please address these 

concerns in the FEIS. 

Response: Appendix A includes a summary of all the issues raised during the scoping 

process. The NRC staff ensured that the EIS includes relevant sections and text discussing the 

concerns raised from citizens during the scoping meeting. Seismic issues are discussed in 

Section 3.6.2. No change was made to the EIS as a result of this comment. 

F.4.7 Water Resources 

Comment Summary: The following comments provide support for the IIFP project and indicate 

that air and water emissions will be regulated.

[41-05, Michael P. Gallagher II on behalf of the Lea County Board of County 

Commissioners] The Board of Commissioners acknowledge the facility will have regulated air 

and water emissions at or below state and federal limits, as allowed by the NRC and New 

Mexico Environmental Department. 

 

[45-03, Lea County Commissioners and TF-03, Michael P. Gallagher II] ... WHEREAS, the 

facility will have regulated air and water emissions at or below state and federal limits, as 

allowed by the NRC and New Mexico Environment Department; ... 

Response: The NRC staff acknowledges these commenters and appreciates the public 

participation. These comments express general support for the licensing of the proposed IIFP 

facility; however, they do not provide specific information that requires a response from the 

NRC. These comments are outside the scope of the EIS analysis because they do not directly 

relate to the content of the EIS. 

Comment Summary: The following comment, which is applicable to multiple sections including 

water resources, requests clarification on issues identified during the scoping meeting.

[72-06, Rhonda Smith on behalf of the U.S. Environmental Protection Agency] Page A–7, 

Paragraph A.2.2, Summary of Issues Raised: ... several comments from citizens express 

concerns regarding impacts or risks posed by the facility due to ... availability of water 

sources.... It was unclear where in the DEIS these specific concerns were addressed. Please 

address these concerns in the FEIS. 

Response: Appendix A includes a summary of all the issues raised during the scoping 

process. The EIS includes relevant sections and text discussing the topics raised by citizens 

during the scoping meeting. Water sources are discussed in Section 3.7 and comments 

addressing concerns about availability of water sources are addressed in Section F.4.7. No 

change was made to the EIS as a result of this comment. 
F–26 

Comment Summary: The following comment expresses concern about groundwater wells in 

the area. 

[TH-01, Rose Gardner] Are there any groundwater wells in that area at all that feed the Lea 

County communities or the ranchers or cattle in the area? 

Response: There are no wells within the proposed site to provide water to the Lea County 

citizens, other than those used for IIFP operations. Within a mile of the site there is one 

domestic well and 6 industrial wells for Abbott Bros. These wells are not on the IIFP site. No 

change was made to the EIS as a result of this comment. 

F.4.8 Ecological Resources 

Comment Summary: The following comment relates to the environmental impact of the 

proposed IIFP facility on ecological resources. 

[64-01, Mathew Wunder on behalf of the State of New Mexico Department of 

Game & Fish] NMGF concurs with the DEIS conclusion of small impact to ecological 

resources. We stand by the recommendations made in our scoping comment letter, many of 

which have been included as recommendations in the DEIS. 

Response: This comment expresses general support for the licensing of the proposed IIFP 

facility; however, it does not provide specific information that requires a response from the NRC. 

Comment Summary: The following comment relates to the environmental impact of the 

proposed IIFP facility on ecological resources. 

 [64-02, Mathew Wunder on behalf of the State of New Mexico Department of 

Game & Fish] We recommend that, prior to initiating clearing and grading, pre-construction 

clearance surveys should be conducted for the following species of concern which may occur 

on the project site: lesser prairie-chicken, burrowing owl, and swift fox. 

Response: IIFP conducted surveys for Vegetation (GL Environmental, 2010c), Animal (SORA, 

2011) and (NMGF, 2010a) and Cultural Resource (Daras, 2009) at the proposed facility. NRC 

does not have the authority to require a licensee to perform a preconstruction clearance survey; 

imposition of such a requirement may be within the authority of the State of New Mexico. 

Further, IIFP is required to obtain all required Federal, State, and local permits and approvals to 

conduct construction and operations activities. If the State of New Mexico requires a 

preconstruction clearance survey, NRC staff would expect the licensee to comply with that 

requirement. No change was made to the EIS as a result of this comment. 

F.4.9 Socioeconomics and Environmental Justice 

Comment Summary: The following comment expresses a concern that the proposed IIFP 

facility will negatively impact the Ogallala aquifer and result in a socioeconomic impact. 

[03-02, Phil Barr] Here are 2 aquifer maps; one from T Boone Pickens Mesa Water site and 

the other from the Red River Authority site of Texas. The 05 map didn’t have a disclaimer when 

I downloaded it from the Texas site and is remarkably similar to the later one from Mesa Water. 

No matter how the water supply is spun to make it work for nuclear projects; Lea County is 
F–27 

running out of water and when it gets in short supply; prices will go up and the average citizen 

will suffer economically. 

Response: Groundwater at the proposed IIFP site and in its vicinity is discussed in detail in 

Section 3.7.1.2.2, and groundwater use is discussed in Section 3.7.1.3. Section 2.1.5.2 

discusses how the facility would use groundwater resources, stating that “the proposed facility 

would require relatively low volumes of process water because it would recycle process water 

and re-circulate cooling water. IIFP estimates that the total water supply requirement is less 

than 38,000 liters (L) [10,000 gallons (gal)] per day. Sanitary water requirements for showers, 

lavatories, drinking, toilets, and the laboratory would be 11,000 L to 17,000 L [3,000 to 4,500 

gal] per day of the total. Treated sanitary waste water would be used for landscape watering. 

Boiler blow-down would be sent to the environmental protection process (Section 2.1.6.4.2) for 

treatment, if needed, and evaporation.” Further, Section 2.1.5.2 states that “it is anticipated that 

there would be at least one but no more than two groundwater wells to supply water for the 

facility.” As stated in Section 4.1.1.6.1.1, the proposed IIFP site has been included in Lea 

County’s 40-Year Water Development Plan. Based on this information, NRC staff has 

determined that the impact on groundwater resources from the proposed IIFP facility would be 

SMALL and that the facility’s use of groundwater would have a SMALL socioeconomic impact. 

No change was made to the EIS as a result of this comment. 

Comment Summary: The following comments discuss potential beneficial socioeconomic 

impacts of the proposed IIFP facility. 

[06-03, Audrey Nelson; 07-03, Troy Beall; 08-04, Marshall Nadel; 10-03, Erika Prestwich; 

11-03, Dennis Manning; 12-03, Kurt Smith; 13-03, Justin Tomborello; 14-03, Mitchell N.;

15-03, Unknown Individual; 16-03, M. Mayer; 18-03, Giorgio Borlenghi; 20-03, 

James Keane; 22-04, Cindy Bryan; 25-04, Monty D. Newman; 27-04, Paul Campbell; 28-04,

Garry Buie; 29-04, David G. Jeff; 30-04, Randy Pettigrew; 31-03, Ron Black; 32-03, 

Samuel S. Spencer; 33-04, Sandy Nash; 34-04, 55-04, Jonathan Sena; 36-04, 

Kathi Bearden; 37-03, Michael Leighton; 41-02, Michael P. Gallagher II on behalf of the 

Lea County Board of County Commissioners; 43-04, Hal Brunson; 44-03, Janice Jamison;

46-04, Chris Frentzel on behalf of the International Brotherhood of Electrical Workers 

(IBEW), Local 611; 47-03, Gary Schubert; 48-04, Pj Parker; 49-04, Mike Hoyl; 50-04, 

Sally Tomar; 51-03, TB-03, Gary Don Reagan; 52-03, Richard H. Neuwirth; 53-03, 

Charles R. Martin; 54-01-03, Jamie Suprenant; 54-02-03, Sandra Milner; 54-03-03, 

Sylvia Ebel; 54-04-03, Dana Nunley; 54-05-03, Lara Haddad; 54-06-03, Douglas Hager; 

54-07-03, Michael Hager; 54-08-03, Carl Fairman; 54-09-03, Novlette Spence; 54-10-03, 

Jodi Moore; 54-11-03, Connie Pucio; 54-12-03, Rebecca Pless; 54-13-03, Patricia Medina; 

54-14-03, Joe Glen Ensminger; 54-15-03, Linda Jianto; 54-16-03, Sharon Ensminger; 

54-17-03, LaDona Legg; 54-18-03, Regina Diaz; 54-19-03, Katrina Torres; 54-20-03, 

Mayolo Gonzalez; 54-21-03, Krystal Wallace; 54-22-03, Judy Tuttle-Wurth; 54-23-03, 

Kevin Heier; 54-24-03, Maribel Garcia; 54-25-03, Kerry Marschke; 54-26-03, Tami Dunlap; 

54-27-03, Chris Hulsey; 54-28-03, Dana Estrada; 56-04, Brad Nesser; 57-03, 

David G. Stovall; 59-04, Trent Clifton; 63-03, Lane Allgood on behalf of the 

Partnership for Science and Technology; 67-02, J. Stephen Herring; 70-03, Jack Jacli; 

71-04, Holis Riley; 73-04, Marilyn Burns; and TA-03, Farok Sharif] I also believe the facility 

will produce important fluoride products for U.S. markets and be an asset to U.S. chemical 

manufacturing capability. 
F–28 

[09-03, Darrell Fisher] The Environmental Impact Statement shows that International 

Isotopes can provide a safe and environmentally sound approach for treatment of depleted 

uranium hexafluoride.

[12-04, Kurt Smith] It sounds like a win-win situation to me, creating jobs and saving the 

taxpayer money. 

[17-03, William Newsome] I also believe that the synergies with other companies in the 

energy sector in Lea County are an important positive consideration. 

[19-02, Grant Taylor on behalf of the Hobbs Chamber of Commerce] The resulting 

products will fill an important market niche for fluoride products across the country and around 

the world, while simultaneously creating a new center for U.S. chemical manufacturing. 

[21-02, Jeff McCool] I sincerely believe the facility will provide a viable and important product. 

[22-05, Cindy Bryan; 25-05, Monty D. Newman; 27-05, Paul Campbell; 28-05, Garry Buie; 

29-05, David G. Jeff; 30-05, Randy Pettigrew; 33-05, Sandy Nash; 34-05, 55-05, 

Jonathan Sena; 36-05, Kathi Bearden; 38-04, Sara B. Cisneros on behalf of the Hobbs 

Hispano Chamber of Commerce Board of Directors; 43-05, Hal Brunson; 48-05, Pj Parker; 

49-05, Mike Hoyl; 50-05, Sally Tomar; 56-05, Brad Nesser; 57-04, David G. Stovall; 58-04, 

Robert Wallach; 59-05, Trent Clifton; 71-05, Holis Riley; 73-05, Marilyn Burns; TA-04, 

Farok Sharif] I (we) support this project and believe that it will be a positive contribution to 

Lea County by providing safe, quality jobs and economic diversification to the area. 

[23-01, Anonymous] This will be a great opportunity for persons to get employment if this 

facility does get built in Lea County. 

[24-02, John Tanner] I believe that it will be a positive contribution to Lea County and will fulfill 

an important role in the safe and environmentally sound treatment of depleted uranium 

hexafluoride, as well as producing valuable fluoride byproducts. 

[26-03, Carroll H. Leavell] The impact of this project will be very positive as it concerns 

employment and good paying jobs.

[32-04, Samuel S. Spencer on behalf of Lea County State Bank] Our institution is in favor of 

the project moving forward as we believe that it will make a positive contribution to the economic 

diversification of our economy. 

[35-02, Steve McCleery] I sincerely believe the facility will provide a viable and important 

product,.

[40-02, Gay G. Kernan] I am convinced that the project will have a positive impact on the 

quality of life in southeast New Mexico by providing quality jobs in a safe environment. 

[41-03, Michael P. Gallagher II on behalf of the Lea County Board of County 

Commissioners] The Board of County Commissioners support this project and believe that it 

will be a positive contribution to Lea County by providing safe, quality jobs and economic 

diversification to the area. 
F–29 

[42-02, TC-02, Lisa Hardison on behalf of the Economic Development Corporation of 

Lea County (EDCLC)] We are confident that this industry will help continue to diversify our 

economy and create quality jobs for Lea County residents.

It is though the due diligence process of our organization and that of the Nuclear Regulatory 

Commission that EDCLC has been assured that the INIS facility will have a positive impact on 

the economy of Lea County with little environmental concern. 

[45-04, Lea County Commissioners and TF-03, Michael P. Gallagher II] ... WHEREAS, the 

economic benefit to Southeastern New Mexico will be stability, growth, job creation, and 

industry diversification; and 

WHEREAS, the facility will process depleted uranium and fluorine extraction to produce 

important fluoride products for U.S. markets and will be an asset to U.S. chemical 

manufacturing capabilities; and ... 

[46-05, Chris Frentzel on behalf of the International Brotherhood of Electrical Workers 

(IBEW), Local 611] This is a positive step forward for Lea County in terms of providing safe, 

worthwhile jobs and economic diversification to the area. 

[60-03, Thomas E. Magette on behalf of EnergySolutions] This facility will provide a positive 

economic contribution to Lea County. 

[65-02, Michael McKenzie-Carter] The potential benefits of the proposed action-in particular 

the production of industrial fluoride products-are very positive. 

This project represents a positive contribution to our country by safely treating stored DUF6 

much more quickly than other alternatives, and doing so in a safe and commercially-viable way. 

[67-03, J. Stephen Herring] The proposed facility makes an important contribution ..., 

converting the DUF6 to depleted uranium oxides and producing valuable fluorine in the process. 

[72-07, Rhonda Smith on behalf of the U.S. Environmental Protection Agency] In the 

DEIS, the summary of the costs and benefits of the proposed action explains that during 

operation of the plant about $56 million to $71 million (in 2009 dollars) in wages, benefits, goods 

and services would be spent annually. Approximately $554,400 offered in lieu of property tax 

would be paid to the Hobbs Municipal School District and the New Mexico Junior College during 

the construction period. Construction and operation of the facility would have additional indirect 

economic impacts by creating additional employment and economic activity within the region. 

Over the lifetime of operations, the low estimate of gross receipts taxes is $6,500,000 (in 2009 

dollars) to Lea County. With these summary of costs and benefits, it appears the project will be 

good for the local economy. 

[74-02, Paul D. Neuwirth] Because the facility will produce important fluoride products for 

markets in the United States, it will add to U.S. chemical manufacturing capability.

Response: The NRC staff acknowledges these commenters and appreciates the public 

participation. These comments express general support for the licensing of the proposed IIFP 

facility; however, they do not provide specific information that requires a response from the 

NRC. These comments are outside the scope of the EIS analysis because they do not directly 

relate to the content of the EIS. 
F–30 

Comment Summary: The following comment requests information on lifestyles of the Native 

Americans living in the region around the proposed IIFP facility that may lead to a 

disproportionate impact from environmental impacts on Native Americans living in the region 

around the proposed IIFP facility compared to non-Native Americans. 

[72-08, Rhonda Smith on behalf of the U.S. Environmental Protection Agency] The 

proposed facility is not in close proximity to any Tribal reservation or major native/tribal 

population or land base. According to demographic data in the DEIS, there are approximately 

eight hundred (800) American Indians living near Hobbs, New Mexico. There is no information 

presented in the DEIS as to whether American Indians who are living in this area are associated 

with any particular Tribe(s). There is no information provided upon which to form an opinion 

about whether the lifeways of American Indians in the area could include traditional or cultural 

practices that create additional or unique risk pathways. Also, there is no information provided 

upon which to determine whether potential environmental contamination, emergency events, 

increased traffic or other changes associated with the proposed facility could result in 

disproportionate impacts due to other factors that might make these persons more vulnerable or 

place them at greater risk. Please clarify in the FEIS. 

Many Tribes in the United States do have traditional cultural practices that may include 

ingestion or uses of plants, animals and other natural resources that are not common to 

non-Indians. In addition to traditional and cultural practices, diabetes and other health 

conditions may make some Native Americans more susceptible to risks or sensitive to 

environmental conditions. The FEIS should provide appropriate data and analysis of potential 

impacts to American Indians living in the area. 

Response: The Native Americans living in close proximity to the proposed IIFP facility are not 

in close proximity to any Tribal reservation or major native/tribal population or land base. 

However, most of the Native Americans within the region are associated with the Navaho, 

Cherokee, Mexican-American Indian, and Choctaw tribes. Many of the Native Americans in the 

region are associated with more than one tribe. 

As stated in Section 4.1.2.11, there will be no liquid radiological effluent releases and the air 

radiological releases from the proposed IIFP facility are projected to be extremely low. The 

exposure through ingestion or uses of plants, animals and other natural resources would be 

even lower. Therefore, preconstruction, construction, operation, and decommissioning of the 

proposed IIFP facility is not expected to result in disproportionately high and adverse impacts to 

Native Americans. No change was made to the EIS as a result of this comment. 

Comment Summary: The following comment expresses concern that the EIS underestimates 

the positive socioeconomic impacts of and the potential for improving environmental justice from 

the proposed IIFP facility. 

[39-03, Kathleen A. Moran] Also, I believe the positive economic and socio-economic and 

environmental justice effects will be more significant than stated in the report. The opportunity 

to develop cutting edge technology in the nuclear-medicine field will bring highly desirable jobs 

to the area and foster the development of the human resources needed to operate such a 

facility. The local population, which includes a high percentage of Hispanic peoples, will benefit 

from such opportunities. The schools and the community will benefit by the diversity that a 

new industry will bring. The community has seen that with the location of the National 

Enrichment Facility nearby as well. The impact of that development has been extremely 

positive on the community. 
F–31 

Response: The NRC staff acknowledges this commenter and appreciates the public 

participation. This comment expresses general support for the licensing of the proposed IIFP 

facility; however, it does not provide specific information that requires a response from the NRC. 

This comment is outside the scope of the EIS analysis because it does not directly relate to the 

content of the EIS. 

Comment Summary: The following comment requests information on the methods used to 

collect information on migrant worker populations in the region around the proposed IIFP facility 

to evaluate environmental justice. 

[72-09, Rhonda Smith on behalf of the U.S. Environmental Protection Agency] The DEIS 

states that NRC staff used the ESRI ArcGIS 9.3 software that accessed the 2000 decennial 

census to identify block groups; yet the section under Minority Populations states that the 

number of farms which fall either wholly or partially within the 50-mile radius is unknown. There 

is no additional information describing any other measures taken to get information about the 

migrant worker population on these farms. Please clarify in the Final ElS. 

Response: The NRC staff searched for public sources to obtain migrant farm worker 

population statistics. The U.S. Department of Agriculture (USDA) Census of Agriculture 

information showed that the number of farms that reported migrant workers in 2007 for 

operations located in counties either wholly or partially within 80 km [50 mi] of the proposed IIFP 

site (USDA, 2007). Section 3.9.1.2.2 explains that seasonal agricultural migrant workers may 

make up a portion of the minority population, but that the U.S. Census Bureau (USCB) does not 

produce a count of migrant workers. The USDA also reports temporary farm labor (workers 

working for less than 150 days). Temporary laborers are not characterized by USDA the same 

as migrant workers, but represent a worker population that depends on seasonal crops and may 

not have permanent employment or residence. Therefore, temporary farm labor could make up 

a portion of the migrant population. 

In response to the comment, the following additional information and clarifications for temporary 

labor in the region of influence (ROI) is provided. Seasonal agricultural (migrant) workers may 

make up a portion of the minority population within the 80-km (50-mi) radius. Although migrant 

worker population counts are not available from the USCB, the U.S. Department of Agriculture 

has collected information on farms that employ migrant labor and farms that report workers that 

work for less than 150 days per year. The number of farms that reportedly employ migrant 

laborers, the number of farms that employ workers for less than 150 days, and the number of 

workers that work less than 150 days, respectively, in each county that falls wholly or partially 

within the 80-km (50-mi) radius of the IIFP can be obtained from the USDA Web site (USDA, 

2007). The counties that fall wholly or partially within the 80-km (50-mi) radius of the IIFP facility 

are: New Mexico Lea County, New Mexico; Eddy County, New Mexico; Chaves County, New 

Mexico; Loving County, Texas; Winkler County, Texas, Andrews County, Gaines County, 

Yoakum County, Terry County, and Cochran County, Texas. No change was made to the EIS 

as a result of this comment. 

F.4.10 Noise 

Comment Summary: The following comment describes those regulations that pertain to 

noise control. 
F–32 

[62-03, Julie Roybal on behalf of the New Mexico Environment Department] 

Air Quality Bureau 

To further ensure air quality standards are met, applicable local or county regulations requiring 

noise and/or dust control must be followed; if none are in effect, controlling construction-related 

air quality impacts during projects should be considered to reduce the impact of fugitive dust 

and/or noise on community members. 

Response: By law, IIFP is required to obtain all applicable Federal, State, and local permits 

and approvals to conduct construction and operations activities. Also, 10 CFR 51.71(c) requires 

that the EIS provide a list of all Federal permits, licenses, approvals, and other entitlements for 

the proposed action and describe the status of compliance with these requirements, including 

requirements for noise control. In Section 1 of the environmental report (ER), the licensee lists 

all necessary permits from Federal, State, and local entities. Section 1.5 of this EIS describes 

the statutory and regulatory requirements that are applicable to the proposed IIFP facility. In 

addition, Table 1-1 describes laws, regulations, and agreements that apply to the facility; the 

regulatory basis and requirements for these items. Finally, Section 1.5.3 was updated to 

provide the status of the permits, licenses, authorizations, and approvals for construction and 

operation of the proposed IIFP facility, should NRC grant the license. 

F.4.11 Public and Occupational Health 

Comment Summary: The following comment discusses the chemical toxicity of uranium.

[TE-02, Robert Hayes] I do have something that just kind of bugs me, a technical issue, and 

that's that for uranium it's a heavy metal and as a heavy metal it's toxic, chemically toxic, just 

like lead or mercury, and as lead and mercury are toxic, you don't want to eat lead, you can get 

lead poisoning. Until you've enriched uranium to about 20 percent, the radiotoxicity does not 

outweigh the chemical toxicity, and so it's really the chemical toxicity that dominates any kind of 

hazard here. 

Response: Toxicity of uranium is discussed in Sections 3.3.2.2, 3.3.2.3, 3.3.2.4, 6.3.1.8, and 

A.1.1 of the SER (NRC, 2012). The NRC determined that the applicant identifies the chemical 

hazards at the proposed facility and has developed a safety program that is adequate to assure 

compliance with the regulations, as discussed in Section 6.2 and in SER Section 6.4. No 

change was made to the EIS as a result of this comment. 

Comment Summary: The following comment, which is applicable to multiple sections including 

public and occupational health, requests clarification on issues identified during the scoping 

meeting.

[72-10, Rhonda Smith on behalf of the U.S. Environmental Protection Agency] Page A–7, 

Paragraph A.2.2, Summary of Issues Raised: ... several comments from citizens express 

concerns regarding impacts or risks posed by the facility due to... possible health impacts 

associated with nuclear facilities. It was unclear where in the DEIS these specific concerns 

were addressed. Please address these concerns in the FEIS. 

Response: Appendix A includes a summary of all the issues raised during the scoping 

process. The NRC staff ensured that the EIS included relevant sections and text discussing the 

concerns raised from citizens during the scoping meeting. Public and occupational health 
F–33 

impacts are discussed in Sections 4.1.2.11 and 4.2.2.11. No change was made to the EIS as a 

result of this comment. 

F.4.12 Transportation/Waste Management 

Comment Summary: The following comments discuss potential positive national waste 

management impacts of the proposed IIFP facility. 

[06-04, Audrey Nelson; 07-04, Troy Beall; 08-05, Marshall Nadel; 09-04, Darrell Fisher; 

10-04, Erika Prestwich; 11-04, Dennis Manning; 12-05, Kurt Smith; 13-04, Justin 

Tomborello; 14-04, Mitchell N.; 15-04, Unknown Individual; 16-04, M. Mayer; 17-04, 

William Newsome; 18-04, Giorgio Borlenghi; 20-04, James Keane; 22-06, Cindy Bryan;

25-06, Monty D. Newman; 27-06, Paul Campbell; 28-06, Garry Buie; 29-06, David G. Jeff; 

30-06, Randy Pettigrew; 31-04, Ron Black; 32-05, Sam S. Spencer; 33-06, Sandy Nash;

34-06, 55-06, Jonathan Sena; 36-06, Kathi Bearden; 37-04, Michael Leighton; 43-06, 

Hal Brunson; 44-04, Janice Jamison; 47-04, Gary Schubert; 48-06, Pj Parker; 49-06, 

Mike Hoyl; 50-06, Sally Tomar; 51-04, TB-04, Gary Don Reagan; 52-04, Richard H. 

Neuwirth; 53-04, Charles R. Martin; 54-01-04, Jamie Suprenant; 54-02-04, Sandra Milner; 

54-03-04, Sylvia Ebel; 54-04-04, Dana Nunley; 54-05-04, Lara Haddad; 54-06-04, 

Douglas Hager; 54-07-04, Michael Hager; 54-08-04, Carl Fairman; 54-09-04, 

Novlette Spence; 54-10-04, Jodi Moore; 54-11-04, Connie Pucio; 54-12-04, Rebecca Pless; 

54-13-04, Patricia Medina; 54-14-04, Joe Glen Ensminger; 54-15-04, Linda Jianto; 

54-16-04, Sharon Ensminger; 54-17-04, LaDona Legg; 54-18-04, Regina Diaz; 54-19-04, 

Katrina Torres; 54-20-04, Mayolo Gonzalez; 54-21-04, Krystal Wallace; 54-22-04, 

Judy Tuttle-Wurth; 54-23-04, Kevin Heier; 54-24-04, Maribel Garcia; 54-25-04, 

Kerry Marschke; 54-26-04, Tami Dunlap; 54-27-04, Chris Hulsey; 54-28-04, Dana Estrada;

56-06, Brad Nesser; 57-05, David G. Stovall; 58-05, Robert Wallach; 59-06, Trent Clifton; 

63-04, Lane Allgood on behalf of the Partnership for Science and Technology; 67-04, 

J. Stephen Herring; 70-04, Jack Jacli; 71-06, Holis Riley; 73-06, Marilyn Burns; TA-05, 

Farok Sharif] I believe that [the project] will fulfill an important role in the safe and 

environmentally sound treatment of depleted uranium hexafluoride. 

[08-06, Marshall Nadel] By not converting depleted UF6 at Paducah and Portsmouth in a 

timely manner our Department of Energy left a terrible environmental legacy in the form of 

thousands of cylinders of depleted UF6- a most unstable uranium compound. 

[21-03, Jeff McCool , 35-03, Steve McCleery] I sincerely believe the facility will ... create an 

opportunity to produce a safe environment for the treatment of depleted uranium hexafluoride. 

[24-03, John Tanner] I believe that it ... will fulfill an important role in the safe and 

environmentally sound treatment of depleted uranium hexafluoride. 

[41-04, Michael P. Gallagher II on behalf of the Lea County Board of County 

Commissioners] The INIS facility will fulfill an important role in the safe and environmentally 

sound treatment of depleted uranium hexafluoride. 

[42-03, TC-03, Lisa Hardison on behalf of the Economic Development Corporation of 

Lea County] This business will compliment Lea County's uranium enrichment processing plant 

by providing the safe and environmentally sound treatment of depleted uranium hexafluoride 

that will ultimately produce important fluoride products for U.S. markets. 
F–34 

[46-06, Chris Frentzel on behalf of the International Brotherhood of Electrical Workers 

(IBEW), Local 611] I am also impressed with the approach to protecting our environment via 

the prudent treatment of depleted uranium hexafluoride. 

[60-04, Thomas E. Magette on behalf of EnergySolutions] This facility will ... provide a 

commercial entity to address the depleted uranium issue. 

[65-03, Michael McKenzie-Carter] The potential benefits of the proposed action-in particular 

decreasing the amount of stored DUF6 -are very positive. 

[67-05, J. Stephen Herring] The proposed facility makes an important contribution to the safe 

and environmentally responsible treatment of the tails from uranium enrichment, converting the 

DUF6 to depleted uranium oxides...As ceramic solids, the uranium oxides are suitable for the 

long-term storage or disposal of the depleted uranium, whereas the DUF6 is not a suitable 

chemical form for disposal. 

[74-03, Paul D. Neuwirth] I believe that the proposed International Isotopes fluorine products 

facility in Lea County, New Mexico will play an important role in the environmentally sound and 

safe treatment of depleted uranium hexafluoride. 

Response: The NRC staff acknowledges some commenters foresee a potential benefit to 

waste management from the construction and operation of the proposed IIFP facility, including 

the safe and environmentally sound treatment of depleted uranium hexafluoride. These 

comments express general support for the licensing of the proposed IIFP facility; however, they 

do not provide specific information that requires a response from the NRC. 

Comment Summary: The following comment requests clarification on waste management 

data supplied in the draft EIS. 

[62-04, Julie Roybal] Table 4-31 states that if CaF2 (produced at the IIFP facility) is not sold, 

total hazardous waste generation during operations would be 92,000–140,000 kg annually. 

However, Section 4.2.2.12 Waste Management, states: "The quantity of cumulative hazardous 

waste could be as much as 46,300 kg (51 tons) per year if a market for the CaF2 cannot be 

identified.” This discrepancy should be corrected in the final report. 

Response: As stated in Table 4-30 of the EIS, the total hazardous waste generation during 

operations would be 92,000 to 140,000 kg annually. The total hazardous waste in Table 4-40 is 

for Phase 1 of the operations and includes 90,000 to 136,000 kg of CaF2. The potential future 

Phase 2 facility expansion would provide additional deconversion capability. Expansion and 

operation of the expanded facility during Phase 2 would be a reasonably foreseeable action and 

is evaluated as a cumulative impact. Because of the added process technology used in the 

expansion to the Phase 2 facility, a large part of the fluoride-bearing spent scrubber liquids (the 

HF liquor portion) can be recycled to the add-on direct oxide deconversion process and 

recovered rather than be treated with lime to generate CaF2. When this scrubber liquor waste 

(weak aqueous HF solution) is recycled during Phase 2, it eventually enters the process final 

product stream where it is distilled and becomes valuable anhydrous HF product for sale to 

customers (IIFP, 2011). If a market for the CaF2 cannot be identified, then the quantity of 

cumulative hazardous waste, as stated in Section 4.2.2.12, could be as much as 46,300 kg (51 

tons) per year. Since this aqueous HF recycle/distillation capability does not exist within the 

Phase 1 process technology; a larger amount of scrubber spent liquors has to be treated with 

lime thus generating larger amounts of CaF2 during Phase 1 operation than the cumulative 
F–35 

hazardous waste generated by Phase 1 and Phase 2. An explanation has been added to 

Section 4.2.2.12 of the EIS. 

Comment Summary: The following comment outlines requirements that the applicant must 

follow should the applicant decide to transfer waste to the Waste Control Specialists (WCS) 

disposal facility in Texas or the U.S. Ecology waste disposal site in Washington. 

[68-01, Barbara Green on behalf of the Rocky Mountain Low-Level Radioactive Waste 

Compact] The following comments on the above-referenced INIS DEIS are being submitted on 

behalf of the Rocky Mountain low-level Radioactive Waste Compact ("Compact."). The 

Compact is an agreement among the states of Colorado, New Mexico, and Nevada, and was 

created pursuant to the federal low-level Radioactive Waste Act, and approved by Congress. 

Thus, the Compact is both an agreement among its member states, and federal law. The 

Compact has jurisdiction over the import to, export from, and disposal of low-level radioactive 

waste within the Compact Region. 

Import and Export of Low-level Radioactive Waste to and from the Facility 

Pages 2-24 and 4-56 state that the Compact must approve shipments from the facility of 

depleted uranium to the WCS disposal facility in Texas. This statement is true because the 

facility is located in New Mexico, a member state of the Compact, and the Texas facility is not 

within the Compact region. 

The DEIS notes that the U.S. Ecology facility in Richland, Washington, may be a disposal option 

for depleted uranium. Please add that Compact approval is required for the export of any and 

all low-level radioactive waste to this facility. 

Please add that the export of any and all low-level radioactive waste (as defined by the 

Compact) from the Compact region requires Compact approval. 

Also add that the import of any low-level radioactive waste (as defined by the Compact) to the 

INIS facility from outside the Compact will require Compact approval, unless the material is 

depleted uranium oxide as described in the Declaratory Order issued by the Board dated 

September 14, 2010 ("Order"), attached to this letter. The Order describes the conditions under 

which import of DUF6 to the facility from outside the Compact region would not require approval 

by the Compact. 

The Compact will continue to require approval for import of out-of-region low-level radioactive 

waste not covered by the Order. 

Response: The NRC staff acknowledges these comments and appreciates the public 

participation. However, they do not provide specific information that requires a response from 

the NRC. These comments are outside the scope of the EIS analysis because they do not 

directly relate to the content of the EIS. 

Comment Summary: The following comment, which is applicable to multiple sections including 

transportation and disposal of waste, requests clarification on issues identified during the 

scoping meeting.

[72-11, Rhonda Smith on behalf of the U.S. Environmental Protection Agency] Page A–7, 

Paragraph A.2.2, Summary of Issues Raised... several comments from citizens express 
F–36 

concerns regarding impacts or risks posed by the facility due to ... transportation and disposal 

of waste... It was unclear where in the DEIS these specific concerns were addressed. Please 

address these concerns in the FEIS. 

Response: Appendix A includes a summary of all the issues raised during the scoping 

process. The NRC staff ensured that the EIS included relevant sections and text discussing the 

concerns raised from citizens during the scoping meeting. Transportation issues are discussed 

in Section 3.10; waste disposal issues are discussed in Sections 4.1.1.2, 4.1.1.12, and 4.2.2.12. 

No change was made to the EIS as a result of this comment. 

Comment Summary: The following comment expresses concern about the transportation of 

liquid fluorine. 

[TG-01, Rob Hayes] My biggest question, which doesn't seem it got addressed, is the large 

liquid tanks of fluorine that would have to get transported on our roads. I would assume that 

there would be quite a few of them. Liquid fluorine is pretty nasty stuff, kind of like liquid 

chlorine, and I just wondered if and how that was taken into consideration. 

Response: As stated in Sections 4.1.2.9 and 4.1.2.12 the CaF2 will be packaged and shipped. 

IIFP must comply with all applicable Federal, State, and local laws and regulations, including the 

packaging and shipping regulations of Department of Transportation and EPA. No change was 

made to the EIS as a result of this comment. 

Comment Summary: The following comment expresses concern about the transportation of 

the depleted uranium and wastes. 

[TH-02, Rose Gardner] Regarding the transportation of the depleted uranium to the site and 

then the final disposition of the, I guess, oxides wastes after the processing, how would that 

material be moved, on trucks, trains, or what's the plan there? 

Response: Sections 2.1.3.2, 2.1.3.3 and 4.2.4.3 of the ER states that the proposed IIFP facility 

would receive the depleted uranium hexafluoride in 14-ton cylinders by truck. The depleted 

uranium oxides and all other low level waste materials generated at the facility would be 

transported by truck in metal containers, such as 242-(dry) liter (55 gallon) drums or 2,973-(dry) 

liter (105 cubic foot) boxes, that meet disposal facility’s waste acceptance criteria. These 

contains are shipped to a licensed facility in accordance with NRC and Department of 

Transportation packaging and shipping regulations. Trucks would carry 20 to 25 drums per 

shipment. The AHF will be transported in tank-truck trailers. The SiF4 and BF3 are transported 

in compressed gas tube trailers via semi-truck (IIFP, 2009a). No change was made to the EIS 

as a result of this comment. 

F.4.13 Accidents (Wildfires) 

Comment Summary: The following comment requests that the impact of wildfires be 

addressed in the EIS. 

[61-01, Stephen R. Spencer] Commenter David Herrell: Wildfire should be addressed. This 

area sees repeated wildfires that could threaten the safety of the proposed plant. 

Response: All credible accidents at the proposed IIFP facility, including those initiated by 

natural events, are considered by IIFP in the Integrated Safety Analysis. As discussed in 
F–37 

Section 7 of the SER (NRC, 2012), wildfires can occur in areas surrounding the facility. The 

potential for a wild land fire to impact the site is not considered to be a credible event given the 

dry desert topography and lack of forestry and vegetation. Regardless, IIFP has committed to 

maintain vegetation controls to minimize the fire hazard at the facility. No change was made to 

the EIS as a result of this comment. 

F.4.14 Cumulative Impacts 

Comment Summary: The following comment discusses pre-construction activities. 

[64-03, Mathew Wunder on behalf of the State of New Mexico Department of 

Game & Fish] Pre-construction clearing, grading, road-building and utility installation are 

treated as cumulative effects in the DEIS, because no NRC license is required. However these 

actions are logically integral to construction and operation of the facility. 

Response: NRC regulations, including, 10 CFR 40.4, define construction to explicitly exclude 

certain activities, such as land clearing and erection of administrative buildings, that do not have 

a reasonable nexus to radiological health and safety or the common defense and security. 

These activities, termed “preconstruction” activities, are regarded as “non-Federal actions” that 

do not require NRC approval or oversight. Thus, the impacts of these actions are not considered 

to be direct impacts of the Federal action (i.e., issuance of a license); however, the NRC does 

consider preconstruction activities with respect to cumulative impacts. No change was made to 

the EIS as a result of this comment. 

F.4.15 Miscellaneous Comments 

Comment Summary: The following comment expresses concern about underground piping. 

[TH-03, Rose Gardner] Are there any underground piping in the processing of the materials? 

In other words, under the building will there be any underground pipes carrying the dangerous 

materials? 

Response: IIFP in the License Application in Section 1.1.1 states that the facility will not have 

underground piping for transporting process waters. The License Application indicates a 

number of underground pipes will be built for transporting water including fire mains, sanitary 

sewer, and well water. The IIFP facility will also have some underground piping to transfer 

industrial gases (e.g., natural gas) (IIFP, 2009b). No change was made to the EIS as a result of 

this comment.

Comment Summary: NRC has determined that the following comment does not directly relate 

to a specific resource area in the EIS. 

[23-02, Anonymous] But it would be in International Isotopes Fluorine Products Inc. best 

interest to not contract Tactical Security Solutions (TSS) out of Hobbs, NM, for their security 

measure needs. TSS officers currently working @ URENCO USA in Eunice, NM, have been 

stealing things from URENCO personnel. How can you trust TSS personnel to not steal from 

this facility if it ever gets built??? 

Response: The NRC staff acknowledges this comment and appreciates the public 

participation. However, these comments are outside the scope of the EIS analysis because 
F–38 

they do not directly relate to the content of the EIS. No change was made to the EIS as a result 

of this comment. 

Note: [61-02, Stephen R. Spencer] A comment document was submitted with a series of 

comments attributed to Amanda L. Nisula related to the discussion of the No Action Alternative 

and Reasonable Alternatives to the Proposed Action in the draft EIS, another comment related 

to navigation through the draft EIS, and comments on two tables attributed to the draft EIS. 

[69-01, Amanda L. Nisula] subsequently rescinded these comments. 

Comment Summary: The following comment is regarding the safety record of the applicant. 

[TI-01, Miles Chedekel] I just wanted to know what the safety record is of this applicant for 

other facilities that they have run of this type. 

Response: The NRC staff acknowledges the commenter and appreciates the public 

participation. This comment is outside the scope of the EIS analysis because it does not 

directly relate to the content of the EIS. No change was made to the EIS as a result of 

this comment. 

F.5 REFERENCES 

(Daras, 2009) Daras, S. 2009. “Cultural Resource Survey of 640 acres for the Arkansas 

Junction Site, Lea County, New Mexico. 2009 Report No. 1224.” Prepared for New Mexico 

State Land Office by Lone Mountain Archeological Services, Inc. 2009. ADAMS Accession No. 

ML113120204. 

(IIFP, 2009a) International Isotopes Fluorine Products, Inc. 2009. Fluorine Extraction Process 

and Depleted Uranium De-conversion Plant (FEP/DUP) Environmental Report, Revision A, ERIFP-001. December 27, 2009. ADAMS Accession No. ML100120758. 

(IIFP, 2009b) International Isotopes Fluorine Products. Inc. 2009. Fluorine Extraction Process 

and Depleted Uranium De-conversion Plant (FEP/DUP) License Application, Revision A, ERIFP-001. December 23, 2009. ADAMS Accession No. ML100630503. 

(IIFP, 2011) International Isotopes Fluorine Products, Inc. “Fluorine Extraction Process and 

Depleted Uranium De-Conversion Plant (FEP/DUP) Official Responses to Environmental Report 

RAIs, Revision A.” ADAMS Accession No. ML100970481. 

(GL Environmental, 2010c) GL Environmental, Inc. 2010. “2010 Soil and Vegetation Survey 

Report. ” Prepared for International Isotopes Fluorine Products. November 29, 2010. ADAMS 

Accession No. ML112720310. 

(NMGF, 2010a) New Mexico Department of Game and Fish. 2010. “New Mexico Deer Harvest 

Survey Report for the 2009-2010 Season.” Available at http://www.wildlife.state.nm.us/ 

recreation/hunting/harvest/documents/2009-2010_DeerHarvestReport.pdf. Accessed October 

14, 2010. ADAMS Accession No. ML103090088. 

(NRC, 2003) U.S. Nuclear Regulatory Commission. 2003. “Environmental Review Guidance 

for Licensing Actions Associated With NMSS Programs,” NUREG–1748. 
F–39 

(NRC, 2012) U.S. Nuclear Regulatory Commission. 2012. “Safety Evaluation Report for the 

International Isotopes Fluorine Products, Inc. Fluorine Extraction Process and Depleted 

Uranium Deconversion plant in Lea County, New Mexico,” NUREG–2116. ADAMS Accession 

No. ML113140271. 

(SORA, 2011) SORA. 2011. “Lesser Prairie-Chicken Survey on the International Isotope 

Flourine Products Project Site-2011.” Prepared for International Isotopes, Inc., May 24, 2011. 

ADAMS Accession No. ML112720317. 

(USDA, 2007) U.S. Department of Agriculture. “Table 7: Hired Farm Labor-—Workers and 

Payroll: 2007.” 2007 Census of Agriculture. Available at http://www.agcensus.usda.gov/. 

(Accessed March 21, 2012).




UNITED STATES 

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

--------------------

OFFICIAL BUSINESS
 

 

NUREG-2113

Final

Environmental Impact Statement for the Proposed Fluorine Extraction Process 

and Depleted Uranium Deconversion Plant in Lea County, New Mexico